Rideshare Displays, Inc. v. LYFT, INC., Cross-Appellant 2023-2033, 2023-2034, 2023-2035, 2023-2036, 2023-2037,…

N OTE: This disposition is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
RIDESHARE DISPLAYS, INC.,
Appellant
JOHN A. SQUIRES, UNDER SECRETARY OF
COMMERCE FOR INTELLECTUAL PROPERTY
AND DIRECTOR OF THE UNITED STATES
PATENT AND TRADEMARK OFFICE,
Intervenor
v.
LYFT, INC.,
Cross-Appellant
______________________
2023-2033, 2023-2034, 2023-2035, 2023-2036, 2023-2037,
2023-2038, 2023-2039
______________________
Appeals from the United States Patent and Trademark
Office, Patent Trial and Appeal Board in Nos. IPR2021-
01598, IPR2021-01599, IPR2021-01600, IPR2021-01601,
IPR2021-01602.
______________________
Decided: September 29, 2025
______________________
MICHELLE D AWSON, Padmanabhan & Dawson PLLC,
Minneapolis, MN, argued for appellant. Also represented
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 2
by D EVAN V. P ADMANABHAN.
K AKOLI CAPRIHAN , Office of the Solicitor, United States
Patent and Trademark Office, Alexandria, VA, argued for
intervenor. Also represented by ROBERT MCBRIDE, AMY J.
N ELSON, F ARHEENA Y ASMEEN RASHEED.
ELIOT D AMON WILLIAMS , Baker Botts LLP, Washing-
ton, DC, argued for cross-appellant. Also represented by
J EREMY T AYLOR, San Francisco, CA; J ENNIFER COZEOLINO
T EMPESTA , MARGARET MCI NERNEY WELSH , New York, NY.
______________________
Before T ARANTO, CHEN, and HUGHES , Circuit Judges.
HUGHES , Circuit Judge.
Rideshare Displays, Inc. appeals five decisions of the
Patent Trial and Appeal Board determining that claims
1–9 and 11–20 of U.S. Patent No. 9,892,637; claims 1, 2, 4,
and 6–8 of U.S. Patent No. 10,169,987; claim 1 of U.S. Pa-
tent No. 10,395,525; claims 1 and 2 of U.S. Patent
No. 10,599,199; and claims 1–5 of U.S. Patent
No. 10,748,417 are unpatentable for obviousness. Lyft, Inc.
cross-appeals the Board’s partial grant of Rideshare’s mo-
tions to amend claims 29, 31, and 32 of the ’637 patent and
claims 1 and 4 of the ’199 patent. For the lead appeal, we
affirm the Board’s holding that all challenged claims are
unpatentable. For the cross-appeal, we reverse the Board’s
partial grant of the motions to amend.
I
A
The challenged patents, U.S. Patent Nos. 9,892,637;
10,169,987; 10,395,525; 10,559,199; and 10,748,417, are all
directed to “a system and method for vehicle identification”
that allows users of ridesharing apps to verify that they are
getting in the correct cars, and for drivers to verify that
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 3
they are picking up the correct riders.1 J.A. 245. The patent
states that the invention’s goal is to address safety con-
cerns for both drivers and riders. J.A. 245
The patents presume that both rider and driver are us-
ing mobile communication devices. J.A. 246. The system
works by having the driver’s device receive a notification
signal that triggers an indicator that is visible from outside
the car. The specification states that the indicator could be
on an article of clothing or on a tablet held by the driver.
The indicator can be a code, like a text or alphanumeric
string, or an icon on a display that allows the rider to locate
the driver and her car. J.A. 246.
Some embodiments involve transmission of a “notifica-
tion signal” to the driver’s device when the driver’s vehicle
reaches a predetermined distance away from the user’s de-
vice. J.A. 247. In response to receiving the notification sig-
nal, the driver’s device generates an indicatory signal.
J.A. 247. The indicatory signal then triggers the display to
show the indicator. J.A. 247. In another embodiment, the
driver’s device generates a second signal representing an
indicator that is transmitted to the user’s mobile device.
