Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 1 of 23 Page ID #:1

1 Rasheed McWilliams (CA Bar No. 281832)

2
[email protected]
Obi I. Iloputaife (CA Bar No. 192271)
3 [email protected]
4 Jayson S. Sohi (CA Bar No. 293176)
[email protected]
5 COTMAN IP LAW GROUP, PLC
6 35 Hugus Alley, Suite 210
Pasadena, CA 91103
7 (626) 405-1413/FAX: (626) 316-7577
8 Attorneys for Plaintiff
Hailo Technologies, LLC d/b/a Bring
9
10
11 UNITED STATES DISTRICT COURT
12
CENTRAL DISTRICT OF CALIFORNIA
13
14
Hailo Technologies, LLC, d/b/a Bring, a ) Case No. 2:17-cv-03028
15 California Limited Liability Company )
16 ) COMPLAINT FOR
Plaintiff, ) INFRINGEMENT OF
17 ) U.S. PATENT NO. 5,973,619
18 v. )
)
19 Uber Technologies, Inc., a Delaware ) DEMAND FOR JURY TRIAL
20 Corporation, )
)
21 Defendant. )
22 )
23
24
25
26
27
28
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 2 of 23 Page ID #:2

1 COMPLAINT FOR PATENT INFRINGEMENT

2 Plaintiff Hailo Technologies, LLC, ("Hailo" or "Plaintiff"), by and through its
3 undersigned counsel, for its Complaint against Defendant Uber Technologies, Inc.
4 ("Uber" or "Defendant") makes the following allegations. These allegations are made
5 upon information and belief.
6
7 NATURE OF THE ACTION
8 1. This is an action against Defendant for infringement of one or more claims
9 of United States Patent No. 5,973,619 ("the '619 Patent").
10
11 PARTIES
12 2. Plaintiff Hailo Technologies, LLC is a limited liability company organized
13 under the laws of the State of California and has an office and principal place of business
14 at 35 Hugus Alley, Suite 210, Pasadena, California 91103.
15 3. Defendant Uber Technologies, Inc. is a corporation incorporated under the
16 laws of the State of Delaware and has an office and principal place of business at 1455
17 Market Street, 4th Floor, San Francisco, California 94103.
18
19 JURISDICTION AND VENUE
20 4. This patent infringement action arises under the patent laws of the United
21 States, including 35 U.S.C. 271 et seq., 281, and 284.
22 5. This Court has subject matter jurisdiction over this action pursuant to 28
23 U.S.C. 1331 and 1338(a) because it arises under United States Patent law.
24 6. This Court has personal jurisdiction over the Defendant because it (either
25 directly or through its subsidiaries, divisions, groups or distributors) has sufficient
26 minimum contacts with the forum as a result of business conducted within the State of
27 California and this District; and/or specifically over the Defendant (either directly or
28
1
COMPLAINT FOR PATENT INFRINGEMENT
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 3 of 23 Page ID #:3

1 through its subsidiaries, divisions, groups or distributors) because of its infringing

2 conduct within or directed at this district.
3 7. Venue is proper in this district pursuant to 28 U.S.C. 1391(b), 1391(c),
4 since the related acts and transactions include the sale and operation of the software
5 identified herein was done by Defendant in the State of California and throughout this
6 district.
7
8 FACTS
9 8. Plaintiff is the sole owner, by assignment, of U.S. Patent No. 5,973,619,
10 entitled "AUTOMATED VEHICLE DISPATCH AND PAYMENT HONORING
11 SYSTEM," which was duly and legally issued on October 26, 1999 by the United States
12 Patent and Trademark Office ("USPTO").
13 9. A copy of the '619 Patent is attached to this Complaint as Exhibit A.
14 10. The claims of the '619 Patent are valid and enforceable.
15
16 COUNT I: CLAIM FOR PATENT INFRINGEMENT
17 UNDER 35 U.S.C. 271(b) ('619 PATENT)
18 AGAINST DEFENDANT UBER
19 11. Plaintiff hereby incorporates by reference the allegations of paragraphs 1
20 through 10 of this Complaint as if fully set forth herein.
21 12. Claim 1 of the '619 Patent covers "A method as implemented on a
22 computer system for use by a consumer, said method for delivering instructional
23 messages to said consumer regarding private transportation companies and estimated
24 costs for hiring said transportation company for transporting said consumer to listed
25 destinations and further providing an automated taxi dispatch and payment honoring
26 system, said method comprising the steps of: (1) displaying a list of authorized
27 transportation companies for selection by the operator of the computer; (2) prompting
28
2
COMPLAINT FOR PATENT INFRINGEMENT
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 4 of 23 Page ID #:4

1 the consumer to insert the amount of passengers to be traveling in the transportation

2 vehicle; (3) graphically illustrating destination locations; (4) displaying the approximate
3 fare for the number of passengers promoted to a selected destination and types of
4 payment options honored by said selected company; (5) initiating a dispatch call for an
5 available taxi from said selected taxi company; (6) estimate the approximate arrival
6 time for said dispatched taxi." See Exhibit A.
7 13. Defendant developed, develops, used, uses, sells, implements, and
8 distributes systems and software solutions that connect users with independent private
9 car operators for securing paid transportation, including without limitation the "Uber"
10 Passenger Software Application ("Accused Product").
11 14. A claim chart comparing Claim 1 of the '619 Patent to the Accused Product
12 is attached as Exhibit B.
13 15. Defendant offers the Accused Product as a free application for download
14 by either passengers or drivers. See Exhibit B, p. 1.
15 16. The Accused Product executes a method for delivering instructional
16 messages to a user regarding private transportation companies and the estimated costs
17 for hiring one of the transportation companies to travel to a destination, and for
18 providing an automated vehicular dispatching and payment system. See Exhibit B, p.
19 1.
20 17. The Accused Product shows the user a graphical representation of a group
21 of authorized independent private car operators, any one of which Uber may select to
22 signal for the ride, based on each operator's proximity to the user, availability, and
23 service-type registration (e.g. UberX, SELECT, BLACK, etc.). See Exhibit B, p. 2.
24 18. The Accused Product prompts the user to indicate how may seats they will
25 need to occupy in the independent operator's vehicle. See Exhibit B, p. 3