Case 1:25-cv-12127-BEM Document 40 Filed 10/30/25 Page 1 of 13
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
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`COGMEDIA LLC,
`Plaintiff, .. .
`Civil Action No. 1:25-cv-12127
`V.
`REQUEST FOR HEARING
`META PLATFORMS, INC., Leave to File Granted October 30, 2025
`Defendant.
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`DEFENDANT META PLATFORM, INC.’S
`REPLY IN SUPPORT OF ITS MOTION TO DISMISS
`UNDER RULE 12(b)(6)
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`IIL.
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`Case 1:25-cv-12127-BEM Document 40 Filed 10/30/25 Page 2 of 13
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`TABLE OF CONTENTS
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`YN g4 111 1 1<) L AP PRRPPRRUPPRRPR 2
`A. The Complaint fails to state a claim for direct infringement under either of
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`TES SCEMATIOS. c..eutiitiiteitt ettt ettt ettt ettt et ettt ettt eb e st beeanesaeeae e 2
`B. Cogmedia’s reliance on SiRF is fatally misplaced and ignores a decade of
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`Clarifying PreCcedent. .......ccveevuiiiiiieecie e 3
`C. Cogmedia’s conclusory allegations of “in-house testing” are insufficient to
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`SUIVIVE dISTIISSAL ...ttt 7
`D. Dismissal with prejudice is the appropriate remedy. ........cccoeeveevieiiieniieeiienieeen. 8
`CONCIUSION ..ottt ettt e sae e e 8
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`Case 1:25-cv-12127-BEM Document 40 Filed 10/30/25 Page 3 of 13
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`TABLE OF AUTHORITIES
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`Page(s)
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`Cases
`Adaptix, Inc. v. Apple, Inc.,
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`78 F. Supp. 3d 952 (N.D. Cal. 2015) uieueeeiieiieiieiieie ettt ettt sne e 6
`Akamai Techs., Inc. v. Limelight Networks, Inc.,
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`797 F.3d 1020 (Fed. Cir. 2015) (AKGMAT V) oot passim
`Bot M8 LLC v. Sony Corp. of Am.,
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`4 F.4th 1342 (Fed. Cir. 2021) coiiieieieeieeee ettt ae e nas 7,8
`Crandall Techs. LLC v. Vudu, Inc.,
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`No. 20-cv-04849-VC, 2020 U.S. Dist. LEXIS 204571 (N.D. Cal. Nov. 2,
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`2020) 1ttt ettt h ettt ettt h e e bt en bt eh e e bt ea bt en e e bt et e enee bt enbeente bt enteeneennes 8
`De La Vega v. Microsoft Corp.,
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`No. W-19-CV-00612-ADA, 2020 WL 3528411 (W.D. Tex. Feb. 11, 2020)......cc.ccccerrerurennee. 8
`Ericsson, Inc. v. D-Link Sys.,
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`773 F.3d 1201 (Fed. Cir. 2014)...ciiiiieieeeeeee ettt passim
`GoTV Streaming, LLC v. Netflix, Inc.,
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`INOL 2:22-CV0T556 e 7,8
`GoTV Streaming, LLC v. Netflix, Inc.,
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`No. 2:22-c¢v-07556-RGK-SHK, 2023 U.S. Dist. LEXIS 161783 (C.D. Cal.