J.A. 247.
The below claims are illustrative of the claimed subject
matter.
1. A vehicle identification system, comprising:
a display associated with a vehicle, wherein the
display is located to be visible from an exterior of
the vehicle by a rider;
a controller communicatively coupled to a network
and configured to, in response to receipt of a signal
from a user, generate and transmit a first signal
1 All five patents at issue share a specification, so all
citations are to the ’637 patent specification.
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 4
representing an indicator via the network to a mo-
bile communication device associated with a driver
of the vehicle; and
wherein, in response to receiving the first signal,
the mobile communication device associated with
the driver of the vehicle generates and transmits a
second signal representing the indicator to the dis-
play, the indicator identifies the vehicle.
’987 patent, 7:32–46.
1. A vehicle identification system, comprising:
a display associated with a front windshield of a ve-
hicle, wherein the display is movable so as to be
visible from an exterior of the vehicle by a rider;
a controller communicatively coupled to mobile
communication devices, wherein the controller
generates a first signal representing an indicator
which is transmitted to a mobile communication
device associated with a driver of the vehicle and a
second signal representing the indicator which is
transmitted to a mobile communication device as-
sociated with the rider; and
wherein the mobile communication device associ-
ated with the driver of the vehicle generates a third
signal representing the indicator, which is trans-
mitted to the display, the third signal representing
the indicator identifies the vehicle.
’525 patent, 8:8–23.
1. A vehicle identification system for mobile com-
munication device users, comprising:
a display associated with a vehicle, wherein the
display is located to be visible from an exterior of
the vehicle by mobile communication device users;
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 5
a controller communicatively coupled to a network
and configured to, in response to receipt of a ride
request signal from a mobile communication device
of a user in a pickup area, generate and transmit a
notification signal via the network to a mobile com-
munication device associated with a driver of the
vehicle, and in response to the mobile communica-
tion device associated with the driver of the vehicle
receiving the notification signal an indicatory sig-
nal representing a visual indicator is generated
and transmitted to the display and the mobile com-
munication device of the user, wherein the visual
indicator is not duplicated in the same pickup area.
’417 patent, 7:31–8:13.
B
There are four pieces of prior art relevant to this ap-
peal. The first is U.S. Patent Publication
No. US2012/0137256 (Lalancette). The Lalancette refer-
ence is entitled “Human Readable Iconic Display Server”
and discloses a cross-platform target identification system
for “identify[ing] a target in a target-rich environment.”
J.A. 342. The patent application is directed to a system
that uses icons to provide a “more discreet but publicly vis-
ible means of alerting a target.” J.A. 342. One embodiment
comprises a taxi service where, in response to receiving a
user’s request for the service, the system generates an icon
that is sent to the user and displayed on the taxi’s elec-
tronic roof display to provide confirmation to the user that
they are getting in the right taxi. J.A. 342.
The second is U.S. Patent Publication
No. US2015/0332425 (Kalanick). The Kalanick reference is
entitled “User-Configurable Indication Device for Use with
an On-Demand Service” and discloses a vehicle identifica-
tion system that involves a display either positioned on or
fastened to the vehicle. J.A. 304. The display can output
“color(s), [ ] pattern(s), illumination sequence(s), text,
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 6
visual content, video, and/or audio.” J.A. 304. The user can
specify the configuration for the display or let the system
set a default indicator. J.A. 307. When the system deter-
mines that the driver is arriving at the pickup location, the
system displays the selected configuration. J.A. 307–08.
The third is U.S. Patent No. 9,494,938 (Kemler). The
Kemler reference is entitled “Unique Signaling for Auton-
omous Vehicles To Preserve User Privacy” and discloses
systems and methods to provide a user with a way to iden-
tify and confirm that they are interacting with the correct
requested driverless vehicle. J.A. 317. One contemplated
embodiment involves the vehicle displaying a signal on an
external device that is also provided to the user’s device.
J.A. 329.
