Snap Inc. v. You Map, Inc.

NOTE: This disposition is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
SNAP INC.,
Appellant
v.
YOU MAP, INC.,
Appellee
______________________
2024-1120
______________________
Appeal from the United States Patent and Trademark
Office, Patent Trial and Appeal Board in No. IPR2022-
00568.
______________________
Decided: October 1, 2025
______________________
NATHAN R. SPEED, Wolf, Greenfield & Sacks, P.C., Bos-
ton, MA, argued for appellant. Also represented by
ELISABETH H. HUNT, STUART DUNCAN SMITH.
RICHARD A. CATALINA, JR., Jardim, Meisner, Salmon,
Sprague & Susser, PC, Florham Park, NJ, argued for ap-
pellee. Also represented by RYAN NORTH MILLER, Fox
Rothschild LLP, Philadelphia, PA.
______________________
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SNAP INC. v. YOU MAP, INC. 2
Before DYK, HUGHES, and STARK, Circuit Judges.
DYK, Circuit Judge.
Snap Inc. (“Snap”) appeals from a Patent Trial and Ap-
peal Board (“Board”) final written decision allowing substi-
tute claims for U.S. Patent No. 10,616,727 (the
“’727 patent”), which is owned by Appellee You Map, Inc.
(“You Map”). We affirm the Board’s decision that the sub-
stitute claims satisfy the written description requirement
of 35 U.S.C. § 112. However, we conclude that the Board
erred in its determination that Snap failed to show that the
substitute claims were not obvious over prior art reference
Feldman.1 Whether the substitute claims are obvious
turns on the substitute claims’ requirement that the
claimed request for social media posts include a “current
zoom level.” We see no error in the Board’s determination
that Feldman does not disclose a request that includes a
“current zoom level.” However, the Board’s determination
that it would not have been obvious to modify Feldman to
include a “current zoom level” in the request is inconsistent
with KSR International Co. v. Teleflex, Inc., 550 U.S. 398,
401 (2007). We affirm in part, vacate in part, and remand
for further proceedings.
BACKGROUND
Social media platforms that allow users to share
posts—including text posts, photos, and videos—with other
users on the internet were widespread and well known be-
fore the priority date of the ’727 patent. Users often want
to know the location associated with an individual post on
social media or the location of a venue referenced in a social
media post.
1 U.S. Patent Application Publication
No. 2015/0334077 (“Feldman”) (filed May 18, 2015; pub-
lished Nov. 19, 2015).
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SNAP INC. v. YOU MAP, INC. 3
If every post ever made on a social media application
were to be displayed simultaneously on a map, however,
“hundreds or thousands of posts would overcrowd [the] dis-
play making the map, and therefore the posts, virtually
useless.” ’727 patent, col. 3 ll. 47–51. You Map’s ’727 pa-
tent describes a system directed toward solving this prob-
lem by “provid[ing] an overview of the most important
human activity in a country, region, city, or other level” on
a digital map display. Id. col. 10 ll. 65–67. The original
claims of the ’727 patent claimed a system that “re-
ceive[s] . . . a request . . . includ[ing] screen attribute infor-
mation about a display of a client device” and “identify[s] a
set of temporally recent social media posts based on the
screen attribute information . . . .” ’727 patent, claim 1; ac-
cord id. claims 11, 20. The ’727 patent describes various
embodiments to filter the selection of social media posts
shown to the user (or “client”). See id. col. 3 l. 52–col. 4 l. 3.
In one embodiment, the client sends a request to the sys-
tem to display social media posts, and that request includes
a “current zoom level” of the client device. Id. col. 1 l. 65–
col. 2 l. 2; id. col. 7 ll. 3–20. “[W]hen a user has zoomed out,
they may see posts that have a high importance level (also
referred to herein interchangeably with a value or a score),
and when they zoom in on an area, a system may show a
user posts with lower importance values.” Id. col. 3 ll. 58–
63. The “current zoom level” may be used to display a lim-
ited amount of map on the client’s device. Id. col. 7 ll. 8–
20.
