Autolocate Systems LLC v. Via Transportation Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: AutoLocate Systems LLC (New Mexico)
  • Defendant: Via Transportation, Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01318, D. Del., 10/29/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware, has an established place of business in the District, and has committed acts of patent infringement in the District.
• Core Dispute: Plaintiff alleges that Defendant’s transportation services infringe a patent related to systems for wirelessly transmitting a vehicle's current location and estimated arrival time to a user's mobile device.
• Technical Context: The technology at issue falls within the domain of real-time vehicle tracking and communication, a foundational component of modern ride-sharing, public transit, and logistics management systems.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,340,904 - "Transmission of wireless messages of current vehicle location and estimated arrival time to requestors"

• Patent Identification: U.S. Patent No. 8,340,904, “Transmission of wireless messages of current vehicle location and estimated arrival time to requestors,” issued December 25, 2012.

The Invention Explained

• Problem Addressed: The patent’s background section identifies the inconvenience and uncertainty faced by passengers waiting for public transportation, such as a bus, who have no reliable information about the vehicle’s actual location or its real-time arrival schedule, which is often unpredictable due to traffic or other delays (’904 Patent, col. 1:25-44).
• The Patented Solution: The invention proposes a wireless communication device installed on a moving vehicle that can receive a request from a user’s portable device (e.g., a cell phone). The on-vehicle device computes its geographic location using GPS, estimates its arrival time to the user's location, and transmits a message containing this information back to the user’s device (’904 Patent, Abstract; col. 6:28-56). The system architecture depicted in Figure 2 illustrates an on-vehicle device (210) that includes a GPS (225) and map database (230) and communicates with a remote requestor (250) (’904 Patent, Fig. 2).
• Technical Importance: The technology aimed to replace reliance on static, printed schedules with dynamic, on-demand location and arrival time information provided directly to passengers, enabling better time management (’904 Patent, col. 3:20-29).

Key Claims at a Glance

• The complaint does not identify specific claims, referring generally to the "Exemplary '904 Patent Claims" (Compl. ¶11, ¶16). Independent claim 1 is foundational to the patent.
• Essential elements of Independent Claim 1 include:
  • A wireless communication device disposed on a vehicle for public transportation.
  • A vehicle location processor for receiving GPS data to compute the vehicle's geographic location.
  • A request response subsystem for receiving a real-time wireless telephonic signal from a remote requestor carrying a portable communication device.
  • The subsystem automatically generates and transmits a real-time vehicle location message directly to the requestor's portable device.
  • This transmission is performed "without requiring to use a stationary communication device" and indicates when the vehicle will arrive at each of a plurality of stops.

III. The Accused Instrumentality

Product Identification

• The complaint accuses "Exemplary Defendant Products" but does not name specific products or services (Compl. ¶11). Based on the Defendant's identity as Via Transportation, Inc., the accused instrumentalities are understood to be its software platforms and services for on-demand and pre-scheduled transit.

Functionality and Market Context

• The complaint provides no specific description of the accused products' functionality, instead incorporating by reference "charts" from an unprovided Exhibit 2 (Compl. ¶16, ¶17).
• Via Transportation, Inc. operates in the technology-enabled transit sector, providing services that allow users to book rides, view vehicle locations in real-time on a map, and receive estimated times of arrival via a mobile application.

IV. Analysis of Infringement Allegations

The complaint alleges infringement but incorporates the substantive analysis into an external document, Exhibit 2, which was not provided (Compl. ¶16). The complaint states that this exhibit contains claim charts comparing the asserted claims to the accused products and alleges that the products "practice the technology claimed by the '904 Patent" (Compl. ¶16). Without the referenced claim charts, a detailed element-by-element analysis is not possible based on the complaint alone. No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the language of claim 1 of the ’904 Patent and the general nature of modern ride-sharing systems, several key points of contention may arise.
  • Scope Questions: A central dispute may concern the claim limitation "without requiring to use a stationary communication device" (’904 Patent, col. 9:16-18). The question for the court will be whether Defendant's system, which likely relies on cloud-based servers (stationary devices) to coordinate between drivers and riders, meets this limitation. Another question is whether communication routed through a central server can be considered transmitted "directly to the portable communication device of the remote requestor" as the claim requires (’904 Patent, col. 9:14-16).
  • Technical Questions: The complaint lacks the technical detail to frame specific questions about the operation of the accused products. A key factual question will be how Defendant's system architecture routes requests and transmits location and ETA data between the vehicle and the user.

V. Key Claim Terms for Construction

• The Term: "without requiring to use a stationary communication device" (Claim 1)

  • Context and Importance: The viability of the infringement claim may hinge on the construction of this term. Defendant’s system likely requires communication with its central servers, which could be characterized as stationary communication devices, to function.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue the term should be construed from the user’s perspective, meaning the user is not required to use a stationary device like a landline phone or desktop computer to make a request. The patent’s focus is on enabling mobile-to-mobile communication.
    • Evidence for a Narrower Interpretation: A party could argue this term defines a required system architecture that is decentralized and does not depend on a fixed, intermediary device for the claimed communication. The patent’s description of an embodiment where the on-vehicle device itself receives and responds to requests could support this view (’904 Patent, col. 6:47-56).

• The Term: "directly to the portable communication device of the remote requestor" (Claim 1)

  • Context and Importance: This term defines the required communication path. Whether a server-mediated data transmission satisfies the "directly" requirement will be a critical issue.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue "directly" refers to the ultimate destination of the message, meaning it is sent for the purpose of being received by the user's device, irrespective of any intermediate network routing through servers.
    • Evidence for a Narrower Interpretation: A party could contend that "directly" implies a communication link that does not pass through an intermediary processing hub like a central server. The contrast between the system in Figure 1, which includes a "traffic message center" (110), and the language of claim 1 may be a focus of argument (’904 Patent, Fig. 1).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells its products to customers and provides "product literature and website materials" that instruct them to use the products in an infringing manner (Compl. ¶14-15).
• Willful Infringement: The complaint does not allege pre-suit knowledge. It asserts that Defendant has had "actual knowledge of infringement" since the service of the complaint and that any continued infringement is therefore willful (Compl. ¶13, ¶15).

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

• A core issue will be one of architectural scope: does the claimed system, which transmits location messages "without requiring to use a stationary communication device," read on the Defendant's modern, server-centric ride-sharing architecture? The construction of this negative limitation will likely be dispositive.
• A second key issue concerns the communication path: can a message routed from a vehicle, through a central server, and then to a user's mobile app be considered transmitted "directly" as required by the asserted claim? This will test the boundary between direct and indirect communication in the context of the patent's disclosure.
• Finally, a threshold procedural question will be one of pleading sufficiency: given that the complaint's substantive infringement allegations are contained entirely within an unprovided external exhibit, the initial phases of litigation may focus on whether the complaint itself pleads sufficient facts to state a plausible claim for relief.