The final relevant piece of prior art is U.S. Patent
No. 9,442,888 (Stanfield). The Stanfield reference is enti-
tled “Apparatus And Methods For Renting And Controlling
Occupancy Of A Vehicle” and discloses systems and meth-
ods to determine whether a vehicle is available for rent.
J.A. 1668. One contemplated embodiment involves the ve-
hicle displaying a signal on a visual indicator that shows
that the vehicle is available for rent. J.A. 1677.
C
In November 2021, Lyft filed five petitions for inter
partes review of the challenged patents. The five IPR pro-
ceedings were consolidated for the purposes of this appeal.
The Board found all the challenged claims unpatentable as
obvious or anticipated over the prior art references of
Kalanick, Lalancette, and Kemler, either alone or in com-
bination. J.A. 1–72, 73–119, 120–47, 148–211, 212–39.
In the IPR proceedings involving the ’637 patent and
the ’199 patent, Rideshare moved to amend the claims and
add proposed substitute claims 21–32 for the ’637 patent
and proposed substitute claims 3–4 for the ’199 patent. The
Board allowed substitute claims 29 and 31–32 for the ’637
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 7
patent and claims 3–4 for the ’199 patent and either denied
or did not reach the remaining proposed substitute claims.
J.A. 70–71, 210. The below claims are illustrative of the
substitute claims.
’637 patent, Substitute Claim 29. A method of iden-
tifying a vehicle being dispatched to a location of a
user having requested a ride from a transportation
service, comprising:
when it is determined that the vehicle is within a
predetermined distance of the location of the user,
generating a notification signal to a mobile commu-
nication device associated with the driver;
generating, by creating an indicator, an indicatory
signal representing an the indicator in response to
receiving the notification signal;
displaying, on a display associated with the vehicle,
the indicator based on the notification and indica-
tory signals, the display being located to be visible
on the exterior of the vehicle;
displaying the indicator on a mobile communica-
tion device associated with the user; and
identifying the vehicle based on appearance of a
match, by visual observation of the user, between
the indicator being displayed on the mobile commu-
nication device associated with the user and the in-
dicator being displayed on the display associated
with the vehicle.
J.A. 56–57.
’199 patent, Substitute Claim 3. A vehicle identifi-
cation method implemented as an Application on
mobile communication devices over a wireless com-
munication network, comprising:
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 8
requesting a ride from a transportation service
from a mobile communication device of a user;
determining that a vehicle is within a predeter-
mined distance of the location of the user;
generating a notification signal to a mobile commu-
nication device associated with a driver of the vehi-
cle;
generating, by creating an indicator that is specific
to a user and driver match, an indicatory signal
representing an the indicator;
displaying the indicator based on the notification
signal on a display associated with the vehicle, the
mobile communication device associated with the
driver, and the user’s mobile communication de-
vice, wherein the display associated with the vehi-
cle is located to be visible from the exterior of the
vehicle; and
identifying the vehicle based on appearance of a
match, by visual observation of the user, between
the indicator being displayed on the user’s mobile
communication device and the indicator being dis-
played on the display associated with the vehicle.
J.A. 197.
Rideshare appeals the Board’s unpatentability conclu-
sions for claims 1–9 and 11–20 of the ’637 patent; claims 1,
2, 4, 6–8 of the ’987 patent; claim 1 of the ’525 patent;
claims 1 and 2 of the ’199 patent; and claims 1–5 of the ’417
patent. Lyft cross-appeals the Board’s partial grant of
Rideshare’s motions to amend claims 29, 31, and 32 of the
’637 patent and claims 3 and 4 of the ’199 patent. The U.S.
Patent and Trademark Office intervened in the appeals for
the limited purpose of addressing patent eligibility under
35 U.S.C. § 101. We have jurisdiction under 28 U.S.C.
§ 1295(a)(4)(A).
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 9
II
We review the Board’s legal conclusions de novo and
factual findings for substantial evidence. Almirall, LLC v.
Amneal Pharms. LLC, 28 F.4th 265, 271–72 (Fed. Cir.
