Elreich v. Waymo LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ahmad Abu Elreich (California)
  • Defendant: Waymo LLC (California); Uber Technologies, Inc. (California)
  • Plaintiff’s Counsel: Pro Se
• Case Identification: 1:25-cv-00814, E.D. Cal., 07/30/2025
• Venue Allegations: Venue is based on Defendant Uber’s continuous business operations, including ride-hailing services, within the judicial district where the Plaintiff resides.
• Core Dispute: Plaintiff alleges that Defendants’ ride-hailing platforms, including the integrated Uber-Waymo autonomous vehicle service, infringe a patent related to methods for securely identifying a vehicle and authenticating its rider.
• Technical Context: The technology addresses safety and efficiency in the transportation network company (TNC) market by providing a system for riders to confirm they are entering the correct vehicle through digital tokens and displays.
• Key Procedural History: The filing is a First Amended Complaint which adds Uber Technologies, Inc. as a defendant. The complaint’s allegations rely significantly on a declaration summarizing a publicly available video interview with an Uber executive, which Plaintiff characterizes as an admission of infringement.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 11,577,691 - "Method for vehicle identification and communication between transportation network company (TNC) service users," issued February 14, 2023.

The Invention Explained

• Problem Addressed: The patent’s background section identifies problems arising from the growth of TNCs, including traffic congestion and safety risks when riders struggle to locate their assigned vehicle in crowded areas. It notes that confusion can lead to incidents such as passengers "getting kidnapped as they get into the wrong vehicle," highlighting a need for a reliable identification method (’691 Patent, col. 1:28-42).
• The Patented Solution: The invention proposes a method managed by a remote server that links rider, vehicle, and operator (driver) accounts. When a ride is confirmed, the system generates a unique "identifier token" containing an "authentication key" and transmits it to both the rider's personal computing device (e.g., smartphone) and a "vehicle display device" on the assigned car. This allows the rider to visually match the token on their device with the one on the vehicle before entering, with further authentication steps to confirm the correct rider and driver are matched (’691 Patent, Abstract; col. 3:35-44; Fig. 1).
• Technical Importance: The described method aims to provide a dynamic, secure verification layer beyond static identifiers like license plates, thereby enhancing rider safety and logistical efficiency in TNC operations (’691 Patent, col. 1:43-46).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specification (Compl., Prayer A). The analysis focuses on the primary independent method claim.
• Independent Claim 1 recites a multi-step method comprising the essential elements of:
  • Providing rider, vehicle, and operator accounts managed by a remote server.
  • Associating the vehicle account with a "vehicle display device."
  • Receiving a confirmation notification from a rider's device that includes an "identifier token" with an "authentication key."
  • Generating and transmitting an "authentication query" from the operator's device to the rider's device.
  • Prompting the rider to accept the query to complete authentication.
  • Visually outputting the identifier token on both the vehicle display device and the rider's device for matching.
  • Prompting the rider to select a "desired action" (e.g., remote unlock, emergency alert).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are the ride-hailing systems and mobile applications operated by Uber Technologies, Inc., which includes services that utilize its own vehicle fleet as well as Waymo's autonomous vehicles (Compl. ¶¶ 3, 13).

Functionality and Market Context

• The complaint alleges that the accused Uber platform incorporates features that perform the patented steps. These functionalities include "assigning vehicles to riders using visual identification displays," "sending authentication tokens or vehicle identifiers," enabling audible confirmation signals, matching parties with "secure data," and allowing riders to "remotely unlock vehicle doors through the Uber app" (Compl. ¶12).
• The allegations are primarily substantiated by a declaration from the Plaintiff summarizing his review of a video interview with an Uber executive. The declaration asserts the executive admitted to features such as sending vehicle identifiers/tokens to riders for visual confirmation, using secure processes to reduce misidentification, remote unlocking, and audible confirmation alerts (Compl., p. 11, ¶4a-d).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’691 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: Claim 1 recites a specific multi-step authentication process involving an "authentication query" generated by an operator device and transmitted to the rider device for acceptance (steps F-H). The complaint alleges a general "matching" process but does not provide facts showing this specific query-and-response sequence. The analysis may turn on whether the accused system's verification method (e.g., a PIN or color-matching feature) can be read to meet these detailed claim limitations.
  • Technical Questions: A key question is what constitutes the claimed "vehicle display device." The complaint’s reference to "digital displays" is broad and could refer to a driver's smartphone mounted in the car. This raises the question of whether such a device meets the claim limitation, particularly in light of patent figures depicting a distinct, externally-mounted unit.

