Carma Technology Corp v. Uber Tech Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Carma Technology, Corp. (Delaware) and Carma Technology, Ltd. (Ireland)
  • Defendant: Uber Technologies, Inc. (Delaware)
  • Plaintiff’s Counsel: McKool Smith, P.C.; Bunsow De Mory LLP
• Case Identification: 2:25-cv-00029, E.D. Tex., 01/14/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant Uber has a regular and established place of business in Frisco, Texas, within the district, and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s ridesharing and delivery platforms infringe five patents related to shared transportation networks, proxy communications for user safety, logistics for chained deliveries, and management of anomalous trip conditions.
• Technical Context: The technology concerns the foundational software and network architecture for managing modern, on-demand transportation services that match riders, drivers, and goods in real-time.
• Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the patent portfolio, citing a direct notice letter regarding the lead patent sent in 2016. It further alleges that Defendant’s own patent applications were repeatedly rejected by the USPTO over Plaintiff’s patents and published applications dating back to at least 2015, and that Defendant has cited Plaintiff's patents more than 60 times during its own patent prosecution, facts which may be central to the allegations of willful infringement.

Case Timeline

Date	Event
2007-02-12	Earliest Priority Date for all Asserted Patents
2009-01-01	Uber founded as UberCab
2010-01-01	Uber launches ridesharing service in San Francisco
2010-11-23	’427 Patent Issued
2014-01-01	UberPOOL (later UberX Shared) launched
2015-03-16	Earliest alleged date of Uber’s knowledge via USPTO rejection
2016-08-30	Plaintiff sent direct notice letter to Uber regarding ’427 Patent
2020-08-11	’071 Patent Issued
2021-02-09	’138 Patent Issued
2021-05-25	’668 Patent Issued
2021-11-02	’456 Patent Issued
2022-05-01	Uber releases Driver Destination feature
2024-05-02	Uber cites ’456 Patent in an Information Disclosure Statement
2025-01-14	Complaint Filing Date

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

U.S. Patent No. 7,840,427 - “Shared transport system and service network”

The Invention Explained

• Problem Addressed: The patent’s background section describes dysfunctional urban transportation networks, the inefficient use of personal vehicles with empty seats, and a "lack of information about the availability of services and timing between locations" for traditional carpooling (Compl. ¶¶45-46; ’427 Patent, col. 2:1-6, 4:6-8).
• The Patented Solution: The invention provides a networked computer system to match transportation supply (drivers with spare capacity) with demand (riders or goods) in real-time (’427 Patent, Abstract). The system establishes electronic registries for both supply and demand, creates a "network of nodes" representing pick-up and drop-off points, and uses a match engine to connect users and providers traveling along similar routes, thereby improving efficiency and information availability (Compl. ¶¶44, 73; ’427 Patent, col. 3:63-4:4).
• Technical Importance: The technology provided a framework for a dynamic, real-time ridesharing marketplace, moving beyond static carpooling arrangements by leveraging GPS-enabled devices and a central server to coordinate users and vehicles on demand (Compl. ¶¶43, 49).

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶74).
• Claim 1 recites a method of sharing transportation comprising the steps of:
  • providing a computer network;
  • establishing an electronic registry of transport capacity (supply);
  • establishing a network of nodes representing pick-up and drop-off points;
  • abstracting a geographic representation of a predetermined transport vehicle journey into a set of said nodes;
  • providing an electronic registry of demand; and
  • effecting a match in a match engine between transport capacity and demand for a journey between at least two nodes.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 10,741,071 - “Systems and Methods for Proxy Communication in a Shared Transport System”

The Invention Explained

• Problem Addressed: The patent addresses safety and anonymity concerns where riders or drivers may not want to share personal contact information, such as a phone number, with a stranger (Compl. ¶52; ’071 Patent, col. 5:2-6).
• The Patented Solution: The invention describes a proxy messaging system that allows parties in a shared transport system to communicate without revealing their personal contact details (’071 Patent, Abstract). The system receives a first message from a sender, generates a second message containing the contents of the first message along with a unique identifier, and transmits that second message to the recipient, thereby masking the sender's identity (Compl. ¶104; ’071 Patent, Fig. 13).
• Technical Importance: This technology enhances user safety and privacy, which is a critical factor for building trust and encouraging user adoption of services that connect strangers for transportation (Compl. ¶52).

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶105).
• Claim 1 recites a method of exchanging messages comprising:
  • identifying a transport user and a transport provider based on a transport request;
  • receiving, by a proxy messaging system, a first message from a sender (either user or provider);
  • generating, by the proxy system, a second message comprising the contents of the first message and a first unique identifier associated with the sender; and
  • transmitting the second message to the recipient (the other of the user or provider).
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 10,916,138 - “Systems and Methods for Utilizing a Shared Transport Network for Delivery of Goods”

• Technology Synopsis: This patent claims methods for transporting goods that increase efficiency by chaining multiple deliveries. The system identifies a transport provider for a first delivery, tracks its progress, and upon its completion, identifies and dispatches a second nearby delivery to the same provider (Compl. ¶118; ’138 Patent, Abstract).
• Asserted Claims: At least Claim 1 (Compl. ¶119).
• Accused Features: The complaint alleges that Uber’s Delivery Products, including Uber Eats and Uber Freight, infringe by offering features for “reloads,” “back-to-back,” and “batched orders” that chain multiple deliveries for a single driver (Compl. ¶¶26, 144-145).