2022). Substantial evidence means “such relevant evidence
as a reasonable mind might accept as adequate to support
a conclusion.” In re Gartside, 203 F.3d 1305, 1312
(Fed. Cir. 2000) (citation omitted). We review the Board’s
“claim construction and any supporting determinations
based on intrinsic evidence de novo.” Seabed Geosolutions
(US) Inc. v. Magseis FF LLC, 8 F.4th 1285, 1287 (Fed. Cir.
2021). The factual findings underpinning the use of extrin-
sic evidence are reviewed for substantial evidence. Knowles
Elecs. LLC v. Cirrus Logic, Inc., 883 F.3d 1358, 1362
(Fed. Cir. 2018). Obviousness is a question of law based on
underlying findings of fact. Graham v. John Deere Co.,
383 U.S. 1, 17–18 (1966). “The determination of what a ref-
erence teaches is one of fact, as is the existence of a reason
for a person of ordinary skill to combine references.” In re
Constr. Equip. Co., 665 F.3d 1254, 1255 (Fed. Cir. 2011).
We review the Board’s decision to grant a motion to
amend under the APA and can set aside the Board’s action
if it is “arbitrary, capricious, an abuse of discretion, or oth-
erwise not in accordance with law.” Am. Nat’l Mfg. Inc. v.
Sleep No. Corp., 52 F.4th 1371, 1382–83 (Fed. Cir. 2022)
(quoting 5 U.S.C. § 706(2)(A)). We review the Board’s pa-
tent-eligibility determination de novo. cxLoyalty, Inc. v.
Maritz Holdings Inc., 986 F.3d 1367, 1376 (Fed. Cir. 2021).
“Whether a claim amendment satisfies the written descrip-
tion requirement or improperly adds new matter are both
questions of fact reviewed for substantial evidence.”
Medytox, Inc. v. Galderma S.A., 71 F.4th 990, 996
(Fed. Cir. 2023).
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 10
III
On appeal, Rideshare raises four issues with respect to
the Board’s unpatentability determinations. We address
each in turn.
First, Rideshare contends that the Board erred in its
claim construction of the term “generate” in the claim
phrase “generate a signal representing an indicator.” The
Board construed “generate” to have its plain and ordinary
meaning, “which is to originate or produce the signal.”
J.A. 19. Rideshare argues that the term “generate” needs
to modify both the “signal” and the “indicator/code” because
the signal contains indicator information, such that a new
indicator is created whenever the signal is generated. We
disagree; the Board did not err in its construction. The
plain meaning of the claim, and a proper grammatical con-
struction, is that a signal is generated, and said signal rep-
resents an indicator—not that the indicator is also
generated. We find no error in the Board’s construction of
this claim term. Because we do not adopt Rideshare’s pro-
posed construction of the term, we need not address the ob-
viousness arguments that are predicated on reversing the
Board’s construction. See Appellant’s Opening Br. 28–32.
Second, Rideshare argues that there is not substantial
evidence to support the Board’s determination that La-
lancette discloses a “communication device associated with
the driver of a vehicle.” The Board concluded that La-
lancette discloses a “mobile computer” in a taxi that re-
ceives dispatch information, the signal containing the
rider’s indicator, and displays the icon on the roof-top dis-
play. J.A. 142–43. The Board noted that “mobile computer”
can include a smartphone, and Lalancette does not de-
scribe a specific form that the mobile computer must take.
J.A. 142. Rideshare argues that the “patents[] make clear
that a ‘mobile communication device’ must be both portable
and personal to the driver,” Appellant’s Opening Br. 33,
and that Lalancette does not disclose a system that
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 11
includes a mobile communication device associated with
the driver because Lalancette discloses a taxi service, so
the devices are associated with the taxis, not the drivers.
We disagree. The specification states that examples of mo-
bile communication devices include cell phones, smart
phones, mobile email devices, and digital personal assis-
tants, and nothing in the specification supports limiting
the definition of a mobile communication device in the way
Rideshare suggests. J.A. 246. Moreover, the Board had
substantial evidence in finding that Lalancette’s computer
is “associated with the driver”: the mobile computer con-
nects to a dashboard, which in turn provides the driver
with helpful information. See J.A. 343 ¶ 32. Rideshare
does not resist that understanding of Lalancette, see Appel-
lant’s Br. 47–48, and we see no reason why that disclosed
relation between mobile computer and the driver would fail
to “associate” the mobile computer with the driver. Accord-
ingly, we conclude that substantial evidence supports the
Board’s determination that Lalancette discloses a “commu-
nication device associated with the driver of a vehicle.”
