Recently, the U.S. Court of Appeals for the Federal Circuit issued an opinion in Mirror Worlds Technologies, LLC v. Meta Platforms, Inc., Nos. 2022-1600, -1709 (Dec. 4, 2024), affirming a district court’s summary judgment of noninfringement.
Mirror Worlds sued Meta Platforms (hereinafter “Facebook”) for infringement of Mirror Worlds’ patents directed to methods of storing, organizing, and presenting data in time-ordered streams on a computer system. On remand from the Federal Circuit after it reversed the grant of an early motion for summary judgment filed by Facebook, and after discovery closed, Facebook again moved for summary judgment arguing the asserted claims were invalid as directed to patent ineligible subject matter under 35 U.S.C. § 101 and were not infringed. While the district court rejected Facebook’s invalidity challenge, it granted Facebook’s motion for judgment of noninfringement, concluding that no reasonable juror could find that all limitations of the asserted claims were met by the accused features (certain backend systems supporting Facebook’s “News Feed”, “Timeline”, and “Activity Log” features) of Facebook’s service. Mirror Worlds appealed, and Facebook cross-appealed.
The Federal Circuit affirmed the district court’s judgment of noninfringement and, therefore, did not need to address Facebook’s cross-appeal on validity. With respect to infringement, the Court rejected Mirror Worlds’ argument that the district court “overlooked” evidence demonstrating a genuine dispute of material fact as to the “glance view” limitation of the claims of two of the asserted patents. Specifically, the Court held the district court did not err in excluding unauthenticated screenshots from third-party websites and expert testimony relying thereon and that no other record evidence saved Mirror Worlds from summary judgment. As for the remaining asserted patent, the Court rejected Mirror Worlds’ challenge to the district court’s construction of the phrase “data unit” in the “main stream” claim element and agreed with the district court that the record confirmed the “main stream” element was not met.
