California Northern District Court Rejects Uber's Eligibility Challenge To LBT GPS Tracking Patents

The United States District Court for the Northern District of California on 26 June 2026 held that Uber Technologies Inc.'s motion for judgment on the pleadings against LBT IP II LLC could not be sustained, finding that the asserted GPS tracking and location-display patents were not directed to abstract ideas and were patent-eligible.

Judge Rita F. Lin rejected Uber's plea to invalidate LBT's patents at the pleadings stage. She held that the claim "involves more than merely gathering data, using that data to perform calculations, and presenting the result," and instead discloses "a non-abstract technological solution to a technological problem" by improving tracking accuracy when GPS line of sight is unavailable.

The dispute arose from LBT's US Patent No. '724, which covers a method for locating a tracking device using transmitter and receiver station signals when the device does not have a direct line of sight to a GPS satellite, and US Patent No. '355, which relates to a user interface for displaying location data sourced from multiple mapping providers without requiring repeated access to their websites. Uber argued that both patents merely claimed abstract data processing and display functions.

The Court rejected this submission, holding that the claimed inventions went beyond data collection and presentation. It found that the '724 Patent reflected a technical solution addressing limitations in GPS-based tracking, particularly in environments where satellite line of sight is obstructed.

On the '355 Patent, Uber contended that Claim 1 was directed to the abstract idea of providing and displaying location information for a tracked individual. The Court disagreed, holding that the claim was directed to a method that achieved greater technical efficiency than prior systems, thereby constituting a technological improvement rather than an abstract concept.

Having upheld the eligibility of the representative claims, the Court proceeded to construe nine disputed claim terms across the two patents. On the term “activating the tracking device,” it accepted Uber's construction, holding that the claims contemplate passive activation that does not require any action from the person being tracked. The Court relied on the specification's statement that “the system of the present invention is passive,” treating it as a clear limitation on claim scope.

On “without line-of-sight,” the Court rejected Uber's indefiniteness challenge and adopted a graded interpretation distinguishing between partial obstruction, full obstruction, and conditions that merely make GPS tracking difficult without rendering it impossible.

The Court also rejected indefiniteness challenges to “reference signal” and “transmitting the location data,” holding that Uber failed to establish that a person skilled in the art would lack reasonable certainty in understanding the scope of the claims.

For the remaining disputed terms, including “graphical mapping tiles,” “alert message,” and “wizard menu,” the Court largely adopted constructions grounded in the patent specifications, declining to accept narrower interpretations advanced by Uber.