Third, Rideshare argues that there is not substantial
evidence to support the Board’s determination that
Kalanick in combination with Kemler discloses sending a
“[notification] signal . . . when [a] vehicle is within a prede-
termined distance from a specific location.” J.A. 40–41. The
Board relied on expert testimony to conclude that Kalanick
teaches a notification signal being sent from the controller
to user and driver devices, and that the system can deter-
mine if the driver’s position is within a predetermined dis-
tance from the user’s current location. The Board also
found that Kemler teaches sending a notification to a
server when the driver reaches a particular location.
J.A. 42. The Board found that a skilled artisan would have
been motivated to combine the two references to “tie trans-
mission of the first signal to a distance at which the user
would be in range to visually observe and identify the ve-
hicle, thereby resulting in improved accuracy, efficiency,
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 12
and privacy of the user identification system.” J.A. 42.
Rideshare argues that the patent discloses two signals, a
notification signal and a signal that represents an indica-
tor, and that Kalanick and Kemler do not teach a notifica-
tion signal. Yet Kalanick’s system transmits a “first
signal”/“notification signal” too: because the centralized
controller can determine whether the driver arrives at a
predetermined position, it must necessarily exchange a sig-
nal premised on location data, i.e., the first/notification sig-
nal, alongside any other indicatory signals. The
specification of Kemler, moreover, discloses that the cen-
tralized system may send a signal when the vehicle is
within a certain distance from the user, J.A. 330, and the
first signal is referred to as a “notification signal” in the
’637 patent, J.A. 245. This supports the Board’s conclusion
that Kemler, in combination with Kalanick, teaches send-
ing a notification signal when a vehicle is within a prede-
termined distance from a specified location.
Fourth, Rideshare argues that there is not substantial
evidence to support the Board’s determination that the
combination of Kalanick and Kemler discloses the system
“in response to receipt of a signal from the user, generate
and transmit a first signal representing an indicator” be-
cause Kalanick teaches the user sending a signal, and
Kemler teaches a central controller sending a signal repre-
senting the indicator to the driver’s device. J.A. 94–98.
Rideshare argues that Kalanick does not disclose generat-
ing and transmitting a first signal in response to the user,
but instead the signal is transmitted in response to deter-
mining that the user has specified an output configuration
because that is an intermediary step that occurs in the
claim language. Rideshare’s argument supposes that there
must be a direct relationship between the user’s request
and transmitting the signal. We disagree that the claims
require a direct link and exclude a causal chain. We agree
with the Board that the intermediary step does not disrupt
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 13
the causal chain. We conclude that substantial evidence
supports the Board’s conclusion.
We find no reversible error on appeal and affirm the
Board’s conclusions that the challenged claims are un-
patentable.
IV
Lyft’s cross-appeal challenges the Board’s grant of
Rideshare’s motion to amend on three independent
grounds: patent eligibility under 35 U.S.C. § 101, written
description support in the original disclosures, and un-
patentability due to obviousness.
Section 101 provides that a patent may be obtained for
“any new and useful process, machine, manufacture, or
composition of matter, or any new and useful improvement
thereof.” 35 U.S.C. § 101. But “[l]aws of nature, natural
phenomena, and abstract ideas are not patentable.” Alice
Corp. v. CLS Bank Int’l, 573 U.S. 208, 216 (2014) (internal
quotations and citation omitted). In Alice, the Supreme
Court laid out a two-step inquiry to determine whether a
patent is directed to eligible subject matter under § 101.
