Defendant Lyft’s motion for attorney’s fees has been denied despite its victory in the underlying patent case brought by RideApp. Lyft asserted that the case is exceptional and its fees should be paid for under 35 U.S.C. § 285, which states that “[t]he court in exceptional cases may award reasonable attorney fees to the prevailing party.” This is contrary to the standard “American Rule,” which states that “[e]ach litigant pays his own attorney’s fees, win or lose, unless a statute or contract provides otherwise.” A party has to prove that its case is exceptional to justify the attorney’s fees exception. The court stated it “does not find the circumstances of this case to warrant such a departure [from the American Rule].”
Lyft primarily argued that RideApp should have ended the case no later than after the Patent Trial and Appeal Board (PTAB), an administrative court, “opined that the asserted claims were indefinite.” The court stated, however, that unlike other exceptional cases, “the legal determination in this case – which issued from the PTAB – was not controlling.” The court continued that “Lyft does not dispute that the PTAB’s decisions are not binding on this Court, nor does it dispute that the PTAB has no jurisdiction to invalidate a patent based on indefiniteness.” Further, the court “does not find exceptional RideApp’s decision to continue this litigation following the PTAB’s non-dispositive ruling. Nor does it find RideApp’s litigation positions to have been so unreasonable as to make this case exceptional.” The court stated that it does not find RideApp’s actions to necessitate an attorney fee award. While the court previously questioned RideApp’s behavior, it was not so egregious to deem the case exceptional.
RideApp sued Lyft for patent infringement for its “unified ride and vehicle sharing system,” while Lyft alleged that claims 2, 3, and 6 of RideApp’s patent were invalid. The case was terminated in October 2019, the court ruled in favor of Lyft and the invalidity of three claims of the patent, dismissed Lyft’s motion to dismiss RideApp’s Second Amended Complaint, dismissed RideApp’s claims and stated that it should not receive relief from its claims.
The suit was filed in the California Northern District Court. RideApp is represented by Kasowitz Benson Torres. Lyft is represented by Baker Botts.
