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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

Boxey Tech LLC,

Plaintiff,

v.

Lyft, Inc., 

Defendant.

Case No. 6:20-cv-567

Patent Case

Jury Trial Demanded

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff Boxey Tech LLC ("Boxey Tech"), through its attorneys, complains of Lyft, Inc. 

("Defendant”), and alleges the following:

PARTIES

1. Plaintiff Boxey Tech LLC is a corporation organized and existing under the laws 

of Texas that maintains its principal place of business at 5570 FM 423, Suite 250-2049, Frisco, 

TX 75034.

2. Defendant Lyft, Inc. is a corporation organized and existing under the laws of 

Delaware that maintains its principal place of business at 185 Berry St Ste 5000 San Francisco, 

CA 94107.

JURISDICTION

3. This is an action for patent infringement arising under the patent laws of the 

United States, Title 35 of the United States Code.

4. This Court has exclusive subject matter jurisdiction under 28 U.S.C. §§ 1331 and 

1338(a). 

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5. This Court has personal jurisdiction over Defendant because it has engaged in 

systematic and continuous business activities in this District. As described below, Defendant has 

committed acts of patent infringement giving rise to this action within this District. 

VENUE

6. Venue is proper in this District under 28 U.S.C. § 1400(b) because Defendant has 

committed acts of patent infringement in this District, and has employees who work in the 

District. In addition, Boxey Tech has suffered harm in this district.

PATENT-IN-SUIT

7. Boxey Tech is the assignee of all right, title and interest in United States Patents

No. 8,560,238 (the "’238 Patent") and 8,731,833 (the “’833 Patent”) (collectively the "Patentsin-Suit"); including all rights to enforce and prosecute actions for infringement and to collect 

damages for all relevant times against infringers of the Patents-in-Suit. Accordingly, Boxey Tech

possesses the exclusive right and standing to prosecute the present action for infringement of the 

Patent-in-Suit by Defendant.

The ‘238 Patent

8. The ‘238 Patent is entitled "Computing paths between geographical localities," 

and issued August 29, 2013. The application leading to the ‘238 Patent was filed on February 1, 

2011. A true and correct copy of the ‘238 Patent is attached hereto as Exhibit 1 and incorporated 

herein by reference.

9. The ‘238 Patent is valid and enforceable.

The ‘833 Patent

1. The ‘833 Patent is entitled "Computing paths between geographical localities," and issued 

May 20, 2014. The application leading to the ‘833 Patent was filed on July 23, 2013. A true 

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and correct copy of the ‘833 Patent is attached hereto as Exhibit 2 and incorporated herein by 

reference.

2. The ‘833 Patent is valid and enforceable.

COUNT 1: INFRINGEMENT OF THE PATENTS-IN-SUIT

3. Boxey Tech incorporates the above paragraphs herein by reference. 

4. Direct Infringement. Defendant has been and continues to directly infringe one 

or more claims of the Patents-in-Suit in at least this District by making, using, offering to sell, 

selling and/or importing, without limitation, at least the Products identified in the charts 

incorporated into this Count below (the “Exemplary Products”) that infringe at least the 

exemplary claims of the Patents-in-Suit also identified in the charts incorporated into this Count 

below (the "Exemplary Patents-in-Suit Claims") literally or by the doctrine of equivalents. On 

information and belief, numerous other devices that infringe the claims of the Patents-in-Suit 

have been made, used, sold, imported, and offered for sale by Defendant and/or its customers.

5. Defendant also has and continues to directly infringe, literally or under the 

doctrine of equivalents, the Exemplary Patents-in-Suit Claims, by having its employees 

internally test and use these Exemplary Products.

6. The service of this Complaint upon Defendant constitutes actual knowledge of 

infringement as alleged here.

7. Despite such actual knowledge, Defendant continues to make, use, test, sell, offer 

for sale, market, and/or import into the United States, products that infringe the Patents-in-Suit. 

On information and belief, Defendant has also continued to sell the Exemplary Products and 

distribute product literature and website materials inducing end users and others to use its 

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products in the customary and intended manner that infringes the Patents-in-Suit. Thus, on 

information and belief, Defendant is contributing to and/or inducing the infringement of the 

Patents-in-Suit.

8. Induced Infringement. Defendant actively, knowingly, and intentionally has 

been and continues to induce infringement of the Patents-in-Suit, literally or by the doctrine of 

equivalents, by providing the Exemplary Products to their customers for use in end-user products 

in a manner that infringes one or more claims of the Patents-in-Suit.

9. Contributory Infringement. Defendant actively, knowingly, and intentionally 

has been and continues materially contribute to their own customers' infringement of the Patentsin-Suit, literally or by the doctrine of equivalents, by providing the Exemplary Products to their 

customers for use in end-user products in a manner that infringes one or more claims of the 

Patents-in-Suit. Moreover, the Exemplary Products are not a staple article of commerce suitable 

for substantial noninfringing use.

10. Exhibit 2 includes charts comparing the Exemplary Patents-in-Suit Claims to the 

Exemplary Products. As set forth in these charts, the Exemplary Products practice the 

technology claimed by the Patents-in-Suit. Accordingly, the Exemplary Products incorporated in 

these charts satisfy all elements of the Exemplary Patents-in-Suit Claims. 

11. Boxey Tech therefore incorporates by reference in its allegations herein the claim 

charts of Exhibit 2.

12. Boxey Tech is entitled to recover damages adequate to compensate for 

Defendant's infringement.

JURY DEMAND

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13. Under Rule 38(b) of the Federal Rules of Civil Procedure, Boxey Tech

respectfully requests a trial by jury on all issues so triable. 

PRAYER FOR RELIEF

WHEREFORE, Boxey Tech respectfully requests the following relief:

A. A judgment that the Patents-in-Suit are valid and enforceable;

B. A judgment that Defendant has infringed, contributorily infringed, and/or induced 

infringement of one or more claims of the Patents-in-Suit;

C. An accounting of all damages not presented at trial;

D. A judgment that awards Boxey Tech all appropriate damages under 35 U.S.C. § 

284 for Defendant's past infringement, and any continuing or future infringement 

of the Patent-in-Suit, up until the date such judgment is entered, including pre- or 

post-judgment interest, costs, and disbursements as justified under 35 U.S.C. § 284 

and, if necessary, to adequately compensate Boxey Tech for Defendant's 

infringement, an accounting:

i. that this case be declared exceptional within the meaning of 35 U.S.C. § 285 

and that Boxey Tech be awarded its reasonable attorneys' fees against 

Defendant that it incurs in prosecuting this action;

ii. that Boxey Tech be awarded costs, and expenses that it incurs in prosecuting 

this action; and

iii. that Boxey Tech be awarded such further relief at law or in equity as the Court 

deems just and proper.

Dated: June 26, 2020 Respectfully submitted,

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/s/ Isaac Rabicoff

Isaac Rabicoff

Rabicoff Law LLC

5680 King Centre Dr, Suite 645

Alexandria, VA 22315 

(773) 669-4590

isaac@rabilaw.com

Counsel for Plaintiff

Boxey Tech LLC

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