IP Law Daily, PATENT—Fed. Cir.: PTAB’s approval of You Map’s substitute claims partly vacated; case remanded on obviousness, (Oct 1, 2025)

By Saurabh Kashyap, B.A., M.A., LL.B., LL.M.

You Map’s substitute claims met the written description requirement, but the PTAB erred in finding no motivation to combine prior art to add a “current zoom level” limitation.

In a non-precedential disposition, the U.S. Court of Appeals for the Federal Circuit issued a mixed ruling in an appeal arising out of the Patent Trial and Appeal Board’s (PTAB) decisions in inter partes reviews (IPRs) filed by Snap Inc. against You Map, Inc.’s location-based social media mapping patent. The appellate court affirmed the Board’s finding that You Map’s substitute claims for the patent at issue satisfied the written description requirement. However, it vacated the Board’s determination that the claims were nonobvious, holding that the Board applied an overly rigid analysis inconsistent with guiding precedent. The case was remanded for further proceedings (Snap Inc. v. You Map, Inc., No. 24-1120 (Fed. Cir. Oct. 1, 2025)).

Background. The appellant, Snap Inc., is a social media company best known for its Snapchat platform. The appellee, You Map, is a smaller technology company that develops platforms that visualize social media activity on interactive maps.

The patent at issue, U.S. Patent No. 10,616,727 (the ’727 patent), is owned by You Map. It discloses methods for filtering social media posts on a digital map by incorporating attributes of a client device’s display. Without such filtering, the specification explains, maps would be overcrowded with “hundreds or thousands” of posts, rendering them “virtually useless.”

Snap petitioned for IPR of all claims of the ’727 patent, contending that they were obvious in view of prior art, particularly U.S. Patent Application Publication No. 2015/0334077 to Feldman. The Board instituted review and ultimately held claims 1–20 unpatentable as obvious, a finding not disputed on appeal.

During the IPR, You Map filed a contingent motion to amend, introducing substitute claims 21–40. These claims replaced the “screen attribute information” language with an explicit requirement that the request include the “current zoom level” of the display. The Board allowed most substitute claims, finding the zoom-level limitation neither disclosed nor suggested by Feldman. It also found the written description requirement satisfied. Snap appealed, arguing error in both findings.

Obviousness and prior art. The central question on appeal concerned whether it would have been obvious to modify Feldman’s request parameter to include a “current zoom level.” The Board found Feldman disclosed only a “radius,” not a zoom level, and concluded there was no motivation to substitute or add a zoom parameter.

The Federal Circuit affirmed in part, agreeing that Feldman did not expressly disclose a request including a zoom level. However, it found the Board’s non-obviousness conclusion flawed. The appellate court emphasized that Feldman’s “radius” and the ’727 patent’s “current zoom level” were alternative, well-known methods of defining a search perimeter on a map. Both addressed the same problem—overcrowding of posts—and both achieved the same functional result.

Relying on KSR International Co. v. Teleflex Inc., 550 U.S. 398 (2007) and Intel Corp. v. PACT XPP Schweiz AG, 61 F.4th 1373, 1380 (Fed. Cir. 2023), the court reiterated that “simple substitution of one known element for another” can render a claim obvious. It criticized the Board for requiring more than necessary, noting that Snap’s expert testimony and prior art references established a motivation to use zoom level as a predictable design choice. The court stressed that obviousness does not require proof that the substitution was superior, only that it was a known alternative.

The Federal Circuit contrasted this case with Virtek Vision Int’l, ULC v. Assembly Guidance Sys., Inc., 97 F.4th 882 (Fed. Cir. 2024), where no evidence supported a motivation to combine. Here, substantial undisputed evidence showed that both approaches addressed the same technical problem. Accordingly, the appellate court vacated the Board’s finding of non-obviousness and remanded for reconsideration consistent with the KSR standard.

Written description requirement. Snap also challenged the sufficiency of You Map’s written description for the “combined ranking” step. It argued that You Map’s motion to amend lacked adequate explanation and that the cited portions of the specification failed to disclose the claimed ranking.

The Federal Circuit disagreed. Applying Ericsson Inc. v. Intellectual Ventures I LLC, 901 F.3d 1374 (Fed. Cir. 2018), it reviewed the Board’s procedural determinations for abuse of discretion. It found the Board reasonably concluded that the cited passages made the disclosure “apparent.” These passages described multiple maps, each with separate rankings of posts, and systems combining emotive data with geographic location into overall scores. Such examples sufficiently supported the “combined ranking” limitation.

The court distinguished Parus Holdings, Inc. v. Google LLC, 70 F.4th 1365 (Fed. Cir. 2023), where a party improperly incorporated massive exhibits without explanation. Here, You Map provided clear citations to the patent specification itself, which, under Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005), is the “single best guide” to claim meaning. Substantial evidence supported the Board’s written description finding.

Conclusion. Thus, the Federal Circuit affirmed the PTAB’s finding that You Map’s substitute claims satisfied the written description requirement, vacated the Board’s determination that the claims were nonobvious, remanded the case for further proceedings on obviousness, and awarded costs to Snap.

The Case is No. 24-1120.

Judge: Dyk, T.

Attorneys: Nathan R. Speed (Wolf, Greenfield & Sacks, PC) for Snap Inc. Richard A. Catalina, Jr. (Jardim, Meisner, Salmon, Sprague & Susser, PC) for You Map, Inc.

Companies: Snap Inc.; You Map, Inc.

Cases: Patent FedCirNews USPTO GCNNews