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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

Quartz Auto Technologies LLC

Plaintiff,

v.

Lyft, Inc. 

Defendant.

Civil Action No. 6:20-cv-00156

The Honorable ________________________

COMPLAINT FOR PATENT 

INFRINGEMENT

JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT AND DEMAND FOR JURY TRIAL

TO THE HONORABLE JUDGE OF SAID COURT:

Plaintiff Quartz Auto Technologies LLC (“Quartz Auto”), files this Complaint for Patent 

Infringement and Damages against Defendant Lyft, Inc. (“Lyft” or “Defendant”), and would 

respectfully show the Court as follows:

PARTIES

1. Plaintiff Quartz Auto is a Delaware limited liability company with its principal 

place of business located at 301 S. Fremont Ave, Baltimore, MD 21230.

2. On information and belief, Defendant Lyft is a Delaware corporation with its 

principal place of business located at 185 Berry Street, Suite 5000, San Francisco, CA 94107. Lyft

is registered to conduct business in Texas, and may be served through its registered agent, The 

Corporation Trust Company, located at 1999 Bryan St., Suite 900, Dallas TX 75201-3136.

JURISDICTION AND VENUE

3. This is a civil action for patent infringement arising under the Patent Laws of the 

United States as set forth in 35 U.S.C. §§ 271, et seq.

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4. This Court has federal subject matter jurisdiction over this action pursuant to 28 

U.S.C. §§ 1331 and 1338(a) and pendant jurisdiction over the other claims for relief asserted 

herein. 

5. This Court has personal jurisdiction over Defendant pursuant to TEX. CIV. PRAC. &

REM. CODE § 17.041 et seq. Personal jurisdiction exists over Defendant because Defendant has

minimum contacts with this forum as a result of business regularly conducted within the State of 

Texas and within this district, and, on information and belief, specifically as a result of, at least, 

committing the tort of patent infringement within Texas and this district. Personal jurisdiction also 

exists because, on information and belief, Defendant has: (1) operated the Internet website,

https://www.lyft.com/, and provided a mobile application (the “Lyft app”), which is available to 

and accessed by ridesharing users, customers, and potential customers of the Defendant, both 

riders and drivers, within this judicial district; (2) operated within the judicial district, with 

ridesharing offered to users, customers, and potential customers of Defendant in locations 

including Austin, El Paso, San Antonio, and Waco; (3) actively advertised to residents within the 

District to hire more drivers; (4) transacted business within the State of Texas; (5) actively 

infringed and/or induced infringement of Plaintiff’s patents in Texas; (6) established regular and 

systematic business contacts within the State of Texas; and (7) continue to conduct such business 

in Texas through the continued operation within the district. Accordingly, this Court’s jurisdiction 

over the Defendant comports with the constitutional standards of fair play and substantial justice 

and arises directly from the Defendant’s purposeful minimum contacts with the State of Texas.

6. This Court also has personal jurisdiction over Defendant, because in addition to 

Defendant’s own online website and advertising within this judicial district, Defendant has also 

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made its ridesharing services available specifically within this judicial district via the following 

means:

a. Defendant offers ridesharing within the judicial district, in locations 

including:

- Austin (https://www.lyft.com/rider/cities/austin-tx), 

- El Paso (https://www.lyft.com/rider/cities/el-paso-tx), 

- San Antonio (https://www.lyft.com/rider/cities/san-antonio-tx), and

- Waco (https://www.lyft.com/rider/cities/waco-killeen-tx).

b. Defendant actively advertises to district residents to hire more drivers 

within the district. For example:

- Austin (https://www.lyft.com/driver/cities/austin-tx), and 

- Waco (https://www.lyft.com/driver/cities/waco-killeen-tx).

c. Defendant actively promotes working for Lyft to all, including district 

residents, who have downloaded the Lyft passenger application, as “Drive with Lyft” is 

listed in the application drop down menu, and incentivizes new drivers with guaranteed 

money dependent on “X” number of drives in first 30 days (guaranteed money amount and 

number of drives depends on location).

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Lyft Passenger Application Screenshots February 16, 2020

d. Defendant provides in-person support via “Driver Hubs” within the Western 

District of Texas, including a driver center in Austin (6375 US-290, Austin, TX 78723) and 

both a service desk and airport service desk in San Antonio 

(https://thehub.lyft.com/hours/texas).

7. Defendant is subject to this Court’s specific and general personal jurisdiction 

pursuant to due process and/or the Texas Long Arm Statute, due at least to Defendant’s substantial 

business in this forum, including: (i) at least a portion of the infringements alleged herein; and/or 

(ii) regularly doing or soliciting business, engaging in other persistent courses of conduct, and/or 

deriving substantial revenue from goods and services provided to individuals in Texas and in this 

district.

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8. Venue is proper in this Court under 28 U.S.C. §§ 1391(b) and (c) and 28 U.S.C. 

§ 1400(b) based on the information and belief that the Defendant has committed or induced acts 

of infringement, and/or advertise, market, sell, and/or offer to sell products, including infringing 

products, in this judicial district. In addition, Defendant maintains numerous regular and 

established places of business in this district by providing its ridesharing service in this district in, 

for example, Waco, Texas. In addition, Defendant maintains regular and established places of 

business in this district, as discussed in ¶6(d).

THE PATENTS-IN-SUIT

9. On September 3, 2002, United States Patent No. 6,446,004 (“the ‘004 patent”), 

entitled “System and Method for Implementing Proximity or Location Driven Activities” was duly 

and legally issued by the United States Patent and Trademark Office (“USPTO”) to Kevin Tung 

Cao, Daniel Alexander Ford, and Reiner Kraft, with the International Business Machines 

Corporation (“IBM”) as assignee. A copy of the ‘004 patent is attached hereto as Exhibit A.

10. On October 19, 2004, United States Patent No. 6,807,464 (“the ‘464 patent”), 

entitled “Systems and Methods for Distributing Information to an Operator of a Vehicle” was duly 

and legally issued by the USPTO to Philip Shi-lung Yu, David P. Greene, Edith H. Stern, and Barry 

E. Willner, with IBM as assignee. A copy of the ‘464 patent is attached hereto as Exhibit B. 

11. On May 6, 2008, United States Patent No. 7,370,085 (“the ‘085 patent”), entitled 

“Method, System, and Program for Providing User Location Information with a Personal 

Information Management Program” was duly and legally issued by the USPTO to Michael Wayne 

Brown, Rabindranath Dutta, and Michael A. Paolini, with IBM as assignee. A copy of the ‘085 

patent is attached hereto as Exhibit C.

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12. On June 7, 2011, United States Patent No. 7,958,215 (“the ‘215 patent”), entitled 

“System Management Using Real Time Collaboration” was duly and legally issued by the USPTO 

to David Gerard Herbeck and Susette Marie Townsend, with IBM as assignee. A copy of the ‘215

patent is attached hereto as Exhibit D.

13. On October 4, 2016, United States Patent No. 9,460,616 (“the ‘616 patent”), 

entitled “Management of Mobile Objects and Service Platform for Mobile Objects” was duly and 

legally issued by the USPTO to Tomohiro Miyahira and Gaku Yamamoto, with IBM as assignee. 

A copy of the ‘616 patent is attached hereto as Exhibit E. 

14. The ‘004, ‘464, ‘085, ‘215, and ‘616 patents are referred to hereinafter as the 

“Quartz Auto Patents.”

15. Plaintiff Quartz Auto Technologies LLC is the owner of the entire right, title, and 

interest in and to the Quartz Auto Patents. The Quartz Auto Patents were originally owned by and 

assigned to IBM, and through predecessors in interest that were duly recorded in the U.S. Patent 

Office, were ultimately assigned to Quartz Auto on or about February 13, 2020 and February 14, 

2020, and recorded in the Patent Office, with all right, title, and interest in and to the Patents to 

Quartz Auto. Each of the Quartz Auto Patents are presumed valid under 35 U.S.C. § 282.

United States Patent No. 6,446,004

16. The ‘004 patent claims a system and associated method for implementing a 

proximity driven activity. In one embodiment, the system and an associated method of the ‘004 

patent allow requests to be executed at some point in the future without specifying the exact time 

or necessarily a precise location. The execution time of the request is linked to the arrival of a 

person at, or near a geographic location or destination. When a person arrives at that location, or 

comes within a proximity threshold distance of that location, the request to interact will be

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executed. The proximity threshold “can be adjustable and programmable” (col. 2, lines 6-7). A 

“mobile computing device” may be, for example, a personal computer, a personal digital assistant, 

and preferably possesses a wireless means of communication. In the present complaint, 

Defendant’s ride-hailing system and method infringe on these inventive aspects of the ‘004 patent 

by, for example, using both passenger and driver applications that input, collect, and transmit such 

proximity driven activity between the passenger and the driver, and vice versa. Here, the Lyft

applications, installed and used on mobile computing devices (most often wireless mobile phones), 

collect a passenger’s current location and inputted destination and executes software code to 

determine which driver is within the proximity threshold to complete the passenger’s request. The 

passenger’s current location and inputted destination is then transmitted through the Lyft

application to the driver’s mobile device.