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`NS o T I R ) TP TRSTPSRRURSPPSII 8
`IBM v. Booking Holdings Inc.,
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`T75 F. App X 674 (Fed. Cir. 2019) .o 5,6
`Koninklijke Philips N.V. v. Zoll Med. Corp.,
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`656 F. App X 504 (Fed. Cir. 2016) ..cviiuieiieieeiieieeie ettt e e eneesneeneas 6
`Lyda v. CBS Corp.,
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`838 F. 3d 1331 (Fed. Cir. 2010)..cueiiieiieieeieeeee ettt ettt 8
`Ortiz & Assocs. Consulting LLC v. Microsoft Corp
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`No. 19-CV-8262, 2021 WL 3033533, at *2 (N.D. IlL. July 19, 2021)..cc.ceviriiieieiieieieene 6
`Rampage LLC v. Glob. Graphics SE,
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`No. 16-CV-10691-ADB, 2017 WL 239328 (D. Mass. Jan. 19, 2017) ...ccccevveeiienieiieieieenee 8
`Sapphire Crossing LLC v. Abbyy USA Software House, Inc.,
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`497 F. Supp. 3d 762 (N.D. Cal. 2020) ....ceiuieiieieiieieeiesiteie ettt 7
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`Case 1:25-cv-12127-BEM Document 40 Filed 10/30/25 Page 4 of 13
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`Sentius Int’l, LLC v. Apple Inc.,
`No. 4:20-cv-00477-YGR, 2020 U.S. Dist. LEXIS 97576 (N.D. Cal. June 2,
`2020) 1ttt ettt ettt et ettt et te et e st e ae et e ertenseenbeenaeseenteente st enteentenseenteeneeees 7
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`SiRF Tech., Inc. v. ITC,
`601 F.3d 1319 (Fed. Cir. 2010)....uuiiiiiieeiieeeiee ettt enree e eas passim
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`Wi-LAN Inc. v. Sharp Elecs. Corp.,
`362 F. Supp. 3d 226 (D. Del. 2019)...uiiiiieiieeee ettt 6
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`- 1 -
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`Case 1:25-cv-12127-BEM Document 40 Filed 10/30/25 Page 5 of 13
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`In its Opposition, Cogmedia stakes its entire case on a single, fifteen-year old case: SiRF
`Tech., Inc. v. ITC, 601 F.3d 1319 (Fed. Cir. 2010). Cogmedia erroneously represents SiRF as a
`broad, dispositive holding that blesses any direct infringement claim against a software provider
`so long as some steps occur on the defendant’s server. This is a profound misreading. A decade of
`subsequent Federal Circuit jurisprudence, including the clarifying holding in Ericsson, Inc. v. D-
`Link Sys., 773 F.3d 1201, 1221-22 (Fed. Cir. 2014) and the en banc decision in Akamai Techs.,
`Inc. v. Limelight Networks, Inc., 797 F.3d 1020, 1022 (Fed. Cir. 2015) (Adkamai V), has carefully
`cabined SiRF to its unique facts and established a clear, controlling framework for analyzing
`divided infringement. This framework, not Cogmedia’s isolated reading of SiRF, governs the case
`and compels dismissal.
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`In SiRF, direct infringement was predicated on a crucial fact: the end user played no role
`in the claimed method because their devices automatically performed the processing step. 601
`F.3d at 1331. In Ericsson, the Federal Circuit clarified this was a narrow holding and explained
`how to analyze scenarios, like here, where end users actively performed claimed steps on their
`own devices: “Our decision in SiRF'is not applicable here because all of the steps of the method .
`. . are performed on the end product, which is controlled by a third party. Unlike the method in
`SiRF, there are no steps automatically performed by equipment controlled by [defendant].”
`Ericsson, 773 F.3d at 1221-22 (citations omitted) (emphasis added). This is dispositive. Cogmedia
`does not and cannot allege that the user’s only role here is to sit passively while their devices
`automatically performed the claimed steps like in SiRF. Rather, Cogmedia’s own Complaint shows
`that users play an indispensable role—the user triggers the method with a “selection of the at least
`one data item,” the user comments, votes, copies, or links, and the user’s device “display[s]” the
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`allegedly infringing “card.” Dkt. 1 4] 15-16, 49-56; *371 patent, Claim 1. Cogmedia’s case thus
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`falls squarely within the rule of Ericsson, not the narrow exception of SiRF'.
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`Because SiRF is not applicable here, this case is governed by the single-entity rule
`articulated by the en banc Federal Circuit in Akamai V. Under this controlling precedent, where
`multiple actors perform the claimed steps, liability for direct infringement can attach only if a
`single defendant “directs or controls” the others’ performance or there is a “joint enterprise.”
