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Federal Circuit Affirms Non-Infringement At Summary Judgment On “Document Stream” Patents In Mirror Worlds Technologies, LLC v. Meta Platforms, Inc.
12/11/2024Mirror Worlds Technologies, LLC ("Mirror Worlds") owns U.S. Patent Nos. 6,006,227; 7,865,538; and 8,255,439, which claim methods for storing, organizing, and presenting data in time-ordered streams on a computer system. In 2017, Mirror Worlds filed suit against Meta Platforms, Inc. (formerly Facebook, Inc.) in the U.S. District Court for the Southern District of New York (“District Court”), alleging that several Facebook features infringed the patents. The District Court granted Facebook summary judgment on non-infringement while denying Facebook’s 35 U.S.C. § 101 ineligibility defense. Mirror Worlds appealed the non-infringement decision; Facebook cross-appealed on ineligibility. See Mirror Worlds Technologies, LLC v. Meta Platforms, Inc., 22-1600, 2022-1709.
On December 4, 2024, the U.S. Court of Appeals for the Federal Circuit issued a precedential opinion, affirming on non-infringement and declining to reach ineligibility because the patents at issue had expired more than six years prior. The Court awarded costs to Facebook.
Asserted Patents
The ’227 patent, entitled “Document Stream Operating System,” and the ’538 and ’439 patents, both entitled “Desktop, Stream-based, Information Management System,” all disclose “methods for operating a computer system” where documents are automatically stored chronologically. The ’227 patent describes a “main stream” that includes every document or “data unit” received or generated by the computer system, and “substreams” created by filtering based on user-generated search criteria. The ’538 and ’439 patents also include a “glance view” feature, which displays document-specific information when a user hovers over a document. All three parents expired by the end of April 2018.
Accused Features
Mirror Worlds alleged that the backend systems to Facebook’s News Feed, Timeline, and Activity Log features—the Multifeed system, which serves the News Feed feature, and the Timeline system, which serves the Timeline and Activity Log features—infringed the patents.
Federal Circuit's Analysis
The Federal Circuit first addressed the “glance view” limitation recited in the ’538 and ’439 patents. Mirror Worlds argued that the District Court had “‘overlooked’ evidence that demonstrates ‘at least a genuine dispute of material fact,’” specifically, Mirror Worlds’ expert testimony. That expert testimony, however, had been properly excluded by the District Court, because it relied on “screenshots” that were unauthenticated, undated, and “from third-party websites.” The Federal Circuit affirmed summary judgment that Facebook did not infringe the ’538 and ’439 patents.
The Federal Circuit next addressed the “main stream” limitation of the ’227 patent. The Court upheld the District Court's construction of “data unit” as “an item of information.” It rejected Mirror Worlds’ argument that the construction was “overly broad,” noting that the claim was “facially broad”—the claim term had a broad ordinary meaning and the specification “underscore[d]” that breadth. The Court noted that Mirror Worlds’ prior presentations to the Patent and Trademark Office in a post-grant proceeding echoed the Court’s read. The Court resolved claim construction on the “strong intrinsic evidence” and, therefore, did not “address the slight extrinsic evidence invoked by Mirror Worlds.” The Court then affirmed summary judgment of non-infringement for the “main stream” limitation, again rejecting Mirror Worlds’ proposed evidence and expert testimony as speculative and unsupported, and, therefore, unable to create a genuine issue of fact.
Key Take-Away
The Federal Circuit’s analysis reaffirms the importance of concrete and specific evidence at summary judgment to create a genuine issue of material fact. Generalizations or unsupported expert opinions will not suffice to proceed to trial.
