Adnexus Inc. v. Meta Platforms, Inc
Authored by: Jeremy J. Gustrowsky
A recent Federal Circuit decision has breathed new life into a patent dispute between Adnexus Inc. and Meta Platforms, Inc. (the parent company of Facebook), focusing on the technology behind online advertising. At the heart of the case is U.S. Patent No. 8,719,101, which covers a system for delivering targeted ads to users based on their preferences and contact information. Adnexus claims that Meta’s “Lead Ads” feature, which allows businesses to collect information from Facebook users through interactive ads, infringes on this patent.
The district court originally dismissed Adnexus’ lawsuit, finding that the company’s complaint did not plausibly allege that Meta’s Lead Ads used “delivery method preferences” as required by the patent. The court reasoned that simply using a user’s contact information (like an email address) was not the same as using a “delivery method preference,” and therefore, the complaint did not meet the necessary legal standard to move forward.
However, the Federal Circuit disagreed with this approach. The court said that the district court had essentially made a decision about the meaning of key terms in the patent (“contact information” versus “delivery method preferences”) without giving Adnexus a fair chance to argue its interpretation. The appellate court emphasized that, at this early stage, the facts alleged by Adnexus—including claims that Lead Ads can retrieve user preferences and automatically fill in forms based on stored information—should be accepted as true.
The court also pointed out that it’s not uncommon for terms like “contact information” and “delivery method preferences” to overlap, especially in the context of online advertising. For example, a user’s preferred contact method (such as email or phone) could be considered both contact information and a delivery preference. Because of this, the court decided that Adnexus had presented a plausible claim that deserved further consideration.
As a result, the dismissal was vacated, and the case was sent back to the district court for further proceedings. This means Adnexus will have another opportunity to prove its claims that Meta’s Lead Ads system infringes its patent.