DCT

1:25-cv-00882

Municipal Parking Services Inc v. Parking Revenue Recovery Services Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00882, W.D. Tex., 08/13/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendants maintain regular and established places of business in Austin and have committed the alleged acts of infringement in the District by providing and using the accused automated parking systems at facilities located there.
  • Core Dispute: Plaintiff alleges that Defendants’ automated, gateless parking monitoring and management systems infringe five patents related to technology for identifying vehicles, tracking their duration of stay, and automatically enforcing parking violations.
  • Technical Context: The technology at issue facilitates "gateless" or "frictionless" parking by replacing physical barriers and on-site attendants with camera-based monitoring of vehicle entry and exit points and a remote, networked enforcement system.
  • Key Procedural History: The complaint notes that U.S. Patent Nos. 10,121,172, 11,257,302, and 11,688,205 survived ex parte reexamination proceedings at the USPTO, where the patentability of numerous asserted claims was confirmed in view of additional prior art. The complaint also alleges Plaintiff put Defendant LAZ Parking on notice of at least one patent-in-suit during a spring 2022 meeting, prior to the filing of the lawsuit.

Case Timeline

Date Event
2013-01-25 Earliest Patent Priority Date ('172, '302, '205, '085, '187 Patents)
2018-11-06 U.S. Patent No. 10,121,172 Issues
2022-02-22 U.S. Patent No. 11,257,302 Issues
Spring 2022 Plaintiff allegedly put Defendant LAZ Parking on notice of the ’172 Patent
2023-06-27 U.S. Patent No. 11,688,205 Issues
2024-08-28 Third party requests ex parte reexamination of the ’172, ’302, and ’205 Patents
2024-11-12 U.S. Patent No. 12,142,085 Issues
2025-03-11 U.S. Patent No. 12,249,187 Issues
2025-03-17 USPTO issues Reexamination Certificate confirming patentability of claims of the ’205 Patent
2025-03-19 USPTO issues Reexamination Certificate confirming patentability of claims of the ’172 Patent
2025-03-20 USPTO issues Reexamination Certificate confirming patentability of claims of the ’302 Patent
2025-08-13 Complaint Filing Date

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

U.S. Patent No. 10,121,172 - "Parking Lot Monitoring System"

  • Issued: November 6, 2018

The Invention Explained

  • Problem Addressed: The patent addresses the costs and inefficiencies of conventional parking management, which requires "significant manual intervention" by consumers and lot owners, and notes that unmanned lots can present safety and security issues (Compl. ¶¶ 105, 111; ’172 Patent, col. 1:56-63).
  • The Patented Solution: The invention automates parking management by using cameras at facility entrances and exits to capture vehicle identification data (like license plates) and log entry/exit times. This data is sent to a remote computer system that determines if a violation has occurred (e.g., an overstay) and issues a violation notice, eliminating the need for on-site attendants and physical gates (’172 Patent, Abstract; Compl. ¶¶ 103, 115).
  • Technical Importance: This approach provided a technical solution for "gateless" parking facilities, which could increase revenue and improve enforcement while reducing congestion and hardware costs (Compl. ¶¶ 113, 115).

Key Claims at a Glance

  • The complaint asserts independent claim 12 and dependent claims 13, 14, 16, 18, and 19 (Compl. ¶285).
  • Independent Claim 12 recites a method with the following essential elements:
    • Sensing a vehicle entering and exiting a parking lot.
    • Capturing image data of the vehicle at both entry and exit.
    • Transmitting the image data to a remote networked computer system.
    • Recording the times of entry and exit.
    • Determining an identification of the vehicle from the image data at both entry and exit.
    • Determining that a parking violation has occurred.
    • Communicating notice of the parking violation to the remote networked computer system.
  • The complaint does not explicitly reserve the right to assert additional claims of the ’172 Patent.