`Akamai V, 797 F.3d at 1022. Plaintiff’s Complaint pleads no facts supporting either, and Plaintiff
`does not argue otherwise. By ignoring Ericsson and Akamai V, and clinging to a decontextualized
`reading of SiRF, Plaintiff asks the Court to ignore a decade of binding precedent. The Court should
`reject Plaintiff’s erroneous argument and grant Meta’s motion to dismiss with prejudice.
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`L. ARGUMENT
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`A. The Complaint fails to state a claim for direct infringement under either of
`its scenarios.
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`Cogmedia defends with a classic red herring: it argues that Meta overlooked a supposedly
`distinct “web browser scenario.” Opp. at 2. But this is a distinction without a difference. The patent
`claims and Complaint show that both scenarios suffer from the same incurable defect: they
`describe quintessential divided infringement where essential steps are performed by an end user.
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`The claims here are triggered “responsive to a user selection of the at least one data item.”
`’371 patent, Claim 1[a]. This is not, as Cogmedia might wish, mere introductory fluff, but rather
`an indispensable affirmative step. Without it, none of the subsequent claimed steps, e.g., “causing
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`configuring . . .,” “extracting . . .,” and “displaying . . .,” can occur. Plaintiff’s own Complaint
`illustrates this step with an end user sharing a National Geographic travel article in a Facebook
`Post. Dkt. 1 9 48. Under Plaintiff’s own theory, the user is not a passive bystander, but rather the
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`initiator of, and a key contributor to, the allegedly infringing process. The claims further recite a
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`series of “graphically accessible functions” that are, by their very nature, performed by users: “a
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`comment function,” “a vote function,” “a copy function,” and ““a link function.” 371 patent, Claim
`1. Plaintiff’s own Complaint alleges that users—not Meta—perform these functions. See, e.g., Dkt.
`1 9 51. Finally, a web browser on the user’s device “display[s]” the allegedly infringing “card” to
`the user. 371 patent, Claim 1[c]; Dkt. 1 9 16.
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`Plaintiff’s “web browser scenario,” like its “Facebook application scenario,” provides a
`textbook example of “more than one actor [being] involved in practicing the steps. . ..” Akamai V,
`797 F.3d at 1022. Cogmedia’s attempt to distinguish its two scenarios only highlights that the
`distinction is illusory—both scenarios describe a process that is fundamentally divided, collapsing
`Cogmedia’s argument, and bringing us to divided infringement. Missing from Cogmedia’s
`Opposition is any argument that its Complaint has pled any facts in support of a theory that Meta
`“directs or controls” the end users, or that the actors form a “joint enterprise.” Akamai V, 797 F.3d
`at 1022-23. Because Cogmedia has alleged facts describing divided infringement without
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`“direction or control” or “joint enterprise,” its infringement claims fail as a matter of law. /d.
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`B. Cogmedia’s reliance on SiRF'is fatally misplaced and ignores a decade of
`clarifying precedent.
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`Cogmedia portrays SiRF protecting any direct infringement claim against a software
`provider so long as the defendant’s server is somehow involved. Opp. at 7. But this interpretation
`ignores the crucial factual predicate of SiRF, and disregards a subsequent line of cases explicitly
`limiting SiRF and clarifying that it does not apply to facts like those here.
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`The direct infringement finding in SiRF was narrow and fact-specific. In SiRF, the
`defendant manufactured GPS chips that “when incorporated into end-user GPS devices, allow[ed]
`such devices to compute absolute position using the GPS system.” 601 F.3d at 1323. The accused
`chips “automatically perform[ed] the disputed steps . . . .” Id. at 1331 (emphasis added). Nobody
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`else—not the equipment manufacturers, software developers, or end users—could modify how the
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`chips performed. /d. And “only [defendant’s] actions are involved in ‘processing’ or ‘representing’
`the data.” Id. On appeal, the Federal Circuit explained that this was not a divided infringement
`case because the claim did not “specif[y] performance of a step by a third party . . ..” Id. at 1329.
`Rather, the claims “can be performed and are performed by a single party.” /d. Thus, there was no
`divided infringement because no claimed steps required “specified actions be taken by
`[defendant’s] customers or by the end users of the GPS devices.” 1d.
