Litigation

VL Collective IP, LLC v. Meta Platforms, Inc.

dismissed

25-1414

Filed
2025-02-03
Terminated
2025-08-07

Patents at issue (1)

7266682

Summary

Appeal from IPR2023-00923 concerning U.S. Patent No. 7,266,682. The Federal Circuit dismissed the appeal by order dated August 7, 2025.

Case overview & background

Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.

I'll research this case across the docket, PTAB records, and legal press.

Good start. Now let me dig into the IPR outcomes, the district court docket, and the VideoLabs campaign context.

Now let me pin down the IPR2023-00924 outcome, the district court's §101 ruling specifics, and whether the Delaware case settled.

Case Overview — VL Collective IP, LLC v. Meta Platforms, Inc., Nos. 25-1414 / 25-1415 / 25-1454 (Fed. Cir.)

Parties. The appellant here, VL Collective IP, LLC (founded 2019), is the patent-holding and enforcement arm of VideoLabs, Inc. (Palo Alto, CA), an entity the Delaware court described as seeking to "reduce the cost and risk of technological gridlock associated with diverse patent ownership" by assembling a video-technology portfolio acquired from operating companies — Hewlett Packard Enterprise, Siemens AG, and Panasonic among them — and licensing it through a membership platform; VL IP Holdings LLC sits between VideoLabs and VL Collective (D. Del. C.A. No. 22-680-JHS, Doc. 35 at 3, https://storage.courtlistener.com/recap/gov.uscourts.ded.79020/gov.uscourts.ded.79020.35.0.pdf; IPR2023-00923 FWD at 4). VideoLabs markets itself as a "professional intellectual property services company and licensing platform" rather than a classic PAE, but outside observers (e.g., Taiwan's IPO) characterize it within the broad NPE category, and it holds no practicing product business — its revenue model is licensing non-members of its platform, which is precisely the squeeze alleged against Meta Platforms, Inc. and its subsidiaries Instagram, Inc., WhatsApp LLC, Facebook Technologies LLC / Meta Platforms Technologies, LLC, and Giphy, Inc. (acquired by Meta in 2020), all of whom the complaint says are not VideoLabs members (Doc. 35 at 3).

Accused technology and patents. VideoLabs accused Meta's social platforms of infringing five patents through their video functionality — video coding/decoding, real-time transmission, and image/object processing across Facebook, Instagram, WhatsApp, and Giphy (Doc. 35 at 1–3). The five asserted patents are: (1) U.S. 8,139,878 and (2) **

Key legal developments & outcome

Major rulings, motions, claim construction, settlements, and the present posture or final disposition.

I'll research this case thoroughly. Let me start with several parallel searches.

Let me dig deeper into the district court docket, PTAB outcomes, and parallel proceedings.

VL Collective IP, LLC v. Meta Platforms, Inc. — Key Legal Developments & Outcome

Important framing note. The case metadata you supplied (Fed. Cir. No. 25-1414) is not the infringement suit — it is the appellate sequel to it. No. 25-1414 is VL Collective's appeal from the PTAB's Final Written Decision in IPR2023-00923 on U.S. Patent No. 7,266,682 ("the '682 patent"). The infringement action itself was VideoLabs, Inc. and VL Collective IP LLC v. Meta Platforms, Inc., Instagram, Inc., WhatsApp LLC, Facebook Technologies LLC, and GIPHY, Inc., C.A. No. 1:22-cv-00680-JHS (D. Del.). I cover both tracks below, since the litigation milestones you asked about (pleadings, MTD, claim construction, trial) all occurred in the district court case, and the appeal/outcome ran through the PTAB.

I. The District Court Infringement Action (D. Del. 22-680)

2022-05-24 — Complaint filed. VideoLabs, Inc. and VL Collective IP LLC (VL Collective is a 2019-formed VideoLabs subsidiary) sued Meta and four subsidiaries — Instagram, WhatsApp, Facebook Technologies (Oculus), and GIPHY — alleging § 271(a) infringement of five patents:

  • Count I: U.S. 8,139,878 ('878)
  • Count II: U.S. 7,769,238 ('238)
  • Count III: U.S. 7,970,059 ('059)
  • Count IV: U.S. 7,266,682 ('682) — the patent at issue on appeal here
  • Count V: U.S. 7,436,980 ('980)

The '682 patent (granted 2007-09-04; originally assigned to Siemens Corporate Research, Inc.; earliest priority 2000-01-18) claims application-layer authentication of RTP packets. VideoLabs asserted at least claim 1 against Meta's WebRTC/SRTP-implementing products. The complaint pleaded pre-suit notice via licensing outreach beginning 2019-10-02, an in-person meeting on 2020-01-30, and a June 2020 email. (Complaint, ECF 1; D. Del. Op., ECF 35)

2022-08-01 — Partial motion to dismiss (ECF 8, 9). Meta moved on two grounds: (1) § 101 ineligibility of the '682

In the news

What the press has reported about this case, summarized with links to the source articles.