The claims of the ’727 patent include a “combined rank-
ing” step that is used to determine what group of posts are
provided for display on the client’s device. E.g., ’727 pa-
tent, claim 1. The combined ranking of the social media
posts is created through a “first customized score . . . based
on a first set of preference factors” and “a second custom-
ized score . . . based on a second set of preference factors.”
Id.
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SNAP INC. v. YOU MAP, INC. 4
Snap petitioned for inter partes review (“IPR”) of all
claims of the ’727 patent, arguing that the claims were ob-
vious. The Board instituted IPR and determined that
claims 1–20 of the ’727 patent were unpatentable as obvi-
ous. This determination is not challenged on appeal.
However, during the IPR proceedings, You Map filed a
contingent motion to amend the ’727 patent to include sub-
stitute claims 21–40 should claims 1–20 be determined to
be unpatentable, and requested preliminary guidance on
its substitute claims. You Map’s substitute claims replaced
“screen attribute information” with “current zoom level.”
The following portion of substitute claim 21 is representa-
tive of the “current zoom level” amendments:
A system for providing location information on a
social network, comprising:
[21.1] a computer processor; and
[21.2] a social mapping module executing on the
computer processor and configured to enable the
computer processor to:
[21.3] receive, from a client device, a re-
quest for one or more social media posts,
wherein the request includes [screen at-
tribution information about] a current
zoom level of a display of the client device,
geographic location information, and an
identification of a requesting account of the
social network;
[21.4] identify a set of temporally recent so-
cial media posts based on the [screen at-
tribute information] current zoom level of
the display of the client device and the geo-
graphic location information; . . . .
J.A. 1693 (alterations in original).
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SNAP INC. v. YOU MAP, INC. 5
In its final written decision, the Board determined sub-
stitute claims 21–23, 25, 27–33, 35, and 37–40 were not ob-
vious because of You Map’s added “current zoom level”
limitation.2 In reaching this conclusion, the Board rejected
Snap’s argument that the “current zoom level” limitation
would have been obvious. First, the Board found that Feld-
man disclosed sending a request that contained a “radius,”
but did not disclose sending a request containing a “current
zoom level,” and that “radius” and the zoom level described
in Feldman were two different concepts. J.A. 51–53. Sec-
ond, the Board found an ordinarily skilled artisan would
not have been motivated to combine Feldman’s request
with the inclusion of a “current zoom level” parameter, and
thus that Snap had not shown that the substitute claims
would have been obvious. In addition, the Board deter-
mined the ’727 patent provided adequate written descrip-
tion support for the “combined ranking” step, which was
present in both the original and substitute claims.
Snap timely appeals. We have jurisdiction under
28 U.S.C. § 1295(a)(4)(A).
DISCUSSION
I
A
We first consider the Board’s obviousness determina-
tion. Because obviousness is a mixed question of law and
fact, the Board’s legal conclusion of obviousness is reviewed
de novo and its factual findings related to obviousness are
reviewed for substantial evidence. Apple Inc. v. Gesture
Tech. Partners, LLC, 127 F.4th 364, 368 (Fed. Cir. 2025).
Snap argues that the Board erred in finding that Feldman
2 You Map voluntarily withdrew substitute
claims 24, 26, 34, and 36 before the Board issued its final
written decision.
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SNAP INC. v. YOU MAP, INC. 6
does not disclose a “request includ[ing] a current zoom
level” as required by the substitute claims. Although the
Board found that Feldman discloses a zoom level, the
Board found that Feldman’s request for social media posts
contained only “the radius . . . , not the current zoom
level[.]” J.A. 53. This finding is supported by substantial
evidence. While Feldman refers to adjusting the zoom level
of the client device, it says nothing about including a zoom
level in the request.
Snap appears to contend, however, that the “current
zoom level” and the “radius” are the same thing. Appel-
lant’s Br. 31.3 As discussed below, the record establishes
that the two can achieve the same result—defining the
search perimeter—but they achieve this result in different
ways. Feldman’s “radius” is a definition of the “perimeter,”
which may be used to “designate geosearch location” in a
search request for social media posts,” J.A. 902 ¶¶ 68, 71.