17. The ‘004 patent overcomes shortcomings in the prior art, which were ineffective at 

integrating location positioning (col. 1, lines 36-40) into functional applications in the everadvancing areas of GPS and mobile computing. Certain of the inventive aspects of the ‘004 patent 

addressed the need for improvements in the area of location dependent data processing, by 

developing software for use with a mobile computing device combined with a global positioning 

system locator (col. 1, lines 16-24). More specifically, the inventive aspects of executing an activity 

linked to the arrival of a person at or near a geographic location or destination, which is dependent 

on a mobile computing device and the calculated current location and destination of the mobile 

device (col. 1, lines 61-67), were not well-understood, routine, or conventional at the time of the 

invention.

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United States Patent No. 6,807,464

18. In one embodiment, the ‘464 patent claims a method and associated system of 

distributing vehicle control information by determining, at a controller location, the vehicle control 

information associated with the location of the vehicle and vehicle operator, and then arranging 

the information to provide an indication to the vehicle operator. Such “vehicle control 

information” may refer to any information that can be used by an operator with respect to a vehicle, 

and may be provided to the operator, for example, via text information, image information, audio 

information, dashboard information, and/or HUD information. In the present complaint, 

Defendant’s ride-hailing system and method infringe on these inventive aspects of the ‘464 patent

by, for example, using both passenger and driver applications that communicate such vehicle 

control information between the passenger and the driver, and vice versa. Here, the Lyft passenger 

application serves as the controller, while the Lyft driver application serves as the operator, and 

the requisite information is provided by text, image, and audio, as needed. 

19. The ‘464 patent overcomes shortcomings in the prior art, which required 

information be presented through traditional signage and traffic signals placed along roads (col. 1, 

lines 20-21). The prior art is not an effective means to disseminate all kinds of information (col. 1, 

lines 39-46). Certain of the inventive aspects of the ‘464 patent addressed the need for 

improvements in the area of distributing information to the operator of a vehicle, by better 

facilitating the dissemination of information via a vehicle device (col. 2, lines 1-5). More 

specifically, the inventive aspects of collecting vehicle control information and distributing the

information to the individual vehicle device for a plurality of vehicles (col. 13, lines 55-67), were 

not well-understood, routine, or conventional at the time of the invention. 

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United States Patent No. 7,370,085

20. The ‘085 patent claims a method for providing user location information for a 

personal information management (PIM) program by generating position coordinates of a wireless 

device with related time information. Additionally, the ‘085 patent claims another method for 

generating a calendar for a PIM program by receiving a time interval and determining position 

coordinates of a wireless device in order to display a user’s activity with the corresponding time.

In one embodiment, the ‘085 patent then determines whether a rate of change in distance between 

position coordinates at designated times indicates a user’s activity during the activity time period, 

and then generates information on the predefined activity. A PIM client gathers and presents PIM 

information, such as calendaring and scheduling information, in accordance with the described 

implementations. A PIM refers to a program designed to allow users to organize random bits of 

information in a useful format (col. 4, lines 27-33). In the present complaint, Defendant’s ridehailing system and method infringe on these inventive aspects of the ‘085 patent. For example,

Defendant’s use of geographical reference data to depict various drivers in the vicinity of a 

potential passenger on its Lyft application fits one definition of gathering and presenting 

information on a PIM. 

21. The ‘085 patent overcomes shortcoming in the prior art, which provided users of 

wireless computing (such as personal information managers) or handheld computers (such as 

cellular phones) significantly limited versions of programs and functions normally available on 

desktop computers (col. 1, lines 56-61). Certain of the inventive aspects of the ‘085 patent 

addressed the need for an application that could more fully exploit wireless computing technology 

and extend the utility beyond that of a portable telephone and limited personal information 

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manager (col. 2, lines 5-10). These aspects were not well-understood, routine, or conventional at 

the time of the invention. 

United States Patent No. 7,958,215

22. The ‘215 patent claims a number of computer-implemented embodiments for 

responding to a condition/alert (for example, needing a ride) and managing an information 

technology device. 

a. Claim 1 of the ‘215 patent claims a method for responding to a problem condition, 

which automatically detects the availability of the first candidate to respond to the problem 

condition, responds to the detection, automatically assigns to the first candidate the responsibility 

for the problem condition, and then receives confirmation that the candidate has accepted 

responsibility.

b. Claim 5 of the ‘215 patent claims a method for managing an information technology 

device, which receives an alert from a device and receives availability information of a plurality 

of candidates, automatically selects a qualified and available candidate to take responsibility for 

the alert, and then receives a reply from the candidate indicating acceptance of responsibility. 

c. Claim 14 of the ‘215 patent claims a method for managing an information 

technology device, which receives an alert from the device, automatically selects a qualified 

candidate and determines candidates’ availability to respond to the alert, automatically sends an 

instant message to the candidate containing information about the alert, receives a reply from the 

candidate indicating acceptance of responsibility, and then automatically assigns responsibility for 

the alert to the candidate.

d. Claim 17 of the ‘215 patent claims a method for assigning responsibility for 

responding to a condition in an information technology device, which receives an alert from a 

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monitored device describing an event in the device, automatically detects an available 

administrator qualified to respond to the event, automatically sends a first instant message to the 

available administrator that references the alert and requests acknowledgment, receives a second 

instant message from the administrator acknowledging the event, and then automatically assigns 

responsibility for the event to the administrator.

In particular, the ‘215 patent relates to management methods and systems using real-time 

collaboration and instant messaging technology (col. 1, lines 5-10). In the present complaint, 

Defendant’s ride-hailing system and method infringe on these inventive aspects of the ‘215 patent. 

For example, Defendant monitors alerts/conditions (ride requests) from passengers through the 

Lyft Application (on a device) and automatically determines the availability of a plurality of 

drivers (candidates/administrators) to respond to the passenger’s request. Once driver location,

availability, and qualification (for example, possession of driver’s license; vehicle type; vehicle 

make; vehicle year; passenger rating; driver rating; driver acceptance rating; driver coverage areas;

etc.) are determined, the drivers are automatically notified via their Lyft Applications. The drivers 

respond, and then one driver is automatically assigned to handle the passenger’s alert. The Lyft

Applications (passenger application to Lyft server to driver application, and vice versa), use realtime collaboration and messaging technology to manage alerts and assignments of responsibility.

23. The ‘215 patent overcomes shortcomings in the prior art, which failed to properly 

ensure responses to alerts and conditions in a cost effective and timely fashion (col. 1, lines 24-

62). Certain of the inventive aspects of the ‘215 patent address the need for ensuring and assigning 

real time responses to alerts and conditions from qualified and available candidates (col.1, lines 

65-67, col. 2, lines 1-62). Such method and aspects were not well-understood, routine, or 

conventional at the time of the invention. 

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United States Patent No. 9,460,616

24. In one embodiment, the ‘616 patent claims a system comprising a mobile object 

server that receives information from a plurality of mobile objects within a geographic space and 

performs a process associated with each mobile object. A notification is provided if one mobile 

object has become distanced from a predetermined location or region. The mobile objects may be 

manned/unmanned automobiles, motorbikes, bicycles, humans having a digital device, airplanes, 

vessels, drones, or the like (col. 2, lines 41-43). In the present complaint, Defendant’s ride-hailing 

system and method infringe on these inventive aspects of the ‘616 patent. For example, Defendant 

monitors its drivers (mobile objects) via its central servers (mobile object server), with each of the 

plurality of drivers in a geographic area providing information which is received at the Defendant’s 

servers. Such information from the drivers may include information about accidents, obstructions, 

closures, limitation statuses, or construction on the road. Defendant’s servers monitor the 

progress/location of the driver, and perform a process of updating the navigation information 

provided to the driver via the Lyft Navigation, Google Maps, or Waze navigation applications, 

with updated estimated times of arrival based on the speed, current traffic, and other considerations 

encountered by the Lyft driver. 

25. The ‘616 patent overcomes shortcomings in the prior art, which failed to account 

for the inherent problem that as the geographic space being handled expands, the number of 

automobiles and the number of roads increases, thereby increasing the amount of information 

being sent and received to a level that surpasses the processing capabilities of the server, nor allows 

different information and services to be provided to each automobile and driver in real time (col. 

