Magistrate Recommends Denial of Lyft’s Dismissal Bid in Patent Dispute

On Monday, Rideshare Displays Inc. (RSDI) secured at least a temporary victory against Lyft Inc. in a District of Delaware case it filed last November. RSDI’s amended complaint, concerning infringement of a patent whose claims are directed “to systems and methods for vehicle identification,” withstood Lyft’s motion to dismiss after the court rejected arguments that it was not patent-eligible and that RSDI failed to state a claim as to a second contested patent.

In her report and recommendation, Magistrate Judge Jennifer L. Hall analyzed the question of eligibility under Supreme Court precedent. After first holding that U.S. Patent No. 9,892,637’s first claim was not necessarily representative of its 44 other claims, the court explained that it was not convinced that all claims were directed to the abstract idea of “identifying a particular vehicle using visual indicators.”

In examining the claim as a whole, the court pointed to examples undercutting Lyft’s argument. The court explained that most claims additionally “require the communication of an indicator by a separate controller to mobile devices associated with the driver and the display of that indicator on the exterior of the vehicle where it can be viewed by the rider so that they can verify they are getting into the correct vehicle.”

The court held that the outcome of the second step of its analysis provides an independent basis for denying Lyft’s motion. As a matter of law, the court wrote, it could not conclude that the patent’s claims lack an inventive concept, citing, at minimum, the existence of a factual dispute. However, Magistrate Judge Hall reserved the right for Lyft to raise the same patent eligibility question at the summary judgment phase.

The parties have until July 26 to file objections to the magistrate’s findings.

RSDI is represented by Seitz, Van Ogtrop & Green P.A. and of-counsel Wiggin and Dana LLP, and Lyft by Ashby & Geddes and of-counsel Baker Botts L.L.P.