Feldman’s zoom level can be used to set a perimeter.
J.A. 52–53. While the zoom level and “radius” can achieve
the same result—establishing a perimeter—they achieve
this result through two different mechanisms. The Board’s
conclusion that Feldman does not disclose sending a “cur-
rent zoom level” in a request for social media posts to a sys-
tem is thus supported by substantial evidence.
3 Snap also argues the Board erred in implicitly con-
struing the term “current zoom level” by requiring the
“‘current zoom level’ be included in a request using a par-
ticular explicit data format.” Appellant’s Br. 24, 31–36.
This is incorrect. The Board required Snap to show the
“current zoom level” was included in a search request, and
determined this parameter simply was not in Feldman’s
request.
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SNAP INC. v. YOU MAP, INC. 7
B
The Board next determined that adding the “current
zoom level” to Feldman’s request would not have been ob-
vious. Snap argued throughout its motion to amend brief-
ing that “[i]ncluding the zoom level would have been an
obvious, predictable design choice to implement Feldman’s
goal of ‘modify[ing] what is searched at the same time the
area the user desires to view is selected dynamically,’”
J.A. 2054 (citing J.A. 903) (alterations in original), and
that “it would have been obvious to modify Feldman to tie
the search area to the zoom level,” J.A. 2628 (emphasis in
original). Snap’s expert also explained that “the modifica-
tion requires only simple, well-understood programming to
include [the ‘current zoom level’] in the request,” how an
ordinarily skilled artisan had “strong incentive to include
‘current zoom level’ in [Feldman’s] request,” and why an
ordinarily skilled artisan “would have expected success”
with this inclusion. J.A. 2373 ¶ 88. The Board agreed with
Snap that prior art references “explain that it was known
to specify the zoom level” in a search request. J.A. 58; see
also J.A. 55–56 (explaining that Snap “provide[d] seven ad-
ditional references with teachings related to zoom level”).
Although You Map was entitled to submit a reply to
Snap’s opposition to the motion to amend under the Board’s
motion to amend pilot program procedures,4 You Map did
not do so. Thus, You Map did not offer evidence to rebut
Snap’s expert’s testimony explaining why adapting Feld-
man’s request to include the “current zoom level” “would
4 Notice Regarding a New Pilot Program Concerning
Motion to Amend Practice and Procedures in Trial Proceed-
ings Under the America Invents Act Before the Patent
Trial and Appeal Board, 84 Fed. Reg. 9497, 9500–01
(Mar. 15, 2019) (stating that a patent owner may file a re-
ply to petitioner’s opposition to motion to amend and “may
file new evidence, including declarations, with its reply”).
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SNAP INC. v. YOU MAP, INC. 8
have been an obvious and predictable design choice.”
J.A. 2373 ¶ 88.
Both You Map and the Board read Snap’s opposition to
You Map’s motion to amend as arguing both that it was
obvious either to add the “current zoom level” to Feldman’s
request or to replace the “radius” in the request with the
“current zoom level.” You Map argues that “Snap was ob-
ligated to explain why one of ordinary skill in the art would
replace the perimeter 303 in Feldman’s request with a ‘cur-
rent zoom level’ or add a ‘current zoom level’ to Feldman’s
request that already includes perimeter 303.” Appellee’s
Br. 3. Likewise, the Board noted that Snap’s failure was in
“not explaining how adding information to [Feldman’s] re-
quest or possibly replacing the perimeter 303 . . . would
further [the] goal” of “modify[ing] what is what is searched
at the same time the area the user desires to view is se-
lected.” J.A. 57; see also J.A. 54.
The Board rejected the first theory (adding the “current
zoom level”) on the ground that “Feldman’s goal of ‘mod-
ify[ing] what is searched at the same time the area the user
desires to view is selected dynamically,’” J.A. 57 (quoting
J.A. 2054), is “already achieve[d]” by sending Feldman’s
perimeter 303 (i.e., how to define the search perimeter) in
the request, id. As to the second theory (replacing the “ra-
dius”), the Board inconsistently concluded that the theory
failed because Snap did not “explain how Feldman would
obtain the search radius if only the zoom level were sent in
the request,” i.e., Snap did not explain how the search pe-
rimeter would be achieved in Feldman using only the zoom
level. J.A. 57.
