PTAB

IPR2019-00671

Lyft Inc. v. RideApp, Inc.

Title: Automated Ride-Sharing System with Unified Billing
Brief Description: The ’730 patent discloses an automated transportation system that uses wireless communication devices and a central data system to match passengers with vehicles. The system tracks vehicle usage, provides on-demand allocation, and distributes periodic invoices for the aggregated usage, a concept referred to as "unified billing."

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," discloses every limitation of the challenged claims. Behnke's system used a central computer to match ride requests from users at "interactive terminals" with ride offers from drivers. The system automatically charged a user's account and billed the user "periodically for his accumulated charges," meeting the "unified billing" and "periodic invoices" limitations. Behnke also disclosed informing the rider of the vehicle's identity and "estimated time of arrival" (ETA), meeting the limitations of informing the passenger of the assignment (claim 3) and alerting the passenger to the vehicle's proximity (claim 6), as an ETA inherently conveys nearness in time.
- Key Aspects: Petitioner contended that a person of ordinary skill in the art (POSA) reading Behnke's disclosure of providing an ETA would "at once envisage" the claimed concept of detecting and alerting a passenger to the vehicle's proximity.

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 disclose certain notification features, Petitioner argued it would have been obvious to supplement Behnke's ride-matching system with the teachings of Jones. Jones disclosed an "advance notification system" that specifically taught alerting users of a vehicle's impending arrival based on a predefined time, distance, or location point. Jones further taught providing an "update message" if a vehicle is delayed, directly addressing the "updated expected arrival time" limitation of claim 3 and the proximity detection/alerting functions of claim 6.
- Motivation to Combine: A POSA would combine these references to solve the common problem of improving transit convenience and safety. Jones’s advanced notification features (e.g., updates for delays, distance-based alerts) were presented as a known technique to improve a similar system like Behnke's. The combination would enhance the user experience by providing more precise and dynamic arrival information than Behnke's static ETA.
- Expectation of Success: A POSA would have had a reasonable expectation of success because combining the systems involved applying a known notification technique to a compatible ride-dispatching system, using conventional wireless and location-tracking technologies disclosed in both references.

Prior Art Relied Upon: Jaffe (WO 99/44186)
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Jaffe, which disclosed a "request dispatch system" for assigning taxis, anticipated all challenged claims. Jaffe's system featured a control center that wirelessly assigned drivers to users via "portable user terminals" and "operator terminals." The control center included an "accounting module for consolidating financial transactions," where the fare was added as an item to the user's "monthly bill," thus teaching unified and periodic billing. Jaffe explicitly taught sending the user the vehicle's identity and ETA (e.g., "Taxi TLN 313 will pick you up in about 5 minutes"), and used GPS in the terminals to consider the "relative closeness" of users and vehicles during assignment, thereby teaching all elements of claims 2, 3, and 6.
Additional Grounds: Petitioner asserted additional challenges, including that claims 2, 3, and 6 are obvious over Behnke alone or Jaffe alone, if not anticipated. Further obviousness grounds were asserted for claims 3 and 6 over combinations including Jaffe in view of Jones, and Penzias (Patent 5,604,676) in view of Jones, relying on similar motivations to combine advanced notification systems with on-demand transit platforms.

"unified billing": Petitioner argued this term, not defined in the specification, should be construed to mean providing a bill or invoice that aggregates multiple trips of a user into a single bill. This construction was central to mapping the billing features of the prior art.
"periodic": Construed according to its plain meaning as "occurring or recurring at regular intervals," such as a monthly bill. This was supported by examples in the ’730 Patent’s specification.
"proximity": Construed as "nearness in space or time." This interpretation was critical for arguing that prior art disclosing an ETA or relative location inherently taught the proximity limitation of claim 6.
"wireless means of...": Petitioner argued that phrases such as "a wireless means of on-demand allocation" were means-plus-function limitations under 35 U.S.C. §112, ¶ 6. Petitioner identified the claimed functions (e.g., allocation, informing, detecting proximity) and the corresponding structure in the specification as a general-purpose wireless device (e.g., cell phone) executing software with location-tracking capabilities.

Petitioner argued that discretionary denial under §325(d) would be inappropriate because none of the primary prior art references (Behnke, Jaffe, Jones, Penzias) were presented to or considered by the USPTO during the original prosecution of the ’730 patent. Petitioner further distinguished the Jones reference it relied upon from other "Jones References" that were mentioned but not substantively analyzed by the Examiner during prosecution.

Petitioner requests institution of an inter partes review and cancellation of claims 2, 3, and 6 of the ’730 patent as unpatentable.