U.S. Patent No. 11,257,302 - "Parking Meter System"

  • Issued: February 22, 2022

The Invention Explained

  • Problem Addressed: The patent addresses the high labor costs and incomplete enforcement of traditional parking systems, which rely on personnel to manually monitor lots and issue tickets. It also notes that conventional electromechanical gates are costly and prone to failure (Compl. ¶¶ 97, 117; ’302 Patent, col. 2:25-28).
  • The Patented Solution: The invention provides a "meterless, gateless, unattended parking lot management system" that monitors vehicle entry and exit points to automatically identify all violators (’302 Patent, col. 23:25-27). By replacing on-site personnel and hardware with automated remote enforcement, the system aims to enhance revenue and reduce operational costs (Compl. ¶¶ 98-99, 118; ’302 Patent, col. 2:20-28).
  • Technical Importance: The technology offered a counterintuitive solution at the time: improving parking enforcement and revenue by removing, rather than adding, on-site infrastructure like gates and individual space monitors (Compl. ¶¶ 112, 133).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-6 and 8 (Compl. ¶315).
  • Independent Claim 1 recites a method with the following essential elements:
    • Capturing image data of a vehicle entering a parking lot.
    • Transmitting the entry image data to a remote networked computer system.
    • Recording the vehicle's time of entry.
    • Determining an identification of the entering vehicle.
    • Capturing image data of the vehicle exiting the lot.
    • Transmitting the exit image data to the remote system.
    • Recording the time of exit.
    • Determining an identification of the exiting vehicle.
    • Determining a parking violation has occurred due to a time period expiring before the vehicle exits.
    • Issuing a parking violation notice.
  • The complaint does not explicitly reserve the right to assert additional claims of the ’302 Patent.

U.S. Patent No. 11,688,205 - "Parking Meter System"

  • Issued: June 27, 2023
  • Technology Synopsis: This patent, which shares a specification with the ’302 Patent, is directed to automated parking management technology. It describes methods and systems that solve problems of conventional parking enforcement by using remote, camera-based monitoring of vehicle entry and exit to automatically detect and process violations without on-site personnel (Compl. ¶¶ 91, 100, 102).
  • Asserted Claims: Independent claim 16 and dependent claims 17-18 are asserted (Compl. ¶345).
  • Accused Features: The complaint alleges that the ARC system’s method of capturing entry/exit images, identifying vehicles, determining violations based on an expired time period, and automatically issuing violation notices infringes the asserted claims (Compl. ¶345).

U.S. Patent No. 12,142,085 - "Parking Meter System"

  • Issued: November 12, 2024
  • Technology Synopsis: As part of the same patent family, this patent addresses technical problems in the parking industry related to revenue loss and high operational costs. The patented solution involves an automated, gateless system that monitors the "whole parking lot" via entry and exit points rather than individual spaces, using the captured data for remote enforcement (Compl. ¶¶ 100, 127, 133).
  • Asserted Claims: Independent claims 1 and 13 and dependent claims 2-5 and 14-20 are asserted (Compl. ¶375).
  • Accused Features: The infringement allegations target the ARC system's automated processes for monitoring vehicles, determining violations, and issuing notices (Compl. ¶375).

U.S. Patent No. 12,249,187 - "Parking Meter System"

  • Issued: March 11, 2025
  • Technology Synopsis: This patent also shares a specification with the other patents in its family and is directed to solving technical problems associated with traditional parking management. The invention provides a technical solution for gateless parking by using novel combinations of capturing entry/exit image data, transmitting it to a remote computer, and using that data to determine and issue violation notices (Compl. ¶¶ 100, 115).
  • Asserted Claims: Independent claims 1 and 9 and dependent claims 2-5, 10-12 are asserted (Compl. ¶405).
  • Accused Features: The accused features are the ARC system's methods of automated, camera-based parking monitoring and violation enforcement (Compl. ¶405).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is Defendant PRRS’s “Automated Recognition and Compliance System,” referred to as the “ARC” system or service. This includes specific offerings such as “ARC360” and “ARC135” (Compl. ¶¶ 225, 248-251).