I'll search across multiple angles for press coverage of this case.

Let me dig deeper into specific coverage angles.

News & Analysis Coverage

Coverage of this dispute is thin and docket-driven. I searched the caption, both party names, the '682 patent number, the IPR number, and the settlement/verdict angles, and found no Reuters, Bloomberg Law, Ars Technica, The Verge, IPWatchdog, JD Supra, or EFF coverage of either the Delaware case or the Federal Circuit appeal. No outlet reported on the Federal Circuit's dismissal of No. 25-1414 itself. The two substantive press items I located are a practitioner trade report on the April 2024 §101 ruling and a Law360 settlement blurb — and neither discusses the '682 IPR appeal that is the subject of this docket.

The § 101 ruling drew the most substantive coverage. Thomson Reuters' VitalLaw / IP Law Daily reported on 2024-04-23 (by Saurabh Kashyap, B.A., LL.B., LL.M.) under the headline "PATENT—D. Del.: Mixed results for Meta in VideoLabs' ongoing patent infringement lawsuit," describing Judge Slomsky's April 22, 2024 split decision on Meta's partial motion to dismiss: the '682 patent was held directed to an abstract idea with no inventive concept (claims "essentially applications of generic computer functions and established network protocols"), while the '980 patent survived because the court credited its spatio-temporal object-detection model as a specific technical improvement. The piece is notably the only reporting I found that frames the case as significant in § 101 terms — i.e., that a Siemens-origin 2000-priority application-layer authentication claim could not clear Alice step two. It also supplies a counsel data point that supplements the earlier sections here: Brian E. Farnan (Farnan LLP) for VideoLabs and Karen Jacobs (Morris, Nichols, Arsht & Tunnell LLP) for Meta — the latter being Meta's Delaware counsel, which my earlier defendant-representatives section flagged as unconfirmed. VitalLaw's characterization of VideoLabs (patents acquired from HPE, Siemens, and Panasonic, licensed through membership fees) tracks the district court's own description rather than adding independent reporting.

On the endgame, Law360 has the only item, and it is a one-line dek. Law360 reported (headline "Meta, VideoLabs Resolve Video Tech Patent Dispute," dated 2025-10-01 on its index pages) that "Patent licensing business VideoLabs has agreed to end its case in Delaware federal court accusing Meta Platforms of infringing various patents related to video technology." That is the entire publicly visible substance — the article body is paywalled and I could not read it. Critically, no outlet has reported any settlement figure, license terms, or damages number, and nothing in the court record supplies one: the actual dismissal order (D. Del. Doc. 106, entered 2025-10-03) dismisses VideoLabs's claims with prejudice, Meta's counterclaims without prejudice, with each side bearing its own fees and costs. Reporting has not gone beyond that — there are no analyst notes, no Meta or VideoLabs executive statements, and no market-impact commentary on this case in any outlet I found.

Industry-adjacent and machine-generated sources require care. The most substantive non-press commentary came from Unified Patents, which on 2023-02-28 posted a $2,000 PATROLL prior-art bounty on claim 1 of the '682 patent, describing it as asserted against Amazon, Facebook, and Instagram — a defensive-aggregator reaction that predates and likely motivated the Meta IPR, and the clearest example of industry reaction to the '682 patent specifically. Beyond that, what exists is largely automated: Legal News Feed carries aggregator posts ("Meta Platforms Settles Patent Dispute with VideoLabs, Resolving Delaware Case"; "Meta Secures Partial Dismissal in Video Technology Patent Dispute") that restate the Law360/Bloomberg Law items without original reporting, and Patsnap's litigation blog posts AI-generated case summaries whose details I could not fully reconcile with the record — one Patsnap page describes the parallel Giphy appeal (No. 25-1454) as "voluntarily dismissed on October 14, 2025" and discusses only the '980 patent, whereas the Federal Circuit's own August 11, 2025 order deconsolidated 25-1415 and 25-1454 and set a 60-day briefing schedule for Giphy. Treat those summaries as unreliable. Finally, a caveat on a near-miss: the IPR2023-00923 final written decision is hosted on Patently-O's CDN (cdn.patentlyo.com/media/2025/04/IPR2023-00923-FWD.pdf), which suggests Patently-O posted or wrote about the December 2024 Board decision, but I could not locate an actual Patently-O article and will not assert one exists.