The Board’s rejection of the second theory is not sup-
ported by substantial evidence. The Board elsewhere
found based on undisputed evidence that search requests
including a zoom level or a radius can accomplish the same
result. The Board determined that “Feldman does not need
to send the zoom level in the request because the search
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SNAP INC. v. YOU MAP, INC. 9
request already contains search perimeter” and that “zoom
level, in some cases, is already accounted for in the radius
specified by search perimeter.” J.A. 55. You Map likewise
conceded that Feldman disclosed using the zoom level as “a
means of setting a radius.” J.A. 2649 (emphasis in origi-
nal). On appeal, You Map contended that the Board, citing
Snap’s petition, “noted that both parties’ experts agree that
adjusting a ‘zoom perspective’ in Feldman’s system was one
such way of establishing the search perimeter.” Appellee’s
Br. 33 (citing J.A. 52–53, then citing J.A. 2624).
In other words, the ’727 patent’s use of a “current zoom
level” and Feldman’s use of a “radius” are merely different
approaches used to achieve the same result—designating a
search perimeter to select a portion of a map for display,
search, or posting. They also address the same problem of
“overcrowd[ing]” on social media maps which, absent these
solutions, would render the maps “virtually useless.” ’727
patent, col. 3 ll. 47–51.
Snap relied on the prior art and expert testimony to ex-
plain how “[i]ncluding the zoom level would have been an
obvious, predictable design choice to implement Feldman’s
goal of ‘modify[ing] what is searched at the same time the
area the user desires to view is selected dynamically.’”
J.A. 2054 (quoting J.A. 903 ¶ 88) (citing J.A. 2373 ¶ 88
(declaration of Snap’s expert), then citing KSR, 550 U.S.
at 417).
In this respect, Snap in its opposition to You Map’s mo-
tion to amend relied on KSR to explain how predictable de-
sign choices were obvious. KSR held that a “simple
substitution of one known element for another or the mere
application of a known technique to a piece of prior art
ready for the improvement” almost certainly renders a pa-
tent obvious. KSR, 550 U.S. at 417. “If a person of ordi-
nary skill can implement a predictable variation, § 103
likely bars its patentability.” Id. “This is the so-called
‘known-technique’ rationale. . . . [I]f there’s a known
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SNAP INC. v. YOU MAP, INC. 10
technique to address a known problem using ‘prior art ele-
ments according to their established functions,” then there
is motivation to combine.” Intel Corp. v. PACT XPP
Schweiz AG, 61 F.4th 1373, 1380 (Fed. Cir. 2023). Such is
the case here.
This is therefore not a situation in which there was a
lack of evidence of motivation to combine teachings known
in the art. Cf. Virtek Vision Int’l, ULC v. Assembly Guid-
ance Sys., Inc., 97 F.4th 882, 886–88 (Fed. Cir. 2024) (re-
versing Board’s obviousness determination when no
evidence gave a “reason for combining” two teachings
known in the prior art, as “[i]t does not suffice to simply be
known”). Under KSR and our cases, a challenger need not
show that the substitution would be an improvement over
the original invention. Instead, the challenger need only
show that one element was a known substitute for the
other. See Intel Corp., 61 F.4th at 1380 (“That [two teach-
ings in the prior art] address the same problem and that
[each of them] was a known way to address that problem is
precisely the reason that there’s a motivation to combine
under KSR and our precedent.”); PAR Pharm., Inc. v. TWI
Pharms., Inc., 773 F.3d 1186, 1197–98 (Fed. Cir. 2014)
(“Our precedent . . . does not require that the motivation be
the best option, only that it be a suitable option from which
the prior art did not teach away.”); Intel Corp. v. Qualcomm
Inc., 21 F.4th 784, 799–801 (Fed. Cir. 2021) (similar).