V. Key Claim Terms for Construction

• The Term: "vehicle display device"

  • Context and Importance: The definition of this term is critical for infringement, as it defines a key piece of hardware in the claimed system. Whether this term is construed broadly to include any screen within the vehicle (e.g., a driver's phone) or narrowly to mean a dedicated, external display will significantly impact the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states the device "can be of any shape, size, material, orientation etc." and may be positioned on "any position on the car roof of the car, the sides, the back, or the grills" (’691 Patent, col. 6:21-26). This language may support a construction not limited to a specific form factor or location.
    • Evidence for a Narrower Interpretation: The patent’s preferred embodiment and Figures 6 and 7 consistently depict the "display device (1)" as a distinct hardware unit mounted on the vehicle's roof, separate from the vehicle itself (’691 Patent, Fig. 6, 7; col. 6:17-19). This may be used to argue that the term should be limited to such purpose-built, external displays.

• The Term: "authentication query"

  • Context and Importance: Claim 1 requires a specific sequence: generating a query on an operator device, transmitting it, and prompting the rider to accept it. This is a core part of the claimed security method. Practitioners may focus on this term because the infringement allegation hinges on whether the accused system's authentication protocol aligns with this precise, interactive process.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a general description of the query as "a question associated with that particular ride" (’691 Patent, col. 4:62-63), which could arguably encompass a range of challenge-response mechanisms.
    • Evidence for a Narrower Interpretation: Claim 1 requires the query to be "generat[ed]... by the operator PC device" and transmitted "when the rider PC device is at a predefined distance" (’691 Patent, col. 7:26-30). The specification's example involves a choice-based question ("'select the right authentication key from a list of keys'"), suggesting an interactive step beyond a simple one-way code display (’691 Patent, col. 5:20-22). This suggests the possibility that a simple PIN match initiated by a server may not meet the limitation.

VI. Other Allegations

• Indirect Infringement: The complaint does not plead a separate count for indirect infringement. However, by accusing Uber of providing a platform and "systems" that enable infringement (Compl. ¶3), and adding Uber for its "Role in using and operating the Infringing technology" (Compl., p. 5), the allegations could potentially be construed to support a theory of induced infringement.
• Willful Infringement: The complaint requests enhanced damages for willful infringement (Compl., Prayer D). The alleged factual basis for willfulness appears to be the public statements from an Uber executive, which the plaintiff asserts demonstrate knowledge of the infringing features (Compl. ¶¶ 14, 15).

VII. Analyst’s Conclusion: Key Questions for the Case

• A core issue will be one of claim construction: can the term "vehicle display device," which is illustrated in the patent as a distinct, external unit, be construed to cover a general-purpose screen such as a driver's smartphone or tablet mounted inside the vehicle?
• A second central issue will be one of evidentiary sufficiency: do the generalized statements attributed to an Uber executive in a media interview provide sufficient factual detail to demonstrate that the accused platform performs every element of the asserted method claim, especially the specific, multi-step "authentication query" sequence?
• The case may also turn on a question of technical operation: does the accused system's method for matching a rider to a vehicle perform the interactive, query-and-response protocol required by Claim 1, or does it utilize a fundamentally different technical approach that falls outside the scope of the claim?