IP Law Daily, PATENT—Fed. Cir.: Invalidity of Rideshare’s display patents affirmed on appeal; PTAB’s allowance of substitute claims reversed, (Sep 29, 2025)

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

PTAB correctly found asserted claims obvious over prior art; erred in allowing amended substitute claims that were patent-ineligible under 35 U.S.C. § 101.

In a nonprecedential disposition, the U.S. Court of Appeals for the Federal Circuit affirmed the Patent Trial and Appeal Board's (PTAB) determinations that five patents owned by Rideshare Displays, Inc. were unpatentable for obviousness. The court agreed that the PTAB properly construed disputed claim terms, relied on substantial evidence in assessing prior art disclosures, and correctly applied obviousness principles. On cross-appeal, the Federal Circuit reversed the PTAB's partial grant of motions to amend, holding that the proposed substitute claims were patent-ineligible under 35 U.S.C. § 101 because they recited abstract ideas of coordinating human activity, and also invalid under 35 U.S.C. § 112 for lack of written description since the claimed scenarios were not disclosed in the original specification (Rideshare Displays, Inc. v. Lyft, Inc., Nos. 23-2033, -2034, -2035, -2036, -2037, -2038, -2039 (Fed. Cir. Sept. 29, 2025)).

Background. The appellant, Rideshare Displays, Inc., is a technology company that develops vehicle identification systems designed to improve rider safety in app-based ridesharing services. The cross-appellant, Lyft, Inc., is one of the largest ridesharing platforms in the United States. The intervenor, the Director of the U.S. Patent and Trademark Office, participated to address questions concerning subject matter eligibility under § 101.

The five patents at issue—U.S. Patent Nos. 9,892,637 (the ’637 patent), 10,169,987 (the ’987 patent), 10,395,525 (the ’525 patent), 10,599,199 (the ’199 patent), and 10,748,417 (the ’417 patent)—all share a common specification. They disclose “vehicle identification systems” in which a rider and a driver can confirm each other’s identities by matching indicators. The system generates a notification signal when a vehicle approaches a pickup location, which in turn triggers a display visible from outside the car.

In November 2021, Lyft filed five petitions for inter partes review (IPR) challenging the validity of these patents. Lyft relied on prior art references including Lalancette (U.S. Pub. No. 2012/0137256), which disclosed iconic displays for taxis; Kalanick (U.S. Pub. No. 2015/0332425), which covered user-configurable vehicle identifiers; Kemler (U.S. Patent No. 9,494,938), addressing signals for autonomous vehicles; and Stanfield (U.S. Patent No. 9,442,888), concerning vehicle rental indicators.

The PTAB determined that all challenged claims across the five patents were obvious in light of these references. In the IPR prceedings on the ’637 and ’199 patents, Rideshare sought to amend by adding substitute claims, some of which the PTAB allowed. Rideshare appealed the unpatentability findings, while Lyft cross-appealed the allowance of amendments.

Claim construction. Rideshare contended that the PTAB misconstrued the claim term “generate” in the phrase “generate a signal representing an indicator.” The Board gave the term its plain meaning: to originate or produce a signal. Rideshare argued that “generate” should also encompass the creation of the indicator itself. The Federal Circuit rejected this reading, explaining that the claim grammar made clear that what was generated was the signal, not the indicator. Because the PTAB’s construction was correct, Rideshare’s derivative obviousness arguments premised on a different construction failed (Seabed Geosolutions (US) Inc. v. Magseis FF LLC, 8 F.4th 1285 (Fed. Cir. 2021)).

Substantial evidence and prior art. Further, Rideshare argued that the Lalancette reference did not disclose a “mobile communication device associated with the driver.” The Federal Circuit affirmed the PTAB’s determination that Lalancette’s “mobile computer,” connected to the taxi dashboard and displaying icons, sufficed as a driver-associated device. Citing In re Gartside, 203 F.3d 1305 (Fed. Cir. 2000), the appellate court noted that the specification of Rideshare’s patents did not limit “mobile communication device” to smartphones, and substantial evidence supported the PTAB’s finding.

The company further challenged the PTAB's conclusion that Kalanick, in combination with Kemler, disclosed sending a notification signal when a vehicle is within a predetermined distance of a rider. The court upheld the Board's reasoning, noting that Kalanick taught a centralized controller determining vehicle proximity, while Kemler described notification signals tied to location. A skilled artisan would combine these teachings to improve accuracy and efficiency, consistent with the obviousness analysis set out in Graham v. John Deere Co., 383 U.S. 1 (1966).

Finally, Rideshare argued that the prior art did not disclose transmitting a first signal in response to a user’s request because Kalanick inserted intermediary configuration steps. The Federal Circuit disagreed. Referencing Knowles Elecs. LLC v. Cirrus Logic, Inc., 883 F.3d 1358 (Fed. Cir. 2018), it noted that the claims did not exclude causal chains involving intermediate actions.

Patent eligibility. Applying the Alice Corp. v. CLS Bank Int’l, 573 U.S. 208 (2014) framework, the court found that the substitute claims were directed to an abstract idea: coordinating ride pickups, a form of organizing human activity. Although the PTAB had reasoned that the claims offered a "technological solution," the court emphasized that they improved only the convenience of ridesharing, not the functioning of the underlying mobile or network technology. "[I]mproving a user's experience while using a computer application is not, without more, sufficient to render the claims directed to an improvement in computer functionality" (Simio, LLC v. FlexSim Software Prods., Inc., 983 F.3d 1353, 1361 (Fed. Cir. 2020)). The court added that invoking computers to streamline abstract processes does not confer eligibility.

Written description. The court also held that the substitute claims lacked written description support under § 112. The patents disclosed two scenarios: automatic generation of indicatory signals as a vehicle approached, or manual generation by the driver. The substitute claims instead described generating a new indicator in response to a notification signal tied to proximity, a scenario not present in the original disclosure. Citing Medytox, Inc. v. Galderma S.A., 71 F.4th 990 (Fed. Cir. 2023), the court noted that because the specification did not show possession of this concept when filing, the claims failed the written description requirement.

Conclusion. Thus, the Federal Circuit affirmed the PTAB’s determinations that all challenged claims of the five patents were unpatentable for obviousness. It also reversed the PTAB’s allowance of Rideshare’s substitute claims, holding them ineligible under § 101 and unsupported under § 112. Costs were awarded to Lyft as cross-appellant.

The Case is Nos. 23-2033, -2034, -2035, -2036, -2037, -2038, -2039.

Judge: Hughes, T.

Attorneys: Michelle Dawson (Padmanabhan & Dawson PLLC) for RideShare Displays, Inc. Eliot Damon Williams (Baker Botts LLP) for Lyft, Inc. Kakoli Caprihan, Office of the Solicitor, USPTO.

Companies: RideShare Displays, Inc.; Lyft, Inc.

Cases: Patent FedCirNews USPTO