1, lines 17-25). Certain of the inventive aspects of the ‘616 patent addressed the need for 

improvements in managing the geographic space and mobile objects within the geographic space

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(col. 27, lines 49-52). These aspects were not well-understood, routine, or conventional at the time 

of the invention. 

The Lyft Application

26. On information and belief, Defendant uses the Lyft network/server in combination

with the Lyft rider/passenger application and the Lyft driver application to operate ride-hailing 

services. For the purposes of this complaint, the term “Lyft app” encompasses all such 

functionalities and any related Lyft technologies, either commercially available or developed 

functionally by Lyft.

a. On information and belief, Lyft operates a network/server infrastructure with its 

riders/passengers and drivers.

b. On information and belief, Lyft operates and provides a Rider application that, 

among other things, allows Lyft passengers/customers to request a ride. For the purposes of this 

complaint, passenger application/app and rider application/app, as well as any different, 

unambiguous iterations, are used interchangeably.

c. On information and belief, Lyft operates and provides a Driver application that, 

among other things, allows Lyft drivers to accept ride requests and perform related activities. For 

the purposes of this complaint, driver application/app and any different, unambiguous iterations, 

are used interchangeably.

COUNT I

PATENT INFRINGEMENT OF THE ‘004 PATENT

27. Plaintiff Quartz Auto repeats and realleges the above paragraphs, which are 

incorporated by reference as if fully restated herein.

28. Plaintiff Quartz Auto is the owner of all rights, title, and interest in the ‘004 patent.

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29. Plaintiff Quartz Auto and its predecessors in interest have never licensed to the 

Defendant under the ‘004 patent, nor has Plaintiff Quartz Auto otherwise authorized the Defendant 

to practice any part of the ‘004 patent.

30. The ‘004 patent is presumed valid under 35 U.S.C. §282.

31. The ‘004 patent relates to, among other things, a system and method for 

implementing proximity or location driven activities. 

32. On information and belief, Defendant operates a ride-hailing service that uses a 

passenger and driver application that collects current location and destination in order to execute 

a proximity-driven activity.

33. Direct Infringement: On information and belief, Defendant has directly infringed 

and continues to directly infringe, either literally or under the doctrine of equivalents, one or more 

claims of the ‘004 patent, including for example (but not limited to) at least method claims 1-11, 

system claims 12-22, and computer program claims 23-33 of the ‘004 patent by making, using,

distributing, providing, supplying, selling, offering to sell without license or authority Defendant’s 

application that include infringing features. The infringing products include applications that can 

be used on a variety of mobile computing devices and gather and transmit location-specific 

information. A detailed infringement claim mapping is provided in paragraphs 37-44 and 

paragraphs 45-49 below.

34. Induced Infringement: On information and belief, Defendant has and continues 

to promote, advertise, and instruct current drivers and riders, and potential drivers and riders about 

Lyft products, such as: 

(i) Providing Defendant’s downloadable applications for Rider 

(https://www.lyft.com/rider) and Driver (https://www.lyft.com/driver); 

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(ii) Providing an overview of how to use Lyft’s branded products 

(https://www.lyftbusiness.com), including instructions for riders to use the services 

(https://help.lyft.com/hc/en-us/categories/115002006488-Riding-with-Lyft); and 

(iii) Providing requirements for drivers to sign-up for the service 

(https://help.lyft.com/hc/en-us/categories/115002009967-Driving-with-Lyft). 

Defendant’s promotion, advertising, and instruction efforts include, at a minimum, maintenance 

of its own website http://www.lyft.com/, providing additional driver application requirements and 

Frequently Asked Questions (FAQs), and other indicia of Lyft branded products 

(https://www.lyft.com/driver-application-requirements). Defendant’s software applications 

require both the rider and the driver to download the software applications for mobile computing 

devices, such as smartphones, laptops, and tablets, which enables Lyft to control the actions of 

both the riders and the drivers to use the infringing features of the products and methods for ridehailing. On information and belief, Defendant continues to engage in these acts with knowledge 

of the ‘004 patent by the filing of this Complaint, and with the actual intent to cause the acts which 

it knew or should have known would induce actual infringement.

35. Defendant Lyft has infringed the ‘004 patent by making, having made, using, 

importing, providing, supplying, distributing, selling, or offering for sale systems utilizing a 

method for implementing proximity driven activities. 

36. Detailed Mapping of Direct Infringement: On information and belief, 

infringement of the ‘004 patent by these Lyft ride-hailing products and applications is 

demonstrated below. 

37. Method claim 1 of the alleged claims:

1. A method of implementing a proximity driven activity, comprising:

specifying an activity to be executed at an indeterminate destination location;

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storing an executable software code corresponding to the activity;

determining a current location of a mobile computing device;

determining whether the destination location is within a predefined proximity range 

from the current location of the mobile computing device;

executing the executable software code at a time when the destination location is 

within the proximity range of the mobile computing device; and

transmitting an address of the destination location to the mobile computing device.

38. On information and belief, the Lyft application or Lyft Network, which includes the 

passenger application, driver application, Lyft server, and all related technology (hereinafter, “Lyft

App”) performs a method of implementing a proximity driven activity.

https://www.youtube.com/watch?v=a8n2--HlzDU

https://www.lyft.com/driver

https://www.Lyft.com/newsroom/semi-automated-science-using-an-ai-simulationframework/

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39. On information and belief, the Lyft App specifies an activity to be executed at an 

indeterminate destination location.

https://www.youtube.com/watch?v=a8n2--HlzDU

40. On information and belief, the Lyft App stores an executable software code 

corresponding to the activity.

https://www.youtube.com/watch?v=a8n2--HlzDU

https://help.lyft.com/hc/en-us/articles/115013080028#app

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41. On information and belief, the Lyft App determines a current location of a mobile 

computing device.

https://www.youtube.com/watch?v=a8n2--HlzDU

42. On information and belief, the Lyft App determines whether the destination location 

is within a predefined proximity range from the current location of the mobile computing device. 

https://www.youtube.com/watch?v=a8n2--HlzDU

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https://www.Lyft.com/newsroom/semi-automated-science-using-an-ai-simulationframework/

https://www.lyft.com/developers/products/ride-request

43. On information and belief, the Lyft App executes the executable software code at a 

time when the destination location is within the proximity range of the mobile computing device.

https://www.youtube.com/watch?v=a8n2--HlzDU

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Lyft Passenger Application Screenshot February 25, 2020

44. On information and belief, the Lyft App transmits an address of the destination 

location to the mobile computing device.

https://www.youtube.com/watch?v=a8n2--HlzDU

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Lyft Driver Application Screenshot February 25, 2020

45. System claim 12 of the alleged claims is provided below (and system claim 12 is 

also taken as representative of breadth of computer program product claim 23):

12. A system for implementing a proximity driven activity, comprising:

a calendar module for specifying an activity to be executed at an indeterminate 

destination location;

a server for storing an executable software code corresponding to the activity and 

for determining a current location of a mobile computing device; and

the server determining whether the destination location is within a predefined 

proximity range from the current location of the mobile computing device, and, when the 

server determines that the destination location is within the proximity range of the mobile 

computing device, the server executes the executable software code, and transmits an 

address of the destination location to the mobile computing device.

46. On information and belief, the Lyft application or Lyft Network, which includes the 

passenger application, driver application, Lyft server, and all related technology (hereinafter, “Lyft

App”) performs a system of implementing a proximity driven activity.

https://www.youtube.com/watch?v=a8n2--HlzDU

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https://www.lyft.com/driver

https://www.Lyft.com/newsroom/semi-automated-science-using-an-ai-simulationframework/

47. On information and belief, the Lyft App uses a calendar module for specifying an 

activity to be executed at an indeterminate destination location.

Lyft Driver Application Screenshot February 25, 2020

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Lyft Driver Application Screenshot February 25, 2020

Lyft Driver Application Screenshot February 25, 2020

48. On information and belief, the Lyft App uses a server for storing an executable 

software code corresponding to the activity and for determining a current location of a mobile 

computing device.

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https://help.lyft.com/hc/en-us/articles/115013080028#app

https://www.youtube.com/watch?v=a8n2--HlzDU

49. On information and belief, the Lyft App server determines whether the destination 

location is within a predefined proximity range from the current location of the mobile computing 

device, and, when the server determines that the destination location is within the proximity range 

of the mobile computing device, the server executes the executable software code, and transmits 

an address of the destination location to the mobile computing device.

