IP Law Daily, PATENT—E.D. Mich.: Patent for vehicle tracking and control system directed to ineligible subject matter, (Mar 30, 2026)

By Steven D. Cole, J.D.

The representative claim was deemed patent-ineligible because it was directed to the abstract idea of location-based control and did not contain an inventive concept.

A patent infringement suit filed by WirelessWerx IP, LLC against Audi of America, Inc., has been dismissed by a federal district court in Michigan because the claims of the patent were invalid as patent-ineligible. WirelessWerx filed a complaint alleging that Audi infringed its U.S. Patent No. 7,323,982 (’982 Patent), “Method and system to control movable entities.” Audi moved to dismiss, arguing that the claims of the ’982 Patent did not recite patent-eligible subject matter. The court granted the motion, determining that representative Claim 1 was directed to the abstract idea of location-based control, and that the use of generic computer elements did not transform it into an inventive concept (WirelessWerx IP, LLC v. Audi of America, Inc., No. 4:25-cv-11147-FKB-CI (E.D. Mich. Mar. 26, 2026)).

The ’982 Patent. WirelessWerx’s ’982 Patent, issued on January 29, 2008, is directed to computer-based tracking systems for vehicles. It purports to improve upon then-existing tracking systems utilizing Global Positioning System (GPS) technology primarily by incorporating a geofencing feature. As its basic components, in addition to a wireless communications network, the purportedly novel tracking system includes a transponder for each vehicle, a client console for users to interact with the transponder, and a backend control system for handling communications between the transponder and the client console. The ’982 Patent consists of 61 claims, all of which recite methods of wirelessly controlling an “entity” (e.g., a vehicle) in relation to a geographical zone through the use of a computing device, a transponder attached to the entity, and a pixilated image.

The parties agreed that Claim 1 was exemplary for the purpose of alleging infringement. The court summarized representative Claim 1 as “recit[ing] method steps for monitoring and controlling an entity which the written description describes as being directed to using coordinates to define a geographical zone on a pixilated image, recognizing when the entity enters or exits the geographical zone, and then controlling the entity in relation to the geographical zone.”

Audi characterized representative Claim 1 as being directed to the abstract idea of “monitoring objects in space.” WirelessWerx countered by arguing that representative Claim 1 focused on the technological improvement of “wireless control of an entity through an attached transponder in a geographical zone that is defined by a plurality of coordinates in the memory of the transponder.”

Abstract idea. The court sided with Audi’s depiction in holding that representative Claim 1 described the abstract idea of location-based control for three reasons. First, representative Claim 1 recited a method of organizing human activity—broadly covering embodiments in which the transponder was configured to carry out everyday actions performed by drivers, such as turning the ignition on and off, locking and unlocking the doors, and increasing and decreasing the vehicle’s speed. Additionally, the generally-worded claim language contemplated embodiments in which the “entity” could refer to any movable object. Second, representative Claim 1 recited a mental process. All of the method steps executed by the transponder could be performed mentally, using a paper map and a pen by a human driver when planning and making a trip to the destination. Third, representative Claim 1 recited a process of collecting and analyzing information. WirelessWerx did not identify any claim language that went further than invoking the transponder as a tool to perform a method focused on collecting information of a particular content, analyzing information by steps people go through in their minds or by mathematical algorithms, and taking some action as an ancillary part of such collection and analysis.

As a further confirmation of abstractness, the court noted that representative Claim 1 was similar to other claims involving location-based decision-making that the Federal Circuit has held to be directed to abstract ideas, such as “exchanging information concerning a bet and allowing or disallowing the bet based on where the user is located” in Beteiro, LLC v. DraftKings Inc., 104 F.4th 1350, 1355 (Fed. Cir. 2024), and “providing advance notification of the pickup or delivery of a mobile thing” in Electronic Communication Technologies, LLC v. ShoppersChoice.com, LLC, 958 F.3d 1178, 1181 (Fed. Cir. 2020).

Lack of technological improvement. WirelessWerx, in contending that representative Claim 1 of the ’982 Patent was focused on a technological improvement to tracking systems, emphasized the geofencing feature as a way of “maximizing the benefits of utilizing GPS technology,” citing the ability to wirelessly control an entity “through an attached transponder in a geographical zone that is defined by a plurality of coordinates in the memory of the transponder.” But, in the opinion of the court, this was merely the recitation of “a generic computer implementation of the abstract idea of location-based control, i.e., monitoring the location of an entity and taking some action to control the entity based on its location.” It found the claim elements of representative Claim 1 to be indistinguishable from various computer-based claim elements that the Federal Circuit has found to be insufficient to constitute an inventive concept. See, e.g., Intell. Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1368 (Fed. Cir. 2015) (explaining that a database, a user profile, and a communication medium “are all generic computer elements”); Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1355 (Fed. Cir. 2016) (explaining that “off-the-shelf” computers, networks, and displays “are not even arguably inventive”); SAP Am., Inc. v. InvestPic, LLC, 898 F.3d 1161, 1169–70 (Fed. Cir. 2018) (explaining that various databases and processors recited by the claims were “just already available computers, with their already available basic functions, to use as tools in executing the claimed process”); Beteiro, 104 F.4th at 1359 (explaining that the inclusion of GPS on a mobile phone was “conventional (even as of 2002) computer equipment”).

Dismissal of complaint. WirelessWerx petitioned the court for leave to amend its complaint, should it grant Audi’s motion to dismiss. The court denied this request and dismissed the complaint with prejudice, citing the “boilerplate language” in WirelessWerx’s petition. This did not comply with the federal requirements for filing a motion seeking leave to amend, which require a party to “state with particularity the grounds for seeking the order.” Fed. R. Civ. P. 7(b)(1)(B).

The Case is No. 4:25-cv-11147-FKB-CI.

Judge: Behm, F.

Attorneys: William P. Ramey, III (Ramey LLP) for WirelessWerx IP, LLC. Elliot Cook and Sherry Hanhui Li (Finnegan, Henderson, Farabow, Garrett Dunner, LLP).

Companies: WirelessWerx IP, LLC; Audi of America, Inc.

Cases: Patent MichiganNews