Rideshare Displays v. Lyft (Fed. Cir.) (nonprecedential)

Not a surprise! In today’s Rideshare Displays v. Lyft case (nonprecedential), the Federal Circuit found ineligible under section 101 claims directed to a system for verifying that a ridesharing-app user is getting into the correct car. Below, the PTAB had granted a motion to amend in an IPR. The substitute claims were challenged on appeal on several grounds, including section 101. The Board had found at Alice step one that the claims were directed to an abstract idea: a method of organizing human activity. However, at Alice step two, the Board found the claims recited a technological solution to a technological problem in computer and network technologies, rendering the claims patent eligible. The court disagreed with the Board at step two by relying on Simio’s holding of “improving a user’s experience while using a computer application is not, without more, sufficient to render the claims directed to an improvement in computer functionality.” Simio v. FlexSim (Fed. Cir. 2020). The court held, “[h]ere, the claims are directed to improving a user’s experience in using a ridesharing app and identifying a driver.” The court also stated, “[t]he claims use technology as a tool to streamline the process of what is normally accomplished by creating hand-printed cards with names to help identify ride pickups at crowded locations, such as an airport.” The court concluded with its oft-used maxim, “‘invoking a computer merely as a tool’ to ‘improve a fundamental practice or abstract process’ does not make an otherwise abstract claim non-abstract” (citing Customedia Techs. (Fed. Cir. 2020)) and found the substitute claims unpatentable for reciting ineligible subject matter.