Functionality and Market Context

  • The ARC system is alleged to be an automated, gateless parking monitoring and management solution that uses “fixed LPR [license plate recognition]” cameras at facility entrances and exits (Compl. ¶229). The system allegedly operates by automatically capturing images of vehicles, identifying license plates via optical character recognition (OCR), recording entry and exit times in a database, checking for payment confirmation, and automatically issuing violation notices for "operating rules exceptions" (Compl. ¶¶ 233, 235, 240). The complaint includes a workflow diagram from PRRS's website that depicts this process, showing steps from vehicle registration via ALPR to notice issuance (Compl. ¶245). The complaint alleges PRRS provides the ARC system to parking facility operators, including co-defendant LAZ Parking, at numerous locations in Austin, Texas and elsewhere (Compl. ¶¶ 18, 56-57).

IV. Analysis of Infringement Allegations

The complaint does not provide claim chart exhibits, but alleges infringement based on narrative descriptions of the accused ARC system.

10,121,172 Infringement Allegations

Claim Element (from Independent Claim 12) Alleged Infringing Functionality Complaint Citation Patent Citation
a method of monitoring and managing parking in a parking lot having an entrance and an exit, the method comprising: sensing a vehicle entering the parking lot; The ARC system uses cameras at the entrance of a parking lot to monitor incoming traffic. ¶225, 229 col. 22:38-46
capturing image data of the vehicle entering the parking lot; The ARC system’s ALPR cameras capture images of vehicle license plates as they enter. ¶235, 245 col. 23:45-49
transmitting the image data of the vehicle entering the parking lot to a remote networked computer system; Image data is transmitted from on-site cameras to PRRS’s remote enforcement system and database. ¶233, 240 col. 22:42-46
determining an identification of the vehicle entering the parking lot; The ARC system uses OCR to convert license plate images to text, thereby identifying the vehicle. ¶235 col. 23:45-49
sensing the vehicle exiting the parking lot; The ARC system uses cameras at the exit of a parking lot to monitor outgoing traffic. ¶225, 229 col. 22:38-46
capturing image data of the vehicle exiting the parking lot; The ARC system’s ALPR cameras capture images of vehicle license plates as they exit. ¶235, 245 col. 23:45-49
determining that a parking violation has occurred; The system determines a violation has occurred if, for example, a vehicle does not pay within a grace period. A screenshot from a PRRS promotional video describes detecting a violation and performing a DMV look up (Compl. ¶237). ¶238, 240 col. 13:1-12
communicating notice of the parking violation to the remote networked computer system. The ARC system records parking events in a database and the enforcement system generates violation notices based on this data. ¶233, 240 col. 23:62-65

11,257,302 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method of monitoring and managing parking in a parking lot having an entrance and an exit, the method comprising: capturing image data of the vehicle entering the parking lot; The ARC system uses ALPR cameras to capture images of vehicles upon entry. ¶225, 245 col. 22:44-46
transmitting the image data of the vehicle entering the parking lot to a remote networked computer system; The ARC system transmits event data, including images, to a remote database and enforcement system. ¶233, 240 col. 22:42-46
determining an identification of the vehicle entering the parking lot; The ARC system employs OCR technology to convert license plate images into text to identify the vehicle. ¶235 col. 23:45-49
determining that a parking violation has occurred due to a time period expiring without the vehicle exiting the lot prior the time period expiring; The ARC system determines a violation has occurred if a vehicle overstays its time or fails to pay within a grace period before exiting. ¶238, 240 col. 13:1-12
issuing a parking violation notice. The ARC system automatically generates and sends a violation notice to the driver. A PRRS video states it will "send a letter to that person within one to two business days of a violation" (Compl. ¶240). ¶225, 237 col. 23:62-65

Identified Points of Contention

  • Scope Questions: The complaint advances direct infringement theories against PRRS as the system operator, but also includes alternative allegations of joint infringement, suggesting that some steps may be performed by PRRS’s customers, such as LAZ Parking (Compl. ¶¶ 287, 317). A potential point of contention may be whether PRRS "directs or controls" its customers' actions to a degree sufficient to attribute all claim steps to PRRS under a theory of joint infringement.
  • Technical Questions: The asserted claims require "determining that a parking violation has occurred." The complaint alleges the ARC system does this by checking for payment after a grace period or for overstays (Compl. ¶¶ 238, 240). The dispute may raise the question of whether the specific logic and data processing used by the ARC system to identify a "violation" is functionally the same as the methods described and claimed in the patents-in-suit.