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`Cogmedia’s case against Meta is the exact opposite. According to Plaintiff’s own
`Complaint, the users and their devices here play an indispensable role in initiating the claimed
`method, in performing the four “graphically accessible functions,” and in “display[ing]” the
`allegedly infringing “card[s].” Because the claims specify performance of steps by a third party,
`this is divided infringement for which “control or direction of the performance of that step by the
`accused infringer is required.” SiRF, 601 F.3d at 1329.
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`The Federal Circuit rejected a broader reading of SiRF in Ericsson, 773 F.3d at 1221-22.
`In Ericsson, the defendant sold a variety of devices, including laptops and routers that used the
`Wi-Fi standard. /d. at 1211. Like Cogmedia, the plaintiff invoked SiRF to argue direct
`infringement. /d. at 1220. The Federal Circuit summarized the facts of SiRF:
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`The method claims at issue in SiRF required some, but not all, of the steps of the claim to
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`be executed by a satellite, which was controlled by the accused infringers. The remaining
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`steps were then automatically performed by the accused GPS products, which were in
`possession of the end users. In SiRF, accordingly, we concluded that, on these facts, it was
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`the accused infringers that performed all the steps required for direct infringement, not the
`customers who possessed the GPS products.
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`Id. at 1221 (emphasis added). The Federal Circuit then rejected plaintiff’s SiRF argument:
`“Contrary to [plaintiff’s] assertions, our decision in SiRF' did not create direct infringement liability
`whenever an alleged infringer sells a product that is capable of executing the infringing method.”
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`Id. at 1221. The Federal Circuit explained:
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`Our decision in SiRF is not applicable here because all of the steps of the method in
`claims 1 and 2 of the ’215 patent are performed on the end product, which is controlled by
`a third party. Unlike the method in SiRF, there are no steps automatically performed by
`equipment controlled by [defendant].
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`Id. at 1221-22 (emphasis added). Turning to the facts, the court explained that because defendant
`did not perform each step or direct or control others in doing so, there was no direct infringement.
`Id. at 1222. As in Ericsson, SiRF is inapplicable because the end user affirmatively performs steps,
`including “selection of the at least one data item,” the four “graphically accessible functions,” and
`the “display[ing]” of the “card[s]” on the user device.
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`Despite Plaintiff’s suggestion to the contrary, Opp. at 10-11, courts have routinely followed
`Ericsson finding SiRF inapplicable to facts similar to those alleged here. In IBM v. Booking
`Holdings Inc., 775 F. App’x 674, 675 (Fed. Cir. 2019), the plaintiff’s alleged that defendants’
`“web applications and mobile applications (Priceline, Kayak, and OpenTable) infringed . . . .” One
`of the claimed steps recited “selectively storing advertising objects at a store established at the
`reception system.” Id. It was undisputed that this “storing step occurs at the user’s reception
`system.” Id. at 678. On appeal, the plaintiff argued that it was not a divided infringement case and
`that the situation was similar to SiRF. Id. at 677. The Federal Circuit rejected plaintiff’s argument:
`“[T]his case is distinguishable from SiRF because some third party (at least a party that is not
`[defendant]) is involved in the performance of a method step.” /d. at 678 (emphasis original). The
`court explained that while there was some dispute over who performed the storing step—a user,
`the user’s device’s manufacturer, or the user’s browser’s provider, “the answer does not matter for
`our purposes. What matters in this case is that [defendant] is not performing the storing step.” /d.
`(emphasis original). Accordingly, the Federal Circuit analyzed the case under the controlling
`standard of Akamai V and found no “direction or control” or “joint enterprise.” Id. at 680.
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`Similarly, in Ortiz & Assocs. Consulting LLC v. Microsoft Corp., the plaintiff alleged that
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`Microsoft’s use of the software infringed its patent. No. 19-CV-8262, 2021 WL 3033533, at *2
`(N.D. 1II. July 19, 2021). But “nothing in the complaint suggests that Defendant uses the software.