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https://www.youtube.com/watch?v=a8n2--HlzDU

https://www.Lyft.com/newsroom/semi-automated-science-using-an-ai-simulationframework/

https://www.youtube.com/watch?v=a8n2--HlzDU

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Lyft Driver Application Screenshot February 25, 2020

50. On information and belief, Defendant’s actions have and continue to constitute 

active inducing infringement of at least method claims 1-11, system claims 12-22, and computer 

program claims 23-33 of the ‘004 patent in violation of 35 U.S.C. §271(b). 

51. As a result of Defendant’s infringement of at least method claims 1-11, system 

claims 12-22, and computer program claims 23-33 of the ‘004 patent, Plaintiff Quartz Auto has 

suffered monetary damages in an amount yet to be determined, and will continue to suffer damages 

in the future unless Defendant’s infringing activities are enjoined by this Court. Defendant is liable 

to Plaintiff in an amount that adequately compensates for such infringements, which, by law, 

cannot be less than a reasonable royalty, together with interest and costs as fixed by this Court 

under 35 U.S.C. § 284. 

52. Defendant’s wrongful acts have damaged and will continue to damage Plaintiff 

Quartz Auto irreparably, and Plaintiff has no adequate remedy at law for those wrongs and injuries. 

In addition to its actual damages, Plaintiff Quartz Auto is entitled to a permanent injunction 

restraining and enjoining Defendant and its agents, servants, and employees, and all persons acting 

thereunder, in concert with, or on its behalf, from infringing at least method claims 1-11, system 

claims 12-22, and computer program claims 23-33 of the ‘004 patent. 

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 26 of 83
27

COUNT II

PATENT INFRINGEMENT OF THE ‘464 PATENT

53. Plaintiff Quartz Auto repeats and realleges the above paragraphs, which are 

incorporated by reference as if fully restated herein.

54. Plaintiff Quartz Auto is the owner of all rights, title, and interest in the ‘464 patent.

55. Plaintiff Quartz Auto and its predecessors in interest have never licensed to the

Defendant under the ‘464 patent, nor has Plaintiff Quartz Auto otherwise authorized the Defendant 

to practice any part of the ‘464 patent.

56. The ‘464 patent is presumed valid under 35 U.S.C. §282.

57. The ‘464 patent relates to, among other things, systems and methods for distributing 

information to the operator of a vehicle.

58. On information and belief, Defendant operates a ride-hailing service that uses a 

passenger and driver application that distributes information to the operator of a vehicle.

59. Direct Infringement: On information and belief, Defendant has directly infringed 

and continues to directly infringe, either literally or under the doctrine of equivalents, one or more 

claims of the ‘464 patent, including for example (but not limited to) at least method claims 1-19

and system claims 20-22 of the ‘464 patent by making, using, distributing, providing, supplying,

selling, offering to sell without license or authority Defendant’s application that include infringing 

features. The infringing products include applications that can be used on a variety of remote 

computing devices and gather and transmit location-specific information. This is without Plaintiff 

Quartz Auto’s authorization, in violation of 35 U.S.C. § 271(a). A detailed infringement claim 

mapping is provided in paragraphs 64-69 and paragraphs 70-72 below.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 27 of 83
28

60. Induced Infringement: On information and belief, Defendant has and continues 

to promote, advertise, and instruct current drivers and riders, and potential drivers and riders about 

Lyft products, such as: 

(i) Providing Defendant’s downloadable applications for Rider 

(https://www.lyft.com/rider) and Driver (https://www.lyft.com/driver); 

(ii) Providing an overview of how to use Lyft’s branded products 

(https://www.lyftbusiness.com), including instructions for riders to use the services 

(https://help.lyft.com/hc/en-us/categories/115002006488-Riding-with-Lyft); and 

(iii) Providing requirements for drivers to sign-up for the service 

(https://help.lyft.com/hc/en-us/categories/115002009967-Driving-with-Lyft). 

Defendant’s promotion, advertising, and instruction efforts include, at a minimum, maintenance 

of its own website http://www.lyft.com/, providing additional driver application requirements 

and Frequently Asked Questions (FAQs), and other indicia of Lyft branded products 

(https://www.lyft.com/driver-application-requirements). Defendant’s software applications 

require both the rider and the driver to download the software applications for mobile computing 

devices, such as smartphones, laptops, and tablets, which enables Lyft to control the actions of 

both the riders and the drivers to use the infringing features of the products and methods for ridehailing. On information and belief, Defendant continues to engage in these acts with knowledge 

of the ‘464 patent by the filing of this Complaint, and with the actual intent to cause the acts 

which it knew or should have known would induce actual infringement.

61. Defendant Lyft has infringed the ‘464 patent by making, having made, using, 

importing, providing, supplying, distributing, selling, or offering for sale systems utilizing a 

method for managing data.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 28 of 83
29

62. The ‘464 patent is well known in the industry – having been cited in at least 64

cited patents since its filing date

63. Detailed Mapping of Direct Infringement: On information and belief, 

infringement of the ‘464 patent by these Lyft ride-hailing products and applications is 

demonstrated below. 

64. Method claim 1 of the alleged claims: 

 

1. A method of distributing vehicle control information, comprising:

determining at a controller located at a location vehicle control information 

associated with the location and with an operator of a vehicle;

transmitting the vehicle control information to a vehicle device;

receiving the vehicle control information at the vehicle device; and

arranging at the vehicle device for an indication to be provided to the operator in 

accordance with the vehicle control information.

65. On information and belief, the Lyft application or Lyft Network, which includes the 

passenger application, driver application, Lyft server, and all related technology (hereinafter, “Lyft

App”) performs a method of distributing vehicle control information.

https://help.lyft.com/hc/en-us/articles/115013079988-How-to-request-a-ride

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 29 of 83
30

66. On information and belief, the Lyft App determines at a controller located at a 

location vehicle control information associated with the location and with an operator of a vehicle.

https://help.lyft.com/hc/en-us/articles/115013079988-How-to-request-a-ride

67. On information and belief, the Lyft App transmits the vehicle control information 

to a vehicle device.

https://www.appsrhino.com/lyft-tech-stack-uber/

68. On information and belief, the Lyft App receives the vehicle control information at 

the vehicle device. 

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 30 of 83
31

https://www.appsrhino.com/lyft-tech-stack-uber/

69. On information and belief, the Lyft App arranges at the vehicle device for an 

indication to be provided to the operator in accordance with the vehicle control information.

https://www.appsrhino.com/lyft-tech-stack-uber/

https://www.youtube.com/watch?v=a8n2--HlzDU&t=10s

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 31 of 83
32

70. System claim 20 of the alleged claims:

20. A system, comprising:

a controller located at a location, wherein the controller is adapted to (i) determine 

vehicle control information associated with the location and with an operator of a vehicle 

and (ii) transmit the vehicle control information; and

a vehicle device adapted to (i) receive the vehicle control information and (ii) 

arrange for an indication to be provided to the operator in accordance with the vehicle 

control information.

71. On information and belief, the Lyft application or Lyft Network, which includes the 

passenger application, driver application, Lyft server, and all related technology (hereinafter, “Lyft

App”) is a system comprising a controller located at a location, wherein the controller is adapted 

to (i) determine vehicle control information associated with the location and with an operator of a 

vehicle and (ii) transmit the vehicle control information.

https://help.lyft.com/hc/en-us/articles/115013079988-How-to-request-a-ride

https://www.appsrhino.com/lyft-tech-stack-uber/

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 32 of 83
33

https://www.youtube.com/watch?v=a8n2--HlzDU&t=10s

72. On information and belief, the Lyft App is a system comprising a vehicle device 

adapted to (i) receive the vehicle control information and (ii) arrange for an indication to be 

provided to the operator in accordance with the vehicle control information.

https://www.appsrhino.com/lyft-tech-stack-uber/

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 33 of 83
34

https://www.youtube.com/watch?v=a8n2--HlzDU&t=10s

73. On information and belief, Defendant’s actions have and continue to constitute 

active inducing infringement of at least claims 1-19 and 20-22 of the ‘464 patent in violation of 35 

U.S.C. §271(b). 

74. As a result of Defendant’s infringement of at least claims 1-19 and 20-22 of the 

‘464 patent, Plaintiff Quartz Auto has suffered monetary damages in an amount yet to be 

determined, and will continue to suffer damages in the future unless Defendant’s infringing 

activities are enjoined by this Court. Defendant is liable to Plaintiff in an amount that adequately 

compensates for such infringements, which, by law, cannot be less than a reasonable royalty, 

together with interest and costs as fixed by this Court under 35 U.S.C. § 284.

75. Defendant’s wrongful acts have damaged and will continue to damage Plaintiff 

Quartz Auto irreparably, and Plaintiff has no adequate remedy at law for those wrongs and injuries. 