U.S. Patent No. 11,017,668 - “Systems and Methods for Managing Anomalous Conditions in a Shared Transport System”

• Technology Synopsis: This patent describes a safety system that continuously tracks a vehicle’s location, analyzes the data for anomalous conditions (e.g., a crash or unexpected long stop), and, upon detection, transmits a notification to the user, provider, or security personnel (’668 Patent, Abstract; Compl. ¶150).
• Asserted Claims: At least Claim 1 (Compl. ¶151).
• Accused Features: The complaint accuses Uber’s “RideCheck” feature, which allegedly detects unusual events like crashes or long stops and proactively sends notifications to riders and drivers to check if they need help (Compl. ¶¶25, 154).

U.S. Patent No. 11,164,456 - “Systems and methods for matching pick-up requests with transport providers, tracking trip progress, and enabling provider ratings”

• Technology Synopsis: The patent claims a comprehensive, end-to-end method for managing a rideshare trip. This includes receiving a request, identifying and dispatching a provider, tracking trip progress via GPS, displaying information (cost, ETA, provider details) to both parties, processing ratings, and handling payment (’456 Patent, Abstract; Compl. ¶161).
• Asserted Claims: At least Claim 1 (Compl. ¶162).
• Accused Features: The complaint alleges that the core functionality of the Uber Rideshare and Uber Eats products, which manage the entire lifecycle of a ride or delivery from request to payment and rating, infringes this patent (Compl. ¶164).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are Defendant’s “Uber Rideshare Products” (e.g., UberX, UberX Shared, UberXL) and “Uber Delivery Products” (e.g., Uber Eats, Uber Connect/Package, Uber Freight) (Compl. ¶¶25-26).

Functionality and Market Context

• The complaint alleges these products operate on a unified technology platform that connects consumers with independent drivers and couriers (Compl. ¶27). Key accused functionalities include a backend system that matches supply with demand based on location and other parameters; a proxy communication system for user anonymity; features for en-route pickups and chained deliveries; and a safety monitoring system called "RideCheck" that detects trip anomalies (Compl. ¶¶25-26, 154). The complaint positions these products as central to Defendant’s business and the global ridesharing and delivery markets.

IV. Analysis of Infringement Allegations

’427 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
providing a computer network	Uber provides and operates a computer network comprising a "giant infrastructure consisting of thousands of services and terabytes of data," including cloud computing services and data centers.	¶¶76-77	col. 4:10-14
establishing an electronic registry in said computer network of capacity containing an indication of the spare transport capacity and location of a plurality of transport vehicles	Uber’s backend system maintains a matching system that orchestrates trips by identifying available drivers, their locations, and their capacity to provide a service.	¶¶79-80	col. 4:55-63
establishing a network of nodes in said computer network representing a plurality of pick-up points and a plurality of drop-off points	Uber’s system creates a spatial index of pick-up and drop-off locations, which are represented as points (nodes) on a street map, using global grid systems like S2 and H3.	¶¶85, 87	col. 13:36-41
abstracting a geographic representation of a predetermined transport vehicle journey by calculating places where said predetermined transport vehicle journey intersects said nodes...	With features like UberX Share and Driver Destination, Uber’s system calculates routes to pick up multiple riders, determining where a driver's journey will intersect with a rider’s requested journey.	¶¶88-90	col. 15:1-5
providing an electronic registry in said computer network of demand containing an indication of the demand for transportation needs...	Uber’s platform receives and registers user requests for rides or deliveries, which indicate a demand for transportation, and uses this data to match with drivers.	¶¶93-95	col. 3:1-4
effecting a match in a match engine... between at least two of said nodes	Uber’s backend system serves as a real-time marketplace that matches rider requests (demand) with available drivers (capacity) moving in a similar direction or whose destinations correspond to nodes in the registry.	¶¶96, 98-99	col. 8:44-50

• Identified Points of Contention:
  • Scope Questions: A central issue may be whether the term "network of nodes," as described in a patent with a 2007 priority date, can be construed to read on the dynamic, non-fixed pick-up and drop-off points generated by Uber's modern spatial indexing systems (e.g., S2/H3). The complaint alleges this mapping (Compl. ¶85), but the defense may argue the patent contemplated a more static network.
  • Technical Questions: What evidence does the complaint provide that Uber's backend matching system performs the specific step of "abstracting a geographic representation of a... journey... in the format of a set of said nodes"? The complaint points to UberX Share functionality (Compl. ¶89), but the precise technical mechanism of that feature compared to the claim language will be a key point of analysis.