`Instead, the complaint alleges that Defendant licenses the software to end users and that the end
`users implement the software.” Id. The plaintiff attempted to get around this by arguing SiRF. Id.
`at *3. The court rejected this argument: “Here, in contrast, according to Plaintiff's own allegations
`[25, at 9 9b—9d], it is the end user who controls the devices. And the Federal Circuit has declined
`to expand SiRF in the manner Plaintiff's argument requires.” /d. (citations omitted). Thus, the court
`concluded that “Plaintiff’s SiRF argument fails” and granted defendant’s motion to dismiss. /d.
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`Similarly, in Wi-LAN Inc. v. Sharp Elecs. Corp., 362 F. Supp. 3d 226, 230 (D. Del. 2019),
`the plaintiff argued direct infringement under SiRF based on defendants selling televisions that
`performed the claimed methods. The court rejected Plaintiff’s argument, explaining that: “unlike
`in SiRF, where the defendant physically possessed and controlled the servers at the time of
`performance of the method, Defendants here have no control over performance of the method after
`they sell their televisions to end users. As ‘there are no steps automatically performed by
`equipment controlled by [Defendants],” SiRF does not apply.” Id. at 235.
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`IBM, Ortiz, and Wi-LAN all undercut Plaintiff’s argument for a broad reading of SiRF. As
`in those cases, Cogmedia’s case here “is distinguishable from SiRF because some third party (at
`least a party that is not [Defendant]) is involved in the performance of a method step.” IBM, 775
`F. App’x at 678 (emphasis original). See also Koninklijke Philips N.V. v. Zoll Med. Corp., 656 F.
`App’x 504, 521 (Fed. Cir. 2016) (declining to extend SiRF' to situations where self-test steps were
`performed by defendant’s customers); Adaptix, Inc. v. Apple, Inc., 78 F. Supp. 3d 952, 957 (N.D.
`Cal. 2015) (“in light of Ericsson, [plaintiff’s] SiRF-based theory of direct infringement does not
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`hold water.”); Sapphire Crossing LLC v. Abbyy USA Software House, Inc., 497 F. Supp. 3d 762,
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`766 (N.D. Cal. 2020) (“SiRF is not applicable and plaintiff fails to state a claim for direct
`infringement.”); GoTV Streaming, LLC v. Netflix, Inc., No. 2:22-cv-07556 RGK-SHK, 2023 WL
`6192744, at *25 (C.D. Cal. Sept. 11, 2023) (“Because the steps must be performed on the device,
`the steps are performed by whoever controls the device. And here, when a customer uses the
`Accused Products using her own wireless device, Defendant does not perform the steps.”).
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`Even Plaintiff’s own cases undercut its argument. Plaintiff cites Sentius Int’l, LLC v. Apple
`Inc., No. 4:20-cv-00477-YGR, 2020 U.S. Dist. LEXIS 97576, at *13 (N.D. Cal. June 2, 2020), but
`glosses over an important fact—the court rejected plaintiff’s arguments, and granted defendant’s
`motion to dismiss. /d. at *11, *13. Whether there exists a theory of liability under SiRF is not the
`right question. The right question is whether Plaintiff here has adequately pled the facts to support
`such a theory. Just as the plaintiff in Sentius failed to plead such facts, so too the Plaintiff here has
`failed to plead such facts. Meta’s motion to dismiss should be granted.
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`Because SiRF is inapplicable, the governing legal standard is the single-entity rule for
`divided infringement from the en banc Federal Circuit in Akamai V. Because Plaintiff has pleaded
`no facts for “direction or control” or “joint enterprise,” Meta’s motion to dismiss should be granted.
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`C. Cogmedia’s conclusory allegations of “in-house testing” are insufficient to
`survive dismissal.
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`In a last-ditch effort to save its pleading, Cogmedia pivots to a single, underdeveloped
`sentence in its Complaint regarding “in-house testing.” Opp. at 14 (citing Dkt. 1 4 17). But this is
`precisely the type of “[t]hreadbare recital[] of the elements of a cause of action, supported by mere
`conclusory statements . . . .” that have been rejected by the Supreme Court and Federal Circuit.
