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Judge Koeltl Holds Facebook Systems are Not “Main Stream”

On August 11, 2018, Judge Koeltl (S.D.N.Y.) granted Defendant Facebook, Inc.’s motion for summary judgment of non-infringement of three patents alleged to read on Facebook’s “News Feed” “Timeline,” and “Activity Log” functionalities.[1]  Plaintiff Mirror Worlds Techs., LLC (“Mirror Worlds”) owns the three patents.

The Court determined that all three patents-in-suit include two necessary limitations: (1) a “main stream,” meaning “a time-ordered sequence of data units that is inclusive of every data unit received by or generated by the computer system;” and (2) a “substream,” which is a time-ordered streamed subset of data units drawn from the “main stream”.  The Court found that Mirror Worlds failed to demonstrate the existence of a “main stream” data feed in the second step.

Facebook argued, and the Court agreed, that its “TAO” backend data storage and organization system is essential to the infringement analysis, even though Mirror Worlds has not accused that system of infringement.  Specifically, the court found that content displayed by Facebook’s accused systems ultimately comes from the “TAO” backend data storage system, which was not accused.  Mirror Worlds argued instead that two intermediate systems, the “Multifeed Leaves” and the “Timeline DB”, provide the “main stream” data feeds. The Court found that the two systems do not contain all of the data required to constitute the “main stream” data feed and, as such, Mirror Worlds failed to identify anything that can be the “main stream” data feed.

The case is Mirror Worlds Techs., LLC v. Facebook, Inc., No. 17-cv-3473 (S.D.N.Y. Aug. 11, 2018).

[1] The three patents in suit are U.S. Patent Nos. 6,006,227; 7,865,538; and 8,255,439.