Mirror Worlds Techs., LLC v. Meta Platforms, Inc
Authored by: Jeremy J. Gustrowsky
A recent Federal Circuit decision has closed the book on a long-running patent dispute between Mirror Worlds Technologies, LLC and Meta Platforms, Inc. (formerly Facebook, Inc.), with the court affirming that Facebook did not infringe three patents related to organizing and displaying information in time-ordered streams. Mirror Worlds had accused Facebook’s News Feed, Timeline, and Activity Log features of violating U.S. Patent Nos. 6,006,227; 7,865,538; and 8,255,439, which describe systems for automatically storing and presenting documents and data in chronological order.
The heart of the case centered on whether Facebook’s backend systems—specifically, the Multifeed and Timeline systems—met the patents’ requirements for storing “every data unit” in a “main stream.” The court found that Facebook’s systems received certain information, such as “coefficient data” (used to determine the strength of relationships between users), that was not stored in the accused “main stream” databases. Because the patents required that every piece of data received or generated by the system be included in the main stream, even a single omission meant there was no infringement.
Another key issue was the “glance view” limitation in two of the patents, which required the display of an abbreviated version of a document indicative of its content when a user hovered over it. The court agreed with the district court that Mirror Worlds failed to provide admissible evidence showing Facebook’s systems displayed such a view. The expert testimony Mirror Worlds relied on was excluded because it was based on unauthenticated screenshots, and the remaining evidence was insufficient.
Ultimately, the Federal Circuit upheld the district court’s summary judgment in favor of Facebook, finding no infringement of any of the asserted patents. The court also dismissed Facebook’s cross-appeal on patent eligibility, noting that the patents had already expired and the non-infringement ruling resolved the dispute. This decision highlights the importance of both claim construction and the need for solid, admissible evidence when alleging patent infringement in complex software systems.