`Bot M8 LLC v. Sony Corp. of Am., 4 F.4th 1342, 1352 (Fed. Cir. 2021) (quoting Ashcroft v. Igbal,
`556 U.S. 662, 678 (2009)). The Federal Circuit has affirmed dismissal on far more detailed, yet
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`still insufficient, testing allegations in Lyda v. CBS Corp., 838 F. 3d 1331, 1337 (Fed. Cir. 2016).
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`Plaintiff’s reliance on GoTV is misplaced. Opp. at 14. In that case, the plaintiff pointed to specific
`evidence that the defendant performed infringing daily tests of the accused products. GoTV
`Streaming, LLC v. Netflix, Inc., No. 2:22-cv-07556-RGK-SHK, 2023 U.S. Dist. LEXIS 161783,
`at *24 (C.D. Cal. Sep. 11, 2023). In contrast, Cogmedia’s single, vague sentence about in-house
`testing falls far short of the standard established in Lyda and other cases dismissing unsubstantiated
`testing allegations. Rampage LLC v. Glob. Graphics SE, No. 16-CV-10691-ADB, 2017 WL
`239328, at *4 (D. Mass. Jan. 19, 2017) (testing allegation insufficient to plead divided
`infringement); Crandall Techs. LLC v. Vudu, Inc., No. 20-cv-04849-VC, 2020 U.S. Dist. LEXIS
`204571, at *2 (N.D. Cal. Nov. 2, 2020) (“the allegations about testing do not include sufficient
`detail to assess whether such testing activity likely or necessarily constituted infringement”).
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`D. Dismissal with prejudice is the appropriate remedy.
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`The court in De La Vega correctly identified the danger of allowing a plaintiff to radically
`pivot its infringement theory in response to a dispositive motion. The court recognized that
`changing from a multi-actor to single-actor infringement theory was “a very substantive change”
`that undermines the integrity of Rule 11. De La Vega v. Microsoft Corp., No. W-19-CV-00612-
`ADA, 2020 WL 3528411, at *4 (W.D. Tex. Feb. 11, 2020). The De La Vega court further
`recognized that amendment would still be futile even to supplement a speculative testing scenario.
`Id. at *4 n.7. Cogmedia finds itself in precisely the same position as in De La Vega. Cogmedia
`pleaded a multi-actor case because that is what the technology and the patent claims describe. It
`cannot now amend to pretend that it had a viable single-actor case all along. Because Cogmedia’s
`“factual allegations are actually incomsistent with and contradict infringement,” Cogmedia has
`“pleaded itself out of court.” Bot M8, 4 F.4th at 1354 (emphasis original).
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`I1. CONCLUSION
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`For the foregoing reasons, Meta’s motion to dismiss should be granted with prejudice.
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`Dated: October 30, 2025 Respectfully submitted,
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`By:
`/s/ Matthias A. Kamber
`PAUL HASTINGS LLP
`200 Clarendon Street, 49th Floor
`Boston, MA 02116
`Tel: (415) 856-7050
`Fax: (415) 856-7150
`
`Matthias A. Kamber (Mass BBO #654217)
`PAUL HASTINGS LLP
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`101 California St., 48th Floor
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`San Francisco, CA 94111
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`Tel: (415) 856-7050
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`Fax: (415) 856-7150
`matthiaskamber@paulhastings.com
`
`Lisa Nguyen (pro hac vice)
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`Eric Lancaster (pro hac vice)
`Joshua Yin (pro hac vice)
`Michelle Zhang (pro hac vice)
`PAUL HASTINGS LLP
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`1117 S. California Ave.
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`Palo Alto, CA 94304
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`Tel: (650) 320-1800
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`Fax: (650) 320-1990
`lisanguyen(@paulhastings.com
`ericlancaster@paulhastings.com
`joshuayin@paulhastings.com
`michellezhang@paulhastings.com
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`Attorneys for Defendant Meta Platforms, Inc.
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