’071 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
identifying... a transport user and a transport provider based on... receiving... a transport request from a transport user device	An Uber user requests a ride via the app, which includes a pick-up location; the request is sent to Uber's system, which identifies a proximate driver.	¶107	col. 8:34-43
receiving, by a proxy messaging system, a first message from a sender device of a sender	Uber's in-app communication system (UberChat) receives a message from either the rider's or driver's device. The complaint includes a diagram illustrating this message flow. (Compl. ¶110, Figure 4).	¶¶108, 110-111	col. 13:15-18
generating, by the proxy messaging system, a second message, wherein the second message comprises contents of the first message and a first unique identifier associated with the sender	Uber's messaging platform generates a second message containing the content of the first message and an identification of the sender to be routed to the recipient.	¶112	col. 13:31-34
transmitting, by the proxy messaging system, the second message to a recipient device of a recipient...	Uber’s system transmits the message to the recipient's device using anonymized contact information, thereby eliminating personal details from the communication.	¶113	col. 13:47-50

• Identified Points of Contention:
  • Scope Questions: Does the term "proxy messaging system" as used in the patent encompass the full architecture of the accused UberChat platform? The complaint's referenced diagram shows a multi-step process involving an Edge Gateway and a Messaging Platform (Compl. ¶110, Figure 4), which may raise questions of whether a single entity performs all claimed steps of the method.
  • Technical Questions: What is the specific nature of the "first unique identifier" required by the claim, and does the complaint provide evidence that Uber’s system generates and uses such an identifier in the claimed manner to associate a message with a sender?

V. Key Claim Terms for Construction

Patent: ’427 Patent

• The Term: "network of nodes"
• Context and Importance: The infringement theory for the '427 patent depends on mapping Uber's system of dynamic, user-defined pick-up and drop-off locations onto the claimed "network of nodes." Practitioners may focus on this term because its construction will determine whether the claim can cover a fluid, on-demand system versus a more structured, pre-defined network.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests nodes can be organized into a "stream of stop nodes" to represent a journey, implying a more abstract or logical connection rather than a physically fixed one (Compl. ¶427 Patent, col. 15:39-42).
  • Evidence for a Narrower Interpretation: The patent’s figures, such as Figure 8a, depict nodes as specific, named geographic locations and intersections (e.g., “Kinsale Roundabout,” “Cork Airport”), which could support an interpretation requiring more defined, fixed points than any address a user might enter into the Uber app (’427 Patent, Fig. 8a).

Patent: ’071 Patent

• The Term: "generating, by the proxy messaging system, a second message"
• Context and Importance: The infringement analysis will likely turn on whether Uber's multi-component chat architecture can be characterized as a single "proxy messaging system" that "generates" a message as claimed. Practitioners may focus on this term because modern distributed systems often separate message routing, persistence, and notification functions, which may not align with the patent's more monolithic description.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent describes the overall goal as enabling "communications between members of the community without losing this identity," suggesting the term could be interpreted functionally to cover any system achieving that result (’071 Patent, col. 13:25-30).
  • Evidence for a Narrower Interpretation: Figure 13 of the patent depicts a specific flowchart where a message is evaluated for content and may be reviewed by an operator before being redirected, a specific sequence that may be used to argue for a narrower definition than the fully automated system described in the complaint (’071 Patent, Fig. 13).

VI. Other Allegations

Willful Infringement

• The complaint makes extensive allegations of willful infringement for all asserted patents. It alleges that Defendant was aware of the foundational '427 patent portfolio through multiple channels, including a direct notice letter in 2016 (Compl. ¶54), numerous USPTO rejections of Defendant’s own patent applications over Plaintiff’s technology starting in 2015 (Compl. ¶¶57-59), and Defendant’s citation of Plaintiff’s patents in its own prosecution filings (Compl. ¶60). The complaint further alleges Defendant was aware of Plaintiff’s predecessor company, Avego, as a direct competitor in the San Francisco Bay Area in the early 2010s (Compl. ¶¶66-69).

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

• A core issue will be one of temporal scope and construction: can claim terms drafted for a 2007-era vision of ridesharing, such as "network of nodes," be construed to cover the highly dynamic, algorithmically complex, and geographically unbounded systems that define modern platforms like Uber? The case may depend on whether the patent's concepts are viewed as foundational principles or as descriptions of a specific, now-outdated technical implementation.
• A second key issue will be one of willfulness and intent: given the extensive and multi-faceted allegations of pre-suit knowledge, a central question for the fact-finder will be whether Defendant’s continued conduct, particularly after its own patent applications were allegedly blocked by Plaintiff’s inventions, constitutes willful infringement warranting enhanced damages.
• A third key question will be evidentiary and technical: does the complex, multi-layered "Big Data Stack" architecture that powers Uber (Compl. ¶81, Figure 1) actually perform the specific, ordered method steps recited in the patents’ claims, or will discovery reveal a fundamental mismatch between the patented methods and the accused system's true technical operation?