Sources

Plaintiff representatives

Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

I'll research the counsel of record for this Federal Circuit appeal, starting with the docket and related PTAB proceeding.

Let me dig into the Federal Circuit docket for 25-1414 specifically and related appeals to confirm appellate counsel.

Let me pull the actual Federal Circuit docket for 25-1414 via CourtListener/RECAP.

Important framing note

Case No. 2025‑1414 is not a district‑court infringement suit — it is VL Collective IP, LLC's appeal to the Federal Circuit from the PTAB's final written decision in IPR2023‑00923 (Meta Platforms, Inc., et al. v. VL Collective IP LLC, U.S. Patent No. 7,266,682). In the Federal Circuit caption, VL Collective IP is styled as the appellant (the "plaintiff" in your metadata). Its trial‑level infringement case against Meta — VideoLabs, Inc. and VL Collective IP LLC v. Meta Platforms, Inc., et al., No. 1:22‑cv‑00680 (D. Del.) — is where most of the counsel of record below first appeared, and that team carried over to the appeal.

A caveat on sourcing: the 25‑1414 Federal Circuit docket itself is not fully visible in the sources I could retrieve (CourtListener/RECAP has the parallel Netflix appeal, 25‑1132, but I could not pull the 25‑1414 docket sheet's individual appearance entries). The names below are drawn from the aggregated litigation record for 25‑1414 (Patsnap Litigation Data, which states names "appear as recorded in the docket"), and they are corroborated by the PTAB power‑of‑attorney/mandatory‑notice filings in IPR2023‑00923 and by the *entry‑of‑appearance entries in the closely related Federal Circuit appeal VL Collective IP, LLC v. Netflix, Inc., No. 25‑1132*. Treat the firm identifications as solid and the specific role labels as best‑evidence rather than verbatim docket text.

Counsel of record for the appellant/plaintiff — VL Collective IP, LLC

All appellate counsel are from Reichman Jorgensen Lehman & Feldberg LLP ("RJLF"). The firm took the lead for VL Collective before the PTAB and on appeal.

Attorney Role Firm / Office Note
Christine E. Lehman Lead counsel (Reg. No. 38,535). Filed the IPR power of attorney as lead counsel and signed the appellant's 25‑1132 entry of appearance. Reichman Jorgensen Lehman & Feldberg LLP — Washington, D.C. (1909 K St., NW) Founding/name partner; registered patent attorney; ran the Patent Owner side of IPR2023‑00923 and is lead appellate counsel across VL Collective/VideoLabs appeals.
Jaime F. Cardenas‑Navia Backup/appellate counsel (appeared pro hac vice before the PTAB; filed the opening brief in the related 25‑1132 appeal). RJLF — New York, NY (400 Madison Ave.) Member of the VideoLabs/VL Collective IPR team; frequent Federal Circuit briefing counsel for the patent owner.
Michael Matulewicz‑Crowley Backup counsel (Reg. No. 72,220). RJLF — New York, NY Registered patent attorney; PTAB and appellate work on the VideoLabs portfolio.
Naveed S. Hasan Backup counsel (Reg. No. 72,688). RJLF — Washington, D.C. Registered patent attorney; listed on the Patent Owner power of attorney in the companion Netflix IPR and on the 25‑1132 appearance.
Brian C. Baran Counsel (corporate/notice counsel on the 25‑1132 docket). RJLF — Washington, D.C. Member of the VideoLabs IPR/appellate team. (Note: do not confuse with Brian E. Farnan, the Delaware local‑counsel attorney — different person, different firm.)
Philip J. Eklem Counsel (correspondence/signatory on the IPR2023‑00923 Director‑Review request "for Christine Lehman"). RJLF — Washington, D.C. Member of the PTAB team; handled Director‑Review filings.
Savannah H. Carnes Counsel (added in the amended entry of appearance in 25‑1132). RJLF — Redwood Shores, CA Member of the appellate team on the VL Collective Federal Circuit matters.

Local counsel (district court, D. Del. — the underlying infringement action)

Attorney Role Firm / Office Note
Brian E. Farnan Local counsel (D. Del.) Farnan LLP — Wilmington, DE Delaware IP‑litigation boutique; served as Delaware local counsel and was served courtesy copies in the related IPR.
Michael J. Farnan Local counsel (D. Del.) Farnan LLP — Wilmington, DE Same firm; co‑local counsel.