As its analysis rested on a flawed understanding of
KSR, we vacate the Board’s finding that there is no moti-
vation to modify Feldman’s request to include a “current
zoom level” based on any of Snap’s seven prior art refer-
ences teaching requests relating to zoom levels. Under the
correct legal standard, the undisputed evidence estab-
lished a motivation to modify the radius in Feldman’s
search request to instead be based on the zoom level pa-
rameter disclosed in the prior art. On remand, the Board’s
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SNAP INC. v. YOU MAP, INC. 11
consideration of obviousness must be consistent with this
conclusion.
II
Finally, we conclude that substantial evidence sup-
ports the Board’s finding that the written description re-
quirement of 35 U.S.C. § 112 was satisfied for the claimed
“combined ranking” step. Snap argues You Map did not
provide the Board with adequate evidence to determine
whether the ’727 patent’s specification discloses the “com-
bined ranking” step. In its motion to amend, You Map
demonstrated that the ’727 patent provided an adequate
written description of the “combined ranking” step by cit-
ing portions of the specification. Snap argues these cita-
tions failed to satisfy the requirements of
37 CFR § 42.22(a)(2), which requires motions before the
Board to include “a detailed explanation of the significance
of the evidence including material facts . . . .”
“Decisions related to compliance with the Board’s pro-
cedures are reviewed for an abuse of discretion.” Ericsson
Inc. v. Intell. Ventures I LLC, 901 F.3d 1374, 1379
(Fed. Cir. 2018). Here, the Board considered You Map’s ci-
tations to the ’727 patent specification, found the meaning
of these citations “apparent,” and determined that the cita-
tions were “sufficient to understand how the original claim
limitations are supported.” J.A. 48–50.
Snap cites to Parus Holdings, Inc. v. Google LLC,
70 F.4th 1365 (Fed. Cir. 2023), for the principle that a
party bearing the burden of production must provide some
combination of relevant record evidence and explain the
significance. Parus, however, arose in the context of a
party asserting an earlier priority date for its claims and
then incorporating by reference 1,300 pages of exhibits and
forty claim charts—without a brief—to support the claimed
priority date. Id. at 1369. The concerns in Parus are not
present here. To demonstrate the disputed “combined
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SNAP INC. v. YOU MAP, INC. 12
ranking step” had written description support, You Map
provided string citations to the specification of the ’727 pa-
tent, which is the “single best guide to the meaning of a
disputed term.” Philips v. AWH Corp., 415 F.3d 1303, 1315
(Fed. Cir. 2005) (quoting Vitronics Corp. v. Conceptronic,
Inc., 90 F.3d 1576, 1582 (Fed. Cir. 1996)). The Board found
the meaning of the specification “apparent,” and thus the
Board’s conclusion that the citations were clear was within
its discretion. J.A. 49–50.
Snap also contends, however, that the passages in-
cluded in the citations did not support the Board’s conclu-
sion. The Board found that the patent disclosed “examples
where the user creates multiple maps that each have their
own ranking of post by relevancy,” J.A. 49, and “that the
system creates more than one customized score when the
posts are ranked for different maps,” J.A. 50. In a specific
example from the cited passages, the Board recognized that
“the system weighs the impact of each social-emotive data
score, incorporating a person’s emotional state and geo-
graphic location, and combines them together to get an
overall score for a map.” J.A. 50 (citing J.A. 1673). These
evidentiary findings, which support the conclusion that the
“combined ranking” step is disclosed in the ’727 patent, are
supported by substantial evidence.
CONCLUSION
We determine that the Board properly rejected Snap’s
written description and single-reference obviousness chal-
lenges but that the Board erred in its analysis of the moti-
vation to modify Feldman’s request to include a “current
zoom level.” Therefore, we affirm in part, vacate in part,
and remand to the Board for further proceedings consistent
with this opinion.
AFFIRMED-IN-PART, VACATED-IN-PART, AND
REMANDED
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SNAP INC. v. YOU MAP, INC. 13
COSTS
Costs to Snap.
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