IP Law Daily, PATENT—N.D. Cal.: Geotracking patents asserted against Lyft, Uber fail Alice test, (Jun 20, 2024)

By Kevin M. Finson

Patent claims directed to the tracking of mobile device locations were invalid for being directed at an abstract idea because they merely recited the collection and analysis of information by use of conventional computer equipment.

Uber and Lyft were entitled to dismissal of two separate but near-identical infringement lawsuits against them by Enovsys, LLC, the U.S. District Court in San Jose has held. The asserted claims of three patents were invalid for being directed at the abstract idea of collecting and analyzing information by using conventional computer equipment without adding an inventive concept (Enovsys LLC v. Uber Technologies, Inc., No. 5:23-cv-04549-EJD and Enovsys LLC v. Lyft, Inc., No. 5:23-cv-05157-EJD (N.D. Cal. June 17, 2024)).

Enovsys, LLC (Enovsys) was the owner of U.S. Patents Nos. 6,441,752 (the ’752 patent); 6,756,918 (the ’918 patent); and 7,199,726 (the ’726 patent), each of which had similar specifications and which were entitled, “Method and Apparatus for Locating Mobile Units Tracking Another or Within a Prescribed Geographic Boundary” and were directed to the collecting and analyzing of the locations of mobile devices within a given geographic area. Enovsys brought suit against Uber Technologies, Inc. (Uber) and Lyft, Inc. (Lyft) for infringement in two separate cases which the court related. Both defendants filed motions to dismiss for failure to state a claim due to the asserted patents being directed at ineligible subject matter. The court held a combined hearing on both cases and applied the two-step Alice test in two separate but near-identical opinions.

Abstract idea. The court began with the issue of a representative claim. Both defendants argued that Claim 15 of the ’918 patent was representative, while Enovsys argued that several other claims required consideration. The court held that the other claims identified by Enovsys were substantially similar to those in the defendant’s preferred representative claim and that there was no showing that other claims would lead to a different result. Reviewing several prior cases, the court found that the claims at hand were most analogous to those which had already been found to be abstract such as collecting, receiving, analyzing, and sending information. The fact that this was done in the context of mobile devices did not change the inherently abstract nature of the claims, and the court noted that the claim language was not directed at any specific improvement in computer functionality.

Inventive concept. Turning to step two of the Alice test, the court found that there was no inventive concept present in the claim language, only the application of the abstract idea through conventional and generic computer components.

The court dismissed the complaints in both cases without leave to amend, finding that amendment would be futile in light of the patent language.

The Cases are No. 5:23-cv-04549-EJD and No. 5:23-cv-05157-EJD.

Judge: Davila, E.

Attorneys: Stanley Hugh Thompson, Jr. (Thompson Technology Law) for Enovsys LLC. Jeremy J. Taylor (Baker Botts LLP) for Lyft, Inc. Heidi Lyn Keefe (Cooley LLP) for Uber Technologies, Inc.

Companies: Enovsys LLC; Lyft, Inc.; Uber Technologies, Inc.

Cases: Patent TechnologyInternet CaliforniaNews