On March 29, 2021, Quartz Auto Technologies LLC (“Quartz Auto” or “Plaintiff”), represented by Ronald P. Golden, III and Stephen B. Brauerman of Bayard, P.A., filed an intellectual property lawsuit against Lyft, Inc. (“Lyft” or “Defendant”), seeking injunctive relief and damages for allegedly infringing one or more claims of patents owned by the Plaintiff. This case was filed in U.S. District Court in the District of Delaware with Judge Maryellen Noreika presiding.
The Plaintiff filed this action for patent infringement of United States Patent Nos. 6,847,871 entitled “Continuously Monitoring And Correcting Operational Conditions In Automobiles From A Remote Location Through Wireless Transmissions” (“’871 Patent”), U.S. Patent No. 6,944,443 entitled “Method, Apparatus And System For Notifying A User Of A Portable Wireless Device” (“’443 Patent”), 7,007,013 entitled “Fast Computation of Spatial Queries In Location-Based Services” (“’013 Patent”), 7,958,215 entitled “System Management Using Real Time Collaboration” (“’215 Patent”) and 9,691,275 entitled “Adjusting Vehicle Timing In A Transportation Network,” (“’275 Patent”) (collectively, the “Asserted Patents”) under the Patent Laws of the United States, 35 U.S.C. § 1, et seq.
The Plaintiff alleged that “Defendant has been and is engaged in direct infringing activities by making, having made, and using the self-driving stack software, server-side software, and/or network of the Level 5 Platform and Defendant is the entity that owns or controls and operates such software, servers, and network. On information and belief, Plaintiff further alleges that Defendant has and continues to make and use the accused systems for development, testing, and/or training purposes.”
The Plaintiff further alleged that “Defendant benefits by providing the Lyft Platform to attract and retain riders and drivers to increase its revenue. The drivers also receive a benefit of receiving payment from Defendant from using the Driver app and transporting passengers to their destinations, and passengers receive the benefit of convenient transportation.”
The Plaintiff also alleged that “Lyft drivers are Lyft employees. Plaintiff pleads in the alternative that, to the extent that Lyft drivers are independent contractors or agents rather than employees, Defendant is responsible as a direct infringer because Defendant has and continues to direct and control the steps performed on the drivers’ mobile devices such that those steps are also attributable to Defendant under principles of joint infringement.”
There are five claims for relief laid down by the Plaintiff, one for the alleged infringement of one or more claims of each of the Asserted Patents.
In the prayer, the Plaintiff requested the court to pass a judgment in favor of Plaintiff Quartz Auto that Defendant has infringed one or more claims of Asserted Patents as alleged in the complaint and to award injunctive relief and damage 35 U.S.C. § 284, and post judgment interest pursuant to 35 U.S.C. § 285, and prejudgment interest against the Defendant.
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1:21-CV-00467
03/29/2021
Pending - Other Pending
Intellectual Property - Patent
Maryellen Noreika
Quartz Auto Technologies LLC
Lyft, Inc.
Ronald P. Golden, III
Stephen B. Brauerman
Thomas James
Jacqueline L. Thompson
Timothy P. Maloney
Nicole L. Little
John G. Day
Andrew Colin Mayo
Redline Comparison
Exhibit E
Exhibit D
Exhibit C
Exhibit B
Exhibit A
Civil Cover Sheet
Exhibit E
Exhibit D
Exhibit C
DocketSO ORDERED re #9 STIPULATION TO EXTEND TIME for the Defendant to respond to the Amended Complaint to June 25, 2021 (Set/Reset Answer Deadlines: Lyft, Inc. answer due 6/25/2021). ORDERED by Judge Maryellen Noreika on 5/18/2021. (dlw) (Entered: 05/18/2021)
[-] Read LessDocket(#9) STIPULATION TO EXTEND TIME for the Defendant to respond to the Amended Complaint to June 25, 2021 - filed by Lyft, Inc.. (Day, John) (Entered: 05/18/2021)
[-] Read LessDocket(#8) First AMENDED COMPLAINT for Patent Infringement against Lyft, Inc.- filed by Quartz Auto Technologies LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Brauerman, Stephen) Modified on 5/12/2021 (dlw). (Additional attachment(s) added on 5/13/2021: #6 Redline Comparison) (dlw). (Entered: 05/12/2021)
[-] Read LessDocketSO ORDERED re #7 STIPULATION TO EXTEND TIME to Respond to the Complaint to May 21, 2021 (Set/Reset Answer Deadlines: Lyft, Inc. answer due 5/21/2021). ORDERED by Judge Maryellen Noreika on 4/14/2021. (dlw) (Entered: 04/14/2021)
[-] Read LessDocket(#7) STIPULATION TO EXTEND TIME to Respond to the Complaint to May 21, 2021 - filed by Lyft, Inc.. (Day, John) (Entered: 04/14/2021)
[-] Read LessDocketPro Hac Vice Attorney Thomas James,Jacqueline L. Thompson,Nicole L. Little,Timothy P. Maloney for Quartz Auto Technologies LLC added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (myr) (Entered: 04/06/2021)
[-] Read LessDocketSO ORDERED re #6 MOTION for Pro Hac Vice Appearance of Attorney Timothy P. Maloney, Nicole L. Little, Jacqueline Thompson, and Thomas James filed by Quartz Auto Technologies LLC. ORDERED by Judge Maryellen Noreika on 4/6/2021. (dlw) (Entered: 04/06/2021)
[-] Read LessDocket(#6) MOTION for Pro Hac Vice Appearance of Attorney Timothy P. Maloney, Nicole L. Little, Jacqueline Thompson, and Thomas James - filed by Quartz Auto Technologies LLC. (Golden, Ronald) (Entered: 04/06/2021)
[-] Read LessDocket(#5) AFFIDAVIT of Service for Summons and Complaint served on The Corporation Trust Company as Registered Agent for Lyft, Inc. on March 31, 2021, filed by Quartz Auto Technologies LLC. (Golden, Ronald) (Entered: 03/31/2021)
[-] Read LessDocketCase Assigned to Judge Maryellen Noreika. Please include the initials of the Judge (MN) after the case number on all documents filed. (rjb) (Entered: 03/31/2021)
[-] Read LessDocket(#4) Summonses Issued (please complete the top portion of the form and print out for use/service). (myr) (Entered: 03/30/2021)
[-] Read LessDocket(#3) Report to the Commissioner of Patents and Trademarks for Patent/Trademark Number(s) 6,847,871 ;6,944,443 ;7,007,013 ;7,958,215 ;9,691,275. (myr) (Entered: 03/30/2021)
[-] Read LessDocket(#2) Notice, Consent and Referral forms re: U.S. Magistrate Judge jurisdiction. (myr) (Entered: 03/30/2021)
[-] Read LessDocket(#1) COMPLAINT FOR PATENT INFRINGEMENT filed with Jury Demand against Lyft, Inc. - Magistrate Consent Notice to Pltf. ( Filing fee $ 402, receipt number ADEDC-3581910.) - filed by Quartz Auto Technologies LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Civil Cover Sheet)(myr) (Entered: 03/30/2021)
[-] Read Less