Thanks for Your Input: Federal Circuit Ignores USPTO’s §101 Framework (Again)
Patent – Patently-O 2025-09-29
Summary:
by Dennis Crouch
In Rideshare Displays, Inc. v. Lyft, Inc., No. 2023-2033 (Fed. Cir. Sept. 29, 2025) (nonprecedential), the Federal Circuit affirmed the PTAB determination that claims directed to vehicle identification systems for ridesharing services were unpatentable for obviousness, but reversed the Board’s grant of Rideshare’s motion to amend substitute claims. Judge Hughes, writing for the panel, held that the substitute claims were directed to patent-ineligible subject matter under 35 U.S.C. § 101 because they merely used technology as a tool to improve user experience rather than improving computer functionality itself.
The patents at issue all share a common specification directed to systems and methods for vehicle identification that allow ridesharing app users to verify they are getting in the correct cars and drivers to confirm they are picking up the correct riders. U.S. Patent Nos. 9,892,637; 10,169,987; 10,395,525; 10,559,199; and 10,748,417. The systems work by having a driver’s device receive a notification signal that triggers an indicator visible from outside the car, such as a code or icon on a display. Lyft filed five petitions for inter partes review in November 2021, and the Board found all challenged claims unpatentable as obvious or anticipated over the prior art.