We first consider “whether the claims at issue are directed
to a patent-ineligible concept.” Id. at 218. If the claims are
directed to a patent-ineligible concept, we then “consider
the elements of each claim both individually and ‘as an or-
dered combination’ to determine whether the additional el-
ements ‘transform the nature of the claim’ into a patent-
eligible application.” Id. at 217 (quoting Mayo Collabora-
tive Servs. v. Prometheus Lab’ys, Inc., 566 U.S. 66, 78–79
(2012)).
The Board concluded that the substitute claims were
directed to an abstract idea, a patent-ineligible concept, un-
der step one of the Alice framework, namely a method of
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 14
organizing human activity.2 J.A. 64–65, 204, 2019, 2042.
But under step two, the Board concluded that the claims
provided a technological solution to a technological prob-
lem in computer and network technologies, which rendered
the claims patent eligible. J.A. 64–66, 204–05.
We disagree with the Board’s conclusion at step two
that the claims are directed to a technological solution.
“[I]mproving a user’s experience while using a computer
application is not, without more, sufficient to render the
claims directed to an improvement in computer functional-
ity.” Simio, LLC v. FlexSim Software Prods., Inc., 983 F.3d
1353, 1361 (Fed. Cir. 2020) (citation omitted). Here, the
claims are directed to improving a user’s experience in us-
ing a ridesharing app and identifying a driver. But nothing
in the claims themselves is directed to an improvement to
the mobile device environment itself—the technological im-
provement more easily enables and facilitates human in-
teractions, but it does not fundamentally alter or improve
the way the technology itself functions. The 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 loca-
tions, such as an airport. “[I]nvoking a computer merely as
2 The Board used the USPTO’s 2019 Revised Patent
Subject Matter Eligibility Guidance and the October 2019
Update, which uses a three-pronged framework. The Guid-
ance is available at: https://www.federalregister.gov/docu-
ments/2019/01/07/2018-28282/2019-revised-patent-subject
-matter-eligibility-guidance; https://www.uspto.gov/sites/
default/files/documents/peg_oct_2019_update.pdf. We de-
cline to adopt this framework, which is not binding on this
Court, and instead evaluate the Board’s decision under our
precedent, which follows the two-step test set out in Alice.
See Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1334
(Fed. Cir. 2016).
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 15
a tool” to “improve a fundamental practice or abstract pro-
cess” does not make an otherwise abstract claim non-ab-
stract. Customedia Techs., LLC v. Dish Network Corp.,
951 F.3d 1359, 1364 (Fed. Cir. 2020). We thus conclude
that the Board’s determination that the substitute claims
were directed to patent-eligible subject matter was legal er-
ror warranting reversal.3
V
We have considered the parties’ remaining arguments
and find them unpersuasive. For the reasons provided
above, we affirm the Board’s determination that claims 1–9
and 11–20 of the ’637 patent, claims 1, 2, 4, and 6–8 of the
’987 patent, claim 1 of the ’525 patent, claims 1 and 2 of the
’199 patent, and claims 1–5 of the ’417 patent are unpatent-
able. Because substitute claims 29, 31, and 32 of the ’637
patent and claims 3 and 4 of the ’199 patent are directed to
patent-ineligible subject matter and lack written
3 Because we conclude that the substitute claims are
not directed to patent eligible subject matter, we may re-
verse the Board’s grant of Rideshare’s motion to amend on
that independent ground. We also conclude that the substi-
tute claims are unsupported by the original disclosure, be-
cause we do not find support for the scenario described in
the substitute claims, where a new indicator is generated
in response to a notification signal when the vehicle is
within a predetermined distance of a particular location.
The original disclosure merely identifies two alternative
scenarios: one where the system generates another indica-
tory signal when the driver approaches a location, and a
second scenario when the driver manually generates an-
other indicator. See J.A. 1809, ¶ 30. For that reason, too,
the Board’s grant of Rideshare’s motion to amend was im-
proper.
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RIDESHARE DISPLAYS, INC. v. LYFT, INC. 16
description support, we reverse the Board’s partial grant of
Rideshare’s motion to amend.
AFFIRMED-IN-PART AND REVERSED-IN-PART
COSTS
Costs to Cross-Appellant.
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