Enovsys LLC v. Uber Technologies, Inc.

Background

Enovsys LLC brought a patent-infringement action against Uber Technologies, Inc., involving U.S. Patent Nos. 6,441,752, 6,756,918, and 7,199,726. On June 17, 2024, the court granted Uber’s motion to dismiss and dismissed the complaint with prejudice, concluding that the asserted patents were patent-ineligible under 35 U.S.C. § 101 as a matter of law.

Enovsys then moved for leave to file a motion for reconsideration under Civil Local Rule 7-9. That rule requires a party to obtain the court’s permission before filing a reconsideration motion. The rule permits leave based on a previously unknown material difference in fact or law, new material facts or a change in law, or the court’s manifest failure to consider material facts or dispositive legal arguments.

Enovsys’s Arguments

Enovsys sought reconsideration of the court’s analysis at the second step of the framework established in Alice Corp. v. CLS Bank International. At that step, the court considers whether a patent claim contains an inventive concept beyond an abstract idea.

Enovsys argued that the court had discounted statements in the patents’ specifications that, Enovsys contended, showed the claimed systems and methods were not well-understood, routine, or conventional. Enovsys also argued that the court had improperly imposed an evidentiary burden on it at the pleading stage and had ruled that all claims in the three patents were invalid even though Uber’s motion to dismiss addressed only the asserted claims.

Court’s Analysis

The court explained that reconsideration cannot be used to present arguments or evidence for the first time when they reasonably could have been raised earlier. It found that Enovsys repeated arguments it had previously made and that the court had already rejected.

The court stated that it had considered the features Enovsys identified, including geographic boundaries, exclusion regions, location requests, and proximity and tracking determinations. The court had previously concluded that those features amounted to filtering or manipulating data and that the claims recited the abstract idea of receiving, reporting, and filtering location information, together with generic computer components.

The court also stated that it had considered the entire specification and determined that the claimed features amounted to the abstract idea described in its earlier order. It therefore rejected Enovsys’s argument that the alleged improvements supplied an inventive concept under the second step of Alice.

The court further rejected Enovsys’s argument that it had shifted the burden of proving non-conventionality. It stated that patents issued by the United States Patent and Trademark Office are presumed valid and that Uber bore the burden of proving that the patents claimed patent-ineligible subject matter. The court said its reference to what Enovsys had “not demonstrated” concerned Enovsys’s comparison of its patents with the patents in another case.

The court also rejected Enovsys’s challenge to dismissal without leave to amend. It concluded that any proposed amendment would be futile in light of the analysis in the earlier order.

Disposition

The court denied in part Enovsys’s motion for leave to file a motion for reconsideration. It deferred ruling only on Enovsys’s request to clarify the scope of the earlier order—specifically, which claims were affected. The court permitted Uber to file a response limited to that clarification request by July 19, 2024, with the response limited to three pages. The opinion does not resolve the deferred scope issue.