In‑house

No in‑house counsel for VL Collective IP is recorded on the appellate docket or in the PTAB filings I reviewed. Nothing indicates an in‑house attorney entered an appearance.

What I could not verify / should be flagged

  1. The literal appearance entries on the 25‑1414 docket. I could not retrieve the 25‑1414 docket sheet's individual "Entry of Appearance" documents (the appeal was voluntarily dismissed under Fed. R. App. P. 42(b) by order dated August 7, 2025, so the docket is short and may not have generated a full briefing-stage appearance). The counsel list above is the aggregated/recorded list and is consistent with the PTAB record and the parallel 25‑1132 docket, but I am not quoting a 25‑1414 appearance entry verbatim.
  2. Role labels. Lead vs. backup/not‑of‑record distinctions are inferred from the IPR power of attorney (Lehman = lead; Cardenas‑Navia, Matulewicz‑Crowley, Hasan = backup) and the 25‑1132 entry of appearance. The Federal Circuit may have designated lead counsel differently.
  3. No sealed‑counsel situation identified. The matter was dismissed before merits briefing, so there is no sealed filing gating an attorney's identity that I found. If you need certainty, the authoritative source is PACER for the Federal Circuit, docket 2025‑1414 (appearance and certificate‑of‑interest entries).

For completeness — opposing counsel (appellee Meta Platforms)

Recorded appellee counsel is Kirkland & Ellis LLP (W. Todd Baker, Ellisen Shelton Turner, Jonathan D. Brit as petitioner's PTAB counsel from IPR2023‑00923). The aggregated 25‑1414 record lists Ellisen Shelton Turner, John C. O'Quinn, Jonathan Drew Brit, and Joshua Popik Glucoft for Meta. This is provided only as context, since your question concerns the plaintiff/appellant side.

Bottom line: The plaintiff/appellant, VL Collective IP, LLC, was represented on appeal by a Reichman Jorgensen Lehman & Feldberg LLP team led by Christine E. Lehman, with Jaime F. Cardenas‑Navia, Michael Matulewicz‑Crowley, Naveed S. Hasan, Brian C. Baran, Philip J. Eklem, and Savannah H. Carnes, and, at the district‑court level, by Delaware local counsel Brian E. Farnan and Michael J. Farnan (Farnan LLP).

Defendant representatives

Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

I'll research the counsel of record for Meta Platforms across the appellate docket, the underlying IPR, and the related district court action.

I have strong IPR-side data. Now let me find the Federal Circuit counsel of record for the appellees, plus the district court defense team.

Now let me pin down the Federal Circuit counsel of record for the appellees and the Delaware district court defense team.

Counsel of Record for the Defendant/Appellee Side — VL Collective IP, LLC v. Meta Platforms, Inc., No. 25-1414 (Fed. Cir.)

Scope note first. This appeal arises from IPR2023-00923, in which Meta was the petitioner and VL Collective the patent owner. VL Collective lost that IPR (the Board held claims 1–28 of the '682 patent unpatentable — see the final written decision) and appealed. So on this docket Meta sits on the defendant/appellee side, and the correct appellee caption is the five-entity Meta group, not just "Meta Platforms, Inc.": Meta Platforms, Inc.; Instagram, Inc.; WhatsApp LLC; Meta Platforms Technologies, LLC; Giphy, Inc. (confirmed in the Aug. 7, 2025 dismissal order).

Important caveat on the appellate docket itself. The appeal was dismissed on the parties' stipulation under Fed. R. App. P. 42(b) on August 7, 2025, and there is no merits opinion. I was not able to retrieve the actual appearances-of-counsel (Fed. Cir. Docket Entries / Form 20) filed in No. 25-1414 itself, and because the case terminated early there is no appellee brief in 25-1414 to mine for a signature block. The entries below are therefore grounded in (a) the counsel-of-record on the underlying IPR2023-00923 — the same dispute now on appeal — and (b) the related Federal Circuit cross-appeal No. 25-1454, where Meta is the appellant and the appearance data is public. I flag each source.