In addition to its actual damages, Plaintiff Quartz Auto is entitled to a permanent injunction 

restraining and enjoining Defendant and its agents, servants, and employees, and all person acting 

thereunder, in concert with, or on its behalf, from infringing at least claims 1-19 and 20-22 of the 

‘464 patent. 

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 34 of 83
35

COUNT III

PATENT INFRINGEMENT OF THE ‘085 PATENT

76. Plaintiff Quartz Auto repeats and realleges the above paragraphs, which are 

incorporated by reference as if fully restated herein.

77. Plaintiff Quartz Auto is the owner of all rights, title, and interest in the ‘085 patent.

78. Plaintiff Quartz Auto and its predecessors in interest have never licensed to the

Defendant under the ‘085 patent, nor has Plaintiff Quartz Auto otherwise authorized the Defendant 

to practice any part of the ‘085 patent.

79. The ‘085 patent is presumed valid under 35 U.S.C. § 282.

80. The ‘085 patent relates to, among other things, a method, system, and program for 

providing user location information with a personal information management program. A personal 

information management program gathers and presents personal information manager 

information, such as calendaring and scheduling information, allowing users to organize random 

bits of information in a useful format, including a person’s geographic location. 

81. On information and belief, Defendant operates a ride-hailing service that uses a 

passenger and driver application that interacts with a personal information management program, 

using geographical reference data to depict the various drivers in the vicinity of a potential 

passenger.

82. Direct Infringement: On information and belief, Defendant has directly infringed 

and continues to directly infringe, either literally or under the doctrine of equivalents, one or more 

claims of the ‘085 patent, including for example (but not limited to) at least claims 1-19 and claims

20-23 of the ‘085 patent by making, using, distributing, providing, supplying, selling, offering to 

sell, or importing without license or authority, Defendant’s application that include infringing 

features. The infringing products include applications that can be used on a variety of remote 

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 35 of 83
36

computing devices and gather and transmit location-specific information. Within Lyft, the 

passenger application generates position coordinates corresponding to the time the Lyft App is 

opened, connecting with the closest drivers, a list that continually updates until the passenger 

selects a destination. This is without Plaintiff Quartz Auto’s authorization, in violation of 35 U.S.C. 

§271(a). A detailed infringement claim mapping is provided in paragraphs 87-91 and paragraphs

92-98 below.

83. Induced Infringement: On information and belief, Defendant has and continues 

to promote, advertise, and instruct current drivers and riders, and potential drivers and riders about 

Lyft products, such as: 

(i) Providing Defendant’s downloadable applications for Rider 

(https://www.lyft.com/rider) and Driver (https://www.lyft.com/driver); 

(ii) Providing an overview of how to use Lyft’s branded products 

(https://www.lyftbusiness.com), including instructions for riders to use the services 

(https://help.lyft.com/hc/en-us/categories/115002006488-Riding-with-Lyft); and 

(iii) Providing requirements for drivers to sign-up for the service 

(https://help.lyft.com/hc/en-us/categories/115002009967-Driving-with-Lyft). 

Defendant’s promotion, advertising, and instruction efforts include, at a minimum, maintenance 

of its own website http://www.lyft.com/, providing additional driver application requirements and 

Frequently Asked Questions (FAQs), and other indicia of Lyft branded products 

(https://www.lyft.com/driver-application-requirements). Defendant’s software applications 

require both the rider and the driver to download the software applications for mobile computing 

devices, such as smartphones, laptops, and tablets, which enables Lyft to control the actions of 

both the riders and the drivers to use the infringing features of the products and methods for rideCase 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 36 of 83
37

hailing. On information and belief, Defendant continues to engage in these acts with knowledge 

of the ‘085 patent by the filing of this Complaint, and with the actual intent to cause the acts which 

it knew or should have known would induce actual infringement.

84. Defendant Lyft has infringed the ‘085 patent by making, having made, using, 

importing, providing, supplying, distributing, selling, or offering for sale systems utilizing a 

method for providing location information.

85. The ‘085 patent is well known in the industry – having been cited in at least 37

cited patents since its filing date

86. Detailed Mapping of Direct Infringement: On information and belief, 

infringement of the ‘085 patent by these Lyft ride-hailing products and applications is 

demonstrated below. 

87. Claim 1 of the alleged claims: 

 

1. A method for providing user location information for a personal information 

management program, comprising:

generating position coordinates of a wireless device and time information 

indicating times when the position coordinates were generated, wherein a user is associated 

with the wireless device;

processing the position coordinates and time information to determine whether a 

rate of change in distance per unit of time in a series of position coordinates at times 

indicates a predefined activity of the user occurring during an activity time period during 

which the position coordinates and the time information were generated; and

generating information on the determined predefined activity for the activity time 

period.

88. On information and belief, the Lyft application or Lyft Network, which includes the 

passenger application, driver application, Lyft server, and all related technology (hereinafter, “Lyft

App”) performs a method for providing user location information for a personal information 

management program.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 37 of 83
38

http://urban.cs.wpi.edu/urbcomp2019/file/Urbcomp_2019_paper_12.pdf

https://eng.lyft.com/lyfts-journey-through-mobile-networking-d8e13c938166

89. On information and belief, the Lyft App generates position coordinates of a wireless 

device and time information indicating times when the position coordinates were generated, 

wherein a user is associated with the wireless device.

http://urban.cs.wpi.edu/urbcomp2019/file/Urbcomp_2019_paper_12.pdf

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 38 of 83
39

Lyft Passenger Application Screenshot February 9, 2020

Lyft Driver Application Screenshot February 25, 2020

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 39 of 83
40

Lyft Driver Application Screenshot February 25, 2020

90. On information and belief, the Lyft App processes the position coordinates and time 

information to determine whether a rate of change in distance per unit of time in a series of position 

coordinates at times indicates a predefined activity of the user occurring during an activity time 

period during which the position coordinates and the time information were generated.

https://eng.lyft.com/detecting-stop-signs-and-traffic-signals-deep-learning-at-lyftmapping-75bac609c231/

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 40 of 83
41

https://eng.lyft.com/detecting-stop-signs-and-traffic-signals-deep-learning-at-lyftmapping-75bac609c231/

https://eng.lyft.com/detecting-stop-signs-and-traffic-signals-deep-learning-at-lyftmapping-75bac609c231/

https://eng.lyft.com/detecting-stop-signs-and-traffic-signals-deep-learning-at-lyftmapping-75bac609c231/

91. On information and belief, the Lyft App generates information on the determined 

predefined activity for the activity time period.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 41 of 83
42

https://eng.lyft.com/how-lyft-creates-hyper-accurate-maps-from-open-source-maps-andreal-time-data-8dcf9abdd46a

https://eng.lyft.com/how-lyft-creates-hyper-accurate-maps-from-open-source-maps-andreal-time-data-8dcf9abdd46a

https://www.lyft.com/safety/rider

92. Claim 20 of the alleged claims:

20. A method for generating a calendar for a personal information management, program, 

comprising:

receiving selection of a time interval;

for the selected time interval, determining position coordinates of a wireless device 

and time information indicating times when the position coordinates were generated, 

wherein a user is associated with the wireless device;

processing the position coordinates and time information during the selected time 

interval to determine whether a rate of change in distance per unit of time in a series of the 

position coordinates at times during the selected time interval indicates a predefined 

activity of the user occurring during the selected time interval;

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 42 of 83
43

generating information on the predefined activity within the selected time interval; 

and

displaying information on the predefined activity of the user and the selected time 

interval.

93. On information and belief, the Lyft application or Lyft Network, which includes the 

passenger application, driver application, Lyft server, and all related technology (hereinafter, “Lyft

App”) performs a method for generating a calendar for a personal information management,

program.

http://urban.cs.wpi.edu/urbcomp2019/file/Urbcomp_2019_paper_12.pdf

https://eng.lyft.com/lyfts-journey-through-mobile-networking-d8e13c938166

94. On information and belief, the Lyft App receives selection of a time interval.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 43 of 83
44

Lyft Driver Application Screenshot February 25, 2020

Lyft Driver Application Screenshot February 25, 2020

Lyft Driver Application Screenshot February 25, 2020

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 44 of 83
45

http://urban.cs.wpi.edu/urbcomp2019/file/Urbcomp_2019_paper_12.pdf

95. On information and belief, the Lyft App determines position coordinates of a 

wireless device and time information indicating times when the position coordinates were 

generated, wherein a user is associated with the wireless device, for the selected time interval.

http://urban.cs.wpi.edu/urbcomp2019/file/Urbcomp_2019_paper_12.pdf

https://developer.lyft.com/docs/ios

96. On information and belief, the Lyft App processes the position coordinates and time 

information during the selected time interval to determine whether a rate of change in distance per 

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 45 of 83
46

unit of time in a series of the position coordinates at times during the selected time interval 

indicates a predefined activity of the user occurring during the selected time interval.

