Background
LBT IP II LLC, a patent assertion entity that acquired patents from Location Based Technologies, Inc., holds U.S. Patent Nos. 7,728,724 and 8,224,355 covering GPS location-tracking innovations. The ‘724 patent claims a method for tracking devices that lack direct line-of-sight to GPS satellites — a common problem in urban environments, tunnels, and dense indoor spaces — by using transmitter/receiver stations to supplement satellite signals. The ‘355 patent claims a user interface for displaying location data from multiple mapping providers without requiring repeated connections to each provider’s servers.
LBT sued Uber in 2022 in the Northern District of California, alleging that Uber’s ride-hailing platform infringes both patents. After discovery, Uber moved for judgment on the pleadings under Rule 12(c), arguing that both patents are directed to abstract ideas and therefore invalid under 35 U.S.C. § 101 and the Alice framework.
The Court’s Holding
Judge Rita F. Lin denied Uber’s motion, holding that both patents are directed to patent-eligible subject matter.
On the ‘724 patent, the court rejected Uber’s framing that the claims merely involved “data gathering, calculations, and result presentation.” Judge Lin found that the claims describe a specific technological solution to the concrete problem of locating devices when GPS satellite coverage is unavailable or imprecise — using terrestrial transmitter infrastructure in a defined way that goes beyond any abstract concept. The court concluded the invention represents “a non-abstract technological solution to a technological problem.”
On the ‘355 patent, the court similarly rejected Uber’s argument that displaying location data from multiple mapping sources is an abstract idea. The claims specify how the interface aggregates data from multiple providers without repeated access requests, which the court found to be a genuine technical improvement in efficiency — not a mere recitation of an abstract concept implemented on generic hardware.
Key Takeaways
- Courts continue to reject § 101 challenges when patent claims are framed around specific technological improvements (here, tracking accuracy and interface efficiency) rather than generic computer-implemented functions.
- The “technological solution to a technological problem” framing — which courts use to distinguish patent-eligible inventions from abstract ideas — benefited LBT here, keeping both GPS patents alive through the pleadings stage.
- Uber faces continued exposure under these location-tracking patents, which cover core functionality of its ride-hailing platform.
- Patent assertion entities holding location-technology portfolios are successfully fending off early § 101 dismissal attempts in some courts, requiring defendants to take their invalidity challenges to claim construction or trial.
Why It Matters
GPS and location-tracking patents sit at the heart of an enormous industry — from ride-hailing and delivery platforms to fleet management, asset tracking, and personal safety devices. When courts reject early § 101 attacks, defendants like Uber face full litigation on infringement and validity grounds, which is expensive and time-consuming. This ruling is a reminder that not all location-technology patents succumb to Alice at the pleadings stage — especially when the claims are carefully drafted to highlight specific technical improvements rather than abstract goals.