Defendant-side (Meta) counsel of record

Name Role Firm / Office Note
W. Todd Baker (Reg. No. 45,265) Lead counsel Kirkland & Ellis LLP — 1301 Pennsylvania Ave. NW, Washington, D.C. Lead counsel for the Meta petitioners in IPR2023-00923. Registered patent attorney; Kirkland IP-litigation/PTAB practice (email todd.baker@kirkland.com).
Ellisen Shelton Turner (Reg. No. 54,503) Backup counsel Kirkland & Ellis LLP — 2049 Century Park East, Los Angeles, CA Named backup on the Meta petitioners' mandatory notices/Power of Attorney in IPR2023-00923.
Jonathan D. Brit (Reg. No. 75,646) Backup counsel Kirkland & Ellis LLP — 601 Lexington Ave., New York, NY Backup in IPR2023-00923; appeared at the related IPR2023-00924 oral hearing (transcript).
Ethan Perbohner (pro hac vice) Backup counsel Kirkland & Ellis LLP — 333 W. Wolf Point Plaza, Chicago, IL Added by the May 8, 2024 updated mandatory notices / updated POA in IPR2023-00923; also appeared at the IPR2023-00924 hearing.
Yan-Xin Li Counsel (appeared at related hearing) Kirkland & Ellis LLP — 555 California St., San Francisco, CA Appeared for the Meta petitioners at the IPR2023-00924 oral hearing (same patent family/VL Collective dispute). Not confirmed as admitted in 25-1414.
John C. O'Quinn Appellate counsel Kirkland & Ellis LLP, Washington, D.C. Listed as counsel for the Meta appellants on the Federal Circuit docket in related No. 25-1454 (the Meta cross-appeal from IPR2023-00924), per Ex Parte AI Lab docket data. A Kirkland Supreme Court/appellate partner and former Acting U.S. Solicitor General; his presence on the parallel Meta appeal is strong circumstantial evidence of who handled the Federal Circuit side of the VideoLabs/Meta appeals, but I could not independently confirm he entered an appearance in 25-1414 specifically.

Service/central contact used by the Meta team in the IPR: the Kirkland litigation distribution #Meta_VideoLabs@kirkland.com (appears throughout the IPR2023-00923 correspondence and certificates of service).

In-house: No Meta in-house counsel is named on the 25-1414 record I could retrieve. In a different Meta IPR (IPR2023-01023, via a Latham & Watkins Power of Attorney) the signing in-house officer was Katie Brockway, Associate General Counsel, IP Litigation, Meta — but I want to be clear that this is from a separate Meta matter, not from this case, and should not be treated as confirmed in-house counsel for 25-1414.

Observations and gaps

  • Kirkland & Ellis LLP is the Meta-side firm across this dispute. It held the Power of Attorney for the Meta petitioners in IPR2023-00923 (lead/backup counsel designated there) and appears on the parallel Federal Circuit appeal 25-1454. That is the most reliable basis for identifying the defense team here.
  • The 25-1414 docket's own appearance entries are not in the sources I could access. Because the appeal was voluntarily dismissed only ~6 months after filing and before any appellee brief, there may be minimal paper. Treat any specific 25-1414 appearance as unconfirmed until the Federal Circuit docket sheet (PACER) or CourtListener RECAP entry is pulled.
  • District court counsel is unconfirmed. The underlying case is VideoLabs, Inc. et al. v. Meta Platforms, Inc. et al., No. 1:22-cv-00680 (D. Del.) (Judge Joel H. Slomsky; opinion on the defendants' partial motion to dismiss, Apr. 22, 2024). I could not retrieve the Meta defendants' Delaware counsel-of-record (including any local Delaware firm) within the search budget; the Law360 settlement item covering the Delaware case does not name counsel in the excerpt I saw. This should be verified directly on the D. Del. docket.
  • For contrast — opposing (patent-owner) counsel, per the IPR record and the related Federal Circuit dockets: Christine E. Lehman (lead), Jaime F. Cardenas-Navia, Michael Matulewicz-Crowley, Philip J. Eklem, Brian C. Baran, and Naveed S. Hasan of Reichman Jorgensen Lehman & Feldberg LLP (Washington, D.C. / New York), with Brian E. Farnan / Michael J. Farnan (Farnan LLP) as Delaware local counsel. These are plaintiff/appellant-side counsel, included only to avoid confusion, since the earlier "In the news" section notes the Reisman-side names.

Bottom line: The defendant/appellee-side representation in this dispute is Kirkland & Ellis LLP, with W. Todd Baker (Washington, D.C.) as lead, assisted by Ellisen Shelton Turner (L.A.), Jonathan D. Brit (N.Y.), and Ethan Perbohner (Chicago) in the underlying IPR2023-00923, and John C. O'Quinn as apparent appellate counsel on the related Federal Circuit Meta appeal. Confirm the exact 25-1414 appearances and any Delaware local counsel on PACER before relying on them.