Lyft Driver Application Screenshot February 25, 2020

http://urban.cs.wpi.edu/urbcomp2019/file/Urbcomp_2019_paper_12.pdf

https://eng.lyft.com/sensor-data-in-localization-wi-fi-329ea84db959

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 46 of 83
47

https://eng.lyft.com/how-lyft-creates-hyper-accurate-maps-from-open-source-maps-andreal-time-data-8dcf9abdd46a

97. On information and belief, the Lyft App generates information on the predefined 

activity within the selected time interval.

Lyft Driver Application Screenshot February 25, 2020

https://developer.lyft.com/docs/android-api-wrappers

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 47 of 83
48

Lyft Driver Application Screenshot February 25, 2020

98. On information and belief, the Lyft App displays information on the predefined 

activity of the user and the selected time interval.

Lyft Driver Application Screenshot February 25, 2020

https://developer.lyft.com/docs/android-api-wrappers

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 48 of 83
49

Lyft Driver Application Screenshot February 25, 2020

99. On information and belief, Defendant’s actions have and continue to constitute 

active inducing infringement of at least claims 1-19 and 20-23 of the ‘085 patent in violation of 35 

U.S.C. §271(b). 

100. As a result of Defendant’s infringement of at least claims 1-19 and 20-23 of the 

‘085 patent, Plaintiff Quartz Auto has suffered monetary damages in an amount yet to be 

determined, and will continue to suffer damages in the future unless Defendant’s infringing 

activities are enjoined by this Court. Defendant is liable to Plaintiff in an amount that adequately 

compensates for such infringements, which, by law, cannot be less than a reasonable royalty, 

together with interest and costs as fixed by this Court under 35 U.S.C. § 284.

101. Defendant’s wrongful acts have damaged and will continue to damage Plaintiff 

Quartz Auto irreparably, and Plaintiff has no adequate remedy at law for those wrongs and injuries. 

In addition to its actual damages, Plaintiff Quartz Auto is entitled to a permanent injunction 

restraining and enjoining Defendant and its agents, servants, and employees, and all person acting 

thereunder, in concert with, or on its behalf, from infringing at least claims 1-19 and 20-23 of the 

‘085 patent. 

COUNT IV

PATENT INFRINGEMENT OF THE ‘215 PATENT

102. Plaintiff Quartz Auto repeats and realleges the above paragraphs, which are 

incorporated by reference as if fully restated herein.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 49 of 83
50

103. Plaintiff Quartz Auto is the owner of all rights, title, and interest in the ‘215 patent.

104. Plaintiff Quartz Auto and its predecessors in interest have never licensed to 

Defendant under the ‘215 patent, nor has Plaintiff Quartz Auto otherwise authorized the Defendant 

to practice any part of the ‘215 patent.

105. The ‘215 patent is presumed valid under 35 U.S.C. § 282.

106. The ‘215 patent relates to, among other things, system management using real time 

collaboration.

107. On information and belief, Defendant operates a ride-hailing service that uses a 

passenger application, driver application, and server that collaborate in real time. 

108. Direct Infringement: On information and belief, Defendant has directly infringed 

and continues to directly infringe, either literally or under the doctrine of equivalents, one or more 

claims of the ‘215 patent, including for example (but not limited to) at least computer implemented 

method claims 1-4, computer implemented method claims 5-13, computer implemented method 

claims 14-16, and computer implemented method claim 17 of the ‘215 patent by making, using,

distributing, providing, supplying, selling, offering to sell, or importing without license or 

authority, Defendant’s application that include infringing features. The infringing products 

includes applications that respond to alerts made by the passenger (e.g., requesting a Lyft) by 

automatically detecting available nearby drivers and assigning responsibility of passenger’s alert 

to a driver (e.g., accepting the passenger’s request for a Lyft). This is without Plaintiff Quartz 

Auto’s authorization, in violation of 35 U.S.C. §271(a). A detailed infringement claim mapping is 

provided in paragraphs 112-117, paragraphs 118-124, paragraphs 125-132, and paragraphs 133-

139 below.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 50 of 83
51

109. Induced Infringement: On information and belief, Defendant has and continues 

to promote, advertise, and instruct current drivers and riders, and potential drivers and riders about 

Lyft products, such as: 

(i) Providing Defendant’s downloadable applications for Rider 

(https://www.lyft.com/rider) and Driver (https://www.lyft.com/driver); 

(ii) Providing an overview of how to use Lyft’s branded products 

(https://www.lyftbusiness.com), including instructions for riders to use the services 

(https://help.lyft.com/hc/en-us/categories/115002006488-Riding-with-Lyft); and 

(iii) Providing requirements for drivers to sign-up for the service 

(https://help.lyft.com/hc/en-us/categories/115002009967-Driving-with-Lyft). 

Defendant’s promotion, advertising, and instruction efforts include, at a minimum, maintenance 

of its own website http://www.lyft.com/, providing additional driver application requirements and 

Frequently Asked Questions (FAQs), and other indicia of Lyft branded products 

(https://www.lyft.com/driver-application-requirements). Defendant’s software applications 

require both the rider and the driver to download the software applications for mobile computing 

devices, such as smartphones, laptops, and tablets, which enables Lyft to control the actions of 

both the riders and the drivers to use the infringing features of the products and methods for ridehailing. On information and belief, Defendant continues to engage in these acts with knowledge 

of the ‘215 patent by the filing of this Complaint, and with the actual intent to cause the acts which 

it knew or should have known would induce actual infringement.

110. Defendant Lyft has infringed the ‘215 patent by making, having made, using, 

importing, providing, supplying, distributing, selling, or offering for sale systems utilizing a 

method and system for tracking mobile objects.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 51 of 83
52

111. Detailed Mapping of Direct Infringement: On information and belief, 

infringement of the ‘215 patent by these Lyft ride-hailing products and applications is 

demonstrated below.

112. Computer implemented method claim 1 is below: 

1. A computer-implemented method of responding to a problem condition, comprising:

automatically detecting availability of a first candidate to respond to a problem 

condition;

responsive to the detecting:

automatically assigning responsibility for the problem condition to the first 

candidate; and

receiving a confirmation from the first candidate indicating acceptance of 

responsibility for the problem condition.

 

113. On information and belief, the Lyft application or Lyft Network, which includes the 

passenger application, driver application, Lyft server, and all related technology (hereinafter, “Lyft

App”) is a computer implemented method of responding to a problem condition.

https://help.lyft.com/hc/en-us/articles/115013079988-How-to-request-a-ride

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 52 of 83
53

https://www.lyft.com/developers/products/ride-request

114. On information and belief, the Lyft App automatically detects availability of a first 

candidate to respond to a problem condition.

Lyft Driver Application Screenshot February 25, 2020

Lyft Driver Application Screenshot February 25, 2020

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 53 of 83
54

Lyft Passenger Application Screenshot February 9, 2020

https://www.lyft.com/developers/products/ride-request

https://help.lyft.com/hc/en-us/articles/115012926847-How-drivers-and-passengers-arepaired

115. On information and belief, the Lyft App is responsive to the detecting.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 54 of 83
55

https://help.lyft.com/hc/en-us/articles/115013079988-How-to-request-a-ride

https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

Lyft Driver Application Screenshot February 25, 2020

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 55 of 83
56

116. On information and belief, the Lyft App automatically assigns responsibility for the 

problem condition to the first candidate.

https://help.lyft.com/hc/en-us/articles/115013079988-How-to-request-a-ride

https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 56 of 83
57

Lyft Driver Application Screenshot February 25, 2020

https://help.lyft.com/hc/en-us/articles/115012926847-How-drivers-and-passengers-arepaired

117. On information and belief, the Lyft App receives a confirmation from the first 

candidate indicating acceptance of responsibility for the problem condition.

https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 57 of 83
58

Lyft Driver Application Screenshot February 25, 2020

118. Computer implanted method claim 5 is below: 

5. A computer-implemented method of managing an information technology device, 

comprising:

receiving an alert from a managed information technology device;

receiving availability information about a plurality of candidates;

automatically selecting a candidate qualified and available to respond to the event 

from among the plurality of candidates;

automatically assigning responsibility for the alert to the candidate; and

receiving a reply from the candidate indicating acceptance of responsibility for the 

alert.