V. Key Claim Terms for Construction

  • The Term: "issuing a parking violation notice" (’302 Patent, Claim 1)
  • Context and Importance: This term is central to the final step of the claimed enforcement method. The manner of "issuance" could be a key point of dispute, as the accused ARC system is alleged to "automatically generate[] a notice" which is then "printed and sent to the driver" (Compl. ¶237). Practitioners may focus on this term because its construction will determine whether automated generation alone, or the physical act of mailing, constitutes "issuing" the notice as required by the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discusses "ticketing as required by system software logic without the need for on-premises attendant personnel," which may suggest that the inventive concept lies in the automated decision to ticket, not the physical delivery method (’302 Patent, col. 2:22-25).
    • Evidence for a Narrower Interpretation: The specification also provides a specific example of "issuance of a citation through the mail" after a query to a department of motor vehicles, which could support a narrower construction requiring the step of sending the notice via a postal service (’302 Patent, col. 3:40-42).
  • The Term: "determining an identification of the vehicle" (’172 Patent, Claim 12)
  • Context and Importance: This step is critical for linking a specific vehicle to a parking event. The complaint alleges the accused ARC system performs this by using ALPR and OCR to convert a license plate image to text (Compl. ¶235). The dispute will likely turn on whether this specific technical process meets the claim limitation as understood in the context of the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification refers to this process as "license plate recognition or LPR" and using an "optical character recognition process" to "extract the plate alpha numerals," suggesting the claimed "determination" covers the accused functionality (’172 Patent, col. 5:8-12).
    • Evidence for a Narrower Interpretation: A defendant might argue that the term, when read in light of the full specification, requires a specific level of accuracy or a confirmation step not present in the accused system. However, the specification's explicit mention of LPR and OCR may limit the viability of such an argument.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that PRRS induces infringement by providing its customers, including LAZ Parking, with "ARC Software modules and related documentation" that instruct them on how to operate the accused system in an infringing manner (Compl. ¶¶ 296, 326). It also alleges that LAZ Parking induces infringement by contracting with PRRS for the use of the ARC system at its facilities (Compl. ¶¶ 299, 304).
  • Willful Infringement: The complaint alleges pre-suit knowledge for both Defendants. It alleges LAZ Parking was put on notice of the ’172 Patent during a spring 2022 meeting and was aware of Plaintiff's prior litigation against a competitor (Compl. ¶¶ 262, 266). It alleges PRRS, as a competitor and through its customer LAZ Parking, also knew of the patents and the prior lawsuit before the complaint was filed (Compl. ¶¶ 273, 276-277).

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

  • A core issue will be one of divided infringement: are all steps of the asserted method claims performed by a single entity (PRRS), or is performance split between PRRS and its customers (e.g., LAZ Parking)? The outcome may depend on whether the contractual relationship and operational instructions between PRRS and its customers satisfy the legal standard for attributing the acts of multiple parties to a single defendant.
  • A second key question will be one of definitional scope: does the automated process of the accused ARC system—which involves identifying "operating rules exceptions" and triggering a notice—constitute "determining that a parking violation has occurred" and "issuing a parking violation notice" as those terms are construed in light of the patent specifications?
  • Finally, a central validity question, prompted by the complaint's emphasis on its reexamination success, will be whether the specific combination of gateless entry/exit monitoring and fully automated remote enforcement claimed in the patents represents a patentable advance over prior art that may have included elements of camera monitoring or remote data processing in different contexts.