Facts

Autocompletion technology suggests ways for the user to complete her search as she actively types it into a search bar. Masterobjects, Inc. owns four patents associated with autocompletion technology: U.S. Patents Nos. 8,539,024; 9,760,628; 10,311,073; and 10,394,866, which all descend from U.S. Patent No. 8,112,529 filed in 2001. Patent No. 8,539,024 described the invention of a "session-based" system that sends a character-by-character string of data to an intelligent server that can be configured to immediately analyze the lengthening string of characters and return the client increasingly appropriate database information as the client sends the string. Meanwhile, Meta Platforms Inc. has the Typeahead system that suggests completions for relevant pages, events, and applications based on the user's input. The system is supported by both frontend functionality, provided by the user's device, and backend functionality, provided by Meta's servers. The entire string of words in the search bar is sent from each Typeahead request first through the frontend then through the backend. Masterobjects brought a patent infringement claim against Meta Platforms Inc. in the District Court for the Western District of Texas in February 2020. The case was then transferred to the District Court for the Northern District of California.

PLAINTIFF'S CONTENTIONS: Plaintiff alleged that defendant infringed 43 claims across four patents, U.S. Patents Nos. 8,539,024, 9,760,628, 10,311,073, and 10,394,866. Plaintiff also contended that the asynchronous limitation of initiating communications between the customer and server in the infringing patents was a non-limiting embodiment that did not distinguish the two inventions. Further, plaintiff maintained that the description of asynchronous communication had no bearing on their claim because every asserted claim says the client sends messages and the server responds to the client's messages.

DEFENDANT'S CONTENTIONS: Defendant argued that in the patented system, the "query messages" sent between the client and the server contained "just the changes" in what the user has input into a growing search string and that collateral estoppel based on prior decisions in the Northern District barred plaintiff's arguments. Defendant also contended that its system did not infringe because the system cannot initiate a communication from the server to the client, while all the claims-in-suit require asynchronous communications between the server and client.

Result

The court granted Meta's motion for summary judgment of noninfringement and Section 101 invalidity.