119. On information and belief, the Lyft application or Lyft Network, which includes the 

passenger application, driver application, Lyft server, and all related technology (hereinafter, “Lyft

App”) is a computer implemented method of managing an information technology device.

https://help.lyft.com/hc/en-us/articles/115013079988-How-to-request-a-ride

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 58 of 83
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https://www.lyft.com/developers/products/ride-request

120. On information and belief, the Lyft App receives an alert from a managed 

information technology device.

Lyft Driver Application Screenshot February 25, 2020

Lyft Driver Application Screenshot February 25, 2020

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 59 of 83
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Lyft Passenger Application Screenshot February 9, 2020

https://www.lyft.com/developers/products/ride-request

https://help.lyft.com/hc/en-us/articles/115012926847-How-drivers-and-passengers-arepaired

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 60 of 83
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121. On information and belief, the Lyft App receives availability information about a 

plurality of candidates.

Lyft Driver Application Screenshot February 25, 2020

Lyft Driver Application Screenshot February 25, 2020

Lyft Passenger Application Screenshot February 9, 2020

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 61 of 83
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https://www.lyft.com/developers/products/ride-request

https://help.lyft.com/hc/en-us/articles/115012926847-How-drivers-and-passengers-arepaired

122. On information and belief, the Lyft App automatically selects a candidate qualified 

and available to respond to the event from among the plurality of candidates.

https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 62 of 83
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https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

Lyft Driver Application Screenshot February 25, 2020

Lyft Passenger Application Screenshots February 25, 2020

https://developer.lyft.com/docs/ios-api-wrappers

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 63 of 83
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Lyft Driver Application Screenshot February 25, 2020

123. On information and belief, the Lyft App automatically assigns responsibility for the 

alert to the candidate.

https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

Lyft Driver Application Screenshot February 25, 2020

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 64 of 83
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124. On information and belief, the Lyft App receives a reply from the candidate 

indicating acceptance of responsibility for the alert. 

https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

Lyft Driver Application Screenshot February 25, 2020

125. Computer implanted method claim 14 is below:

14. A computer-implemented method of managing an information technology device, 

comprising:

receiving an alert from a managed information technology device;

automatically selecting a candidate qualified to respond to the event;

automatically determining if the candidate is available to respond to the event;

automatically sending an instant message to the candidate containing information 

about the alert;

receiving an instant message from the candidate indicating acceptance of 

responsibility for the alert; and

automatically assigning responsibility for the alert to the candidate.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 65 of 83
66

126. On information and belief, the Lyft application or Lyft Network, which includes the 

passenger application, driver application, Lyft server, and all related technology (hereinafter, “Lyft

App”) is a computer implemented method of responding to a problem condition.

https://help.lyft.com/hc/en-us/articles/115013079988-How-to-request-a-ride

https://www.lyft.com/developers/products/ride-request

127. On information and belief, the Lyft App receives an alert from a managed 

information technology device.

Lyft Driver Application Screenshot February 25, 2020

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 66 of 83
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Lyft Driver Application Screenshot February 25, 2020

Lyft Passenger Application Screenshot February 9, 2020

https://www.lyft.com/developers/products/ride-request

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 67 of 83
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128. On information and belief, the Lyft App automatically selects a candidate qualified 

to respond to the event.

https://help.lyft.com/hc/en-us/articles/115012926847-How-drivers-andpassengers-arepaired

Lyft Passenger Application Screenshots February 25, 2020

https://developer.lyft.com/docs/ios-api-wrappers

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 68 of 83
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Lyft Driver Application Screenshot February 25, 2020

129. On information and belief, the Lyft App automatically determines if the candidate 

is available to respond to the event

https://help.lyft.com/hc/en-us/articles/115012926847-How-drivers-andpassengers-arepaired

Lyft Driver Application Screenshot February 25, 2020

130. On information and belief, the Lyft App automatically sends an instant message to 

the candidate containing information about the alert.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 69 of 83
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Lyft Driver Application Screenshot February 25, 2020

131. On information and belief, the Lyft App receives an instant message from the 

candidate indicating acceptance of responsibility for the alert.

https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

132. On information and belief, the Lyft App automatically assigns responsibility for the 

alert to the candidate. 

https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 70 of 83
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133. Computer implanted method claim 17 is below:

 

17. A computer-implemented method for assigning responsibility for responding to a fault 

condition in an information technology device, comprising:

(a) receiving an alert from a monitored information technology device, the alert 

describing an event in the monitored information technology device;

(b) automatically detecting an available administrator qualified to respond to the 

event; 

(c) automatically sending a first instant message to the available administrator, the 

instant message referencing the alert and requesting an acknowledgement;

(d) receiving a second instant message from the available administrator, the second 

instant message containing the acknowledgement from the administrator; and

(e) automatically assigning responsibility for the event to the available 

administrator.

134. On information and belief, the Lyft application or Lyft Network, which includes the 

passenger application, driver application, Lyft server, and all related technology (hereinafter, “Lyft

App”) is a computer implemented method of responding to a problem condition.

https://help.lyft.com/hc/en-us/articles/115013079988-How-to-request-a-ride

https://www.lyft.com/developers/products/ride-request

135. On information and belief, the Lyft App receives an alert from a monitored 

information technology device, the alert describes an event in the monitored information 

technology device. 

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 71 of 83
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Lyft Driver Application Screenshot February 25, 2020

Lyft Driver Application Screenshot February 25, 2020

Lyft Passenger Application Screenshot February 9, 2020

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 72 of 83
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https://www.lyft.com/developers/products/ride-request

136. On information and belief, the Lyft App automatically detects an available 

administrator qualified to respond to the event.

https://help.lyft.com/hc/en-us/articles/115012926847-How-drivers-andpassengers-arepaired

Lyft Passenger Application Screenshots February 25, 2020

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 73 of 83
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https://developer.lyft.com/docs/ios-api-wrappers

Lyft Driver Application Screenshot February 25, 2020

137. On information and belief, the Lyft App automatically sends a first instant message 

to the available administrator, the instant message references the alert and requests 

acknowledgment.

Lyft Driver Application Screenshot February 25, 2020

138. On information and belief, the Lyft App receives a second instant message from 

the available administrator, the second instant message contains the acknowledgement from the 

administrator.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 74 of 83
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https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

139. On information and belief, the Lyft App automatically assigns responsibility for the 

event to the available administrator.

https://help.lyft.com/hc/en-us/articles/115013080028-How-to-give-a-Lyft-ride

140. On information and belief, Defendant’s actions have and continue to constitute 

active inducing infringement of at least claims 1-4, 5-13, 14-16, and 17 of the ‘215 patent in 

violation of 35 U.S.C. §271(b). 

141. As a result of Defendant’s infringement of at least claims 1-4, 5-13, 14-16, and 17 

of the ‘215 patent, Plaintiff Quartz Auto has suffered monetary damages in an amount yet to be 

determined, and will continue to suffer damages in the future unless Defendant’s infringing 

activities are enjoined by this Court. Defendant is liable to Plaintiff in an amount that adequately 

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 75 of 83
76

compensates for such infringements, which, by law, cannot be less than a reasonable royalty, 

together with interest and costs as fixed by this Court under 35 U.S.C. § 284.

142. Defendant’s wrongful acts have damaged and will continue to damage Plaintiff 

Quartz Auto irreparably, and Plaintiff has no adequate remedy at law for those wrongs and injuries. 

In addition to its actual damages, Plaintiff Quartz Auto is entitled to a permanent injunction 

restraining and enjoining Defendant and its agents, servants, and employees, and all person acting 

thereunder, in concert with, or on its behalf, from infringing at least claims 1-4, 5-13, 14-16, and 

17 of the ‘215 patent.

COUNT V

PATENT INFRINGEMENT OF THE ‘616 PATENT

143. Plaintiff Quartz Auto repeats and realleges the above paragraphs, which are 

incorporated by reference as if fully restated herein.

144. Plaintiff Quartz Auto is the owner of all rights, title, and interest in the ‘616 patent.

145. Plaintiff Quartz Auto and its predecessors in interest have never licensed to 

Defendant under the ‘616 patent, nor has Plaintiff Quartz Auto otherwise authorized the Defendant

to practice any part of the ‘616 patent.

146. The ‘616 patent is presumed valid under 35 U.S.C. § 282.

147. The ‘616 patent relates to, among other things, the management of mobile objects 

and a service platform for mobile objects.

148. On information and belief, Defendant operates a ride-hailing service that uses a 

passenger and driver application to manage mobile objects (vehicles).

149. Direct Infringement: On information and belief, Defendant has directly infringed 

and continues to directly infringe, either literally or under the doctrine of equivalents, one or more 

claims of the ‘616 patent, including for example (but not limited to) at least system claims 1-10, 

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 76 of 83
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method claims 11-15, and computer program claims 16-19 of the ‘616 patent by making, using,

distributing, providing, supplying, selling, offering to sell, or importing without license or 

authority, Defendant’s application that include infringing features. The infringing products 

includes applications that monitors the locations of drivers (mobile objects) and passengers within 

a geographic area. This is without Plaintiff Quartz Auto’s authorization, in violation of 35 U.S.C. 

§271(a). A detailed infringement claim mapping is provided in paragraphs 154-156 below.

150. Induced Infringement: On information and belief, Defendant has and continues 

to promote, advertise, and instruct current drivers and riders, and potential drivers and riders about 

Lyft products, such as: 

(i) Providing Defendant’s downloadable applications for Rider 

(https://www.lyft.com/rider) and Driver (https://www.lyft.com/driver); 

(ii) Providing an overview of how to use Lyft’s branded products 

(https://www.lyftbusiness.com), including instructions for riders to use the services 

(https://help.lyft.com/hc/en-us/categories/115002006488-Riding-with-Lyft), and 

(iii) Providing requirements for drivers to sign-up for the service 

(https://help.lyft.com/hc/en-us/categories/115002009967-Driving-with-Lyft). 

Defendant’s promotion, advertising, and instruction efforts include, at a minimum, maintenance 

of its own website http://www.lyft.com/, providing additional driver application requirements and 

Frequently Asked Questions (FAQs), and other indicia of Lyft branded products 

(https://www.lyft.com/driver-application-requirements). Defendant’s software applications 

require both the rider and the driver to download the software applications for mobile computing 

devices, such as smartphones, laptops, and tablets, which enables Lyft to control the actions of 

both the riders and the drivers to use the infringing features of the products and methods for rideCase 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 77 of 83
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hailing. On information and belief, Defendant continues to engage in these acts with knowledge 

of the ‘616 patent by the filing of this Complaint, and with the actual intent to cause the acts which 

it knew or should have known would induce actual infringement.

151. Defendant Lyft has infringed the ‘616 patent by making, having made, using, 

importing, providing, supplying, distributing, selling, or offering for sale systems utilizing a 

method and system for tracking mobile objects.

152. The ‘616 patent is well known in the industry – having been cited in at least 11 cited 

patents since its filing date

153. Detailed Mapping of Direct Infringement: On information and belief, 

infringement of the ‘616 patent by these Lyft ride-hailing products and applications is 

demonstrated below. System claim 1 of the ‘616 patent is representative of, and is of similar scope 

to method claim 11 and computer program claim 16 of the ‘616 patent. 

154. System claim 1 is representative of the alleged claims: 

 

1. A system comprising:

a mobile object server operable to receive information from each of a plurality of 

mobile objects within a geographic space and perform a process associated with each 

mobile object; and

a registration server operable to register a first additional process that is to be 

performed in addition to a first basic process common to the plurality of mobile objects, in 

association with one mobile object among the plurality of mobile objects, wherein the 

mobile object server is operable to perform, as the first additional process, a process of 

providing notification that the one mobile object has become distanced from a 

predetermined location or region.

155. On information and belief, the Lyft application or Lyft Network, which includes the 

passenger application, driver application, Lyft server, and all related technology (hereinafter, “Lyft

App”) is a system comprising a mobile object server operable to receive information from each of 

a plurality of mobile objects within a geographic space and perform a process associated with each 

mobile object.

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 78 of 83
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http://urban.cs.wpi.edu/urbcomp2019/file/Urbcomp_2019_paper_12.pdf

https://www.quora.com/What-technology-does-Lyft-use-In-their-dispatch-service-whichlanguages-are-used-How-is-Lyft-providing-real-time-geotracking-to-multiple-mobileclients-Finally-how-was-Lyft-able-to-develop-their-consumer-facing-app-so-quickly

https://www.youtube.com/watch?v=a8n2--HlzDU

156. On information and belief, the Lyft App is a system comprising a registration server 

operable to register a first additional process that is to be performed in addition to a first basic 

process common to the plurality of mobile objects, in association with one mobile object among 

the plurality of mobile objects, wherein the mobile object server is operable to perform, as the first 

additional process, a process of providing notification that the one mobile object has become 

distanced from a predetermined location or region. 

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 79 of 83
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http://urban.cs.wpi.edu/urbcomp2019/file/Urbcomp_2019_paper_12.pdf

https://www.quora.com/What-technology-does-Lyft-use-In-their-dispatch-service-whichlanguages-are-used-How-is-Lyft-providing-real-time-geotracking-to-multiple-mobileclients-Finally-how-was-Lyft-able-to-develop-their-consumer-facing-app-so-quickly

https://www.lyft.com/safety/rider

Lyft Driver Application Screenshot February 25, 2020

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 80 of 83
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157. On information and belief, Defendant’s actions have and continue to constitute 

active inducing infringement of at least claims 1-10, 11-15, and 16-19 of the ‘616 patent in 

violation of 35 U.S.C. § 271(b). 

158. As a result of Defendant’s infringement of at least claims 1-10, 11-15, and 16-19 of 

the ‘616 patent, Plaintiff Quartz Auto has suffered monetary damages in an amount yet to be 

determined, and will continue to suffer damages in the future unless Defendant’s infringing 

activities are enjoined by this Court. Defendant is liable to Plaintiff in an amount that adequately 

compensates for such infringements, which, by law, cannot be less than a reasonable royalty, 

together with interest and costs as fixed by this Court under 35 U.S.C. § 284.

159. Defendant’s wrongful acts have damaged and will continue to damage Plaintiff 

Quartz Auto irreparably, and Plaintiff has no adequate remedy at law for those wrongs and injuries. 

In addition to its actual damages, Plaintiff Quartz Auto is entitled to a permanent injunction 

restraining and enjoining Defendant and its agents, servants, and employees, and all person acting 

thereunder, in concert with, or on its behalf, from infringing at least claims 1-10, 11-15, and 16-19

of the ‘616 patent. 

PRAYER FOR RELIEF

WHEREFORE, Plaintiff Quartz Auto respectfully requests that this Court enter:

A. A judgment in favor of Plaintiff Quartz Auto that Defendant has been and is

infringing at least claims 1-33 of the ‘004 patent, claims 1-22 of the ‘464 patent, claims 1-23 of 

the ‘085 patent, claims 1-17 of the ‘215 patent, and claims 1-19 of the ‘616 patent pursuant to 35 

U.S.C. §§ 271(a) and/or 271(b);

B. A permanent injunction enjoining Defendant and its officers, directors, agents, 

servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all others acting in 

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 81 of 83
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concert or privity with any of them from infringing, or inducing the infringement of, at least claims

1-33 of the ‘004 patent, claims 1-22 of the ‘464 patent, claims 1-23 of the ‘085 patent, claims 1-

17 of the ‘215 patent, and claims 1-19 of the ‘616 patent;

C. A judgment awarding Plaintiff Quartz Auto all damages adequate to compensate it 

for Defendant’s infringement of the Quartz Auto Patents under 35 U.S.C. § 284, and in no event 

less than a reasonable royalty for Defendant’s acts of infringement, including all post-judgment 

interest at the maximum rate permitted by law, and also any past damages permitted under 35 

U.S.C. § 286, as a result of Defendant’s infringement of at least claims 1-33 of the ‘004 patent,

claims 1-22 of the ‘464 patent, claims 1-23 of the ‘085 patent, claims 1-17 of the ‘215 patent, and

claims 1-19 of the ‘616 patent;

D. An assessment of costs, including reasonable attorney fees pursuant to 35 U.S.C. § 

285, and prejudgment interest against Defendant; and

E. Such other and further relief as this Court may deem just and proper.

JURY TRIAL DEMANDED

Pursuant to FED. R. CIV. P. 38, Plaintiff Quartz Auto hereby demands a trial by jury on all 

issues so triable.

Dated: February 28, 2020 Respectfully submitted,

By: _/s/ Thomas M. Dunlap__________

 

Thomas M. Dunlap (Admitted W.D. 

Tex./VA Bar No. 44016)

David Ludwig (Admitted W.D. 

Tex./VA Bar No. 73157)

Dunlap Bennett & Ludwig PLLC

8300 Boone Blvd., Suite 550

Vienna, Virginia 22182

(703) 442-3890 (t)

(703) 777-3656 (f)

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 82 of 83
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tdunlap@dbllawyers.com

dludwig@dbllawyers.com

Attorneys for Quartz Auto Technologies 

LLC

Case 6:20-cv-00156-ADA Document 1 Filed 02/28/20 Page 83 of 83