PTAB

IPR2019-00671

Lyft Inc v. RideApp Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Automated System for Providing Unified Billing for Passenger Transport
  • Brief Description: The ’730 patent describes an automated ride-sharing system that uses wireless communication devices for passengers and vehicles to connect with a central data system. The system facilitates on-demand matching of passengers to vehicles, provides trip information, tracks vehicle usage, and handles aggregated billing for transport services.

3. Grounds for Unpatentability

Ground 1: Anticipation by Behnke - Claims 2, 3, and 6 are anticipated by Behnke.

  • Prior Art Relied Upon: Behnke (Patent 4,360,875).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Behnke, which teaches a "flexible-route transportation system," disclosed every limitation of the challenged claims. Behnke’s "central coordinating station computer" was argued to be the claimed "central data system" that tracks usage and "bills the rider periodically for his accumulated charges," meeting the unified and periodic billing limitations. Behnke’s wireless "interactive terminals" used by riders and drivers allegedly meet the "plurality of communication devices" for wireless communication. Finally, Petitioner asserted that Behnke's system, which performs "trip-by-trip demand-responsive matching" and notifies the rider of the vehicle's identity and "estimated time of arrival," anticipates the "wireless means of" on-demand allocation, passenger notification, and proximity detection.

Ground 2: Anticipation by Jaffe - Claims 2, 3, and 6 are anticipated by Jaffe.

  • Prior Art Relied Upon: Jaffe (WO 99/44186).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Jaffe, which discloses a request dispatch system for assigning taxis, anticipates all challenged claims. Jaffe's control center, with its "accounting module for consolidating financial transactions," was alleged to meet the "unified billing" limitation, as it adds fares to a user's "monthly bill." This central system also tracks usage and provides "periodically debited" invoices. The system's "portable user terminals" and "operator terminals" that communicate wirelessly with the control center were mapped to the claimed communication devices. Petitioner argued Jaffe's control center, which assigns available taxis to users on-demand and sends assignment confirmation with an estimated time of arrival, discloses the "wireless means of" allocation and passenger notification. The system's use of GPS to consider the "relative closeness of users to available vehicles" was argued to meet the proximity detection limitation.

Ground 3: Obviousness over Behnke and Jones - Claims 3 and 6 are obvious over Behnke in view of Jones.

  • Prior Art Relied Upon: Behnke (Patent 4,360,875) and Jones (WO 98/40837).

  • Core Argument for this Ground:

    • Prior Art Mapping: To the extent Behnke was found not to teach the notification and proximity detection limitations of claims 3 and 6, Petitioner argued they would have been obvious by combining Behnke with Jones. Jones teaches an "advance notification system" that notifies users of a vehicle's impending arrival based on predefined time, distance, or location triggers, and provides "update messages" for delays. Petitioner asserted a POSITA would have incorporated Jones's more advanced notification features into Behnke's ride-sharing system.
    • Motivation to Combine: A POSITA would combine these references to solve the common problem of improving transit safety and efficiency. Integrating Jones’s specific arrival alerts (e.g., notifying when a vehicle is a certain distance away) into Behnke’s system, which already provided a basic ETA, was presented as a predictable solution to enhance the user experience.
    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success because combining the systems involved applying a known technique (advanced user alerts) to a similar system (a ride dispatch service). The references themselves demonstrate the compatibility of the technologies, as both operate in the transportation domain using wireless communication and location data.

  • Additional Grounds: Petitioner asserted additional challenges including: obviousness of claims 2, 3, and 6 over Behnke alone and Jaffe alone; obviousness of claims 3 and 6 over Jaffe in view of Jones; and obviousness of claims 3 and 6 over Penzias in view of Jones. These grounds relied on similar arguments regarding the common knowledge of a POSITA and motivations to improve system efficiency and safety.

4. Key Claim Construction Positions

  • "unified billing": Petitioner proposed this term, which is not defined in the specification, should be construed to mean "providing a bill or invoice that aggregates multiple trips of a user into one bill." This construction was argued to be supported by the specification's description of a "utility style billing" system that "aggregates all the trips of a user in one bill statement."
  • "wireless means of": Petitioner argued that claim limitations beginning with "a wireless means of" are means-plus-function limitations under §112, ¶ 6. The claimed functions include on-demand allocation, informing the passenger of assignment/ETA, and detecting/alerting proximity. Petitioner contended the corresponding structure disclosed in the specification is a generic wireless communication device (e.g., a cellular phone or PDA) executing software that utilizes location functions (e.g., GPS or cellular triangulation) known to those skilled in the art.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 2, 3, and 6 of Patent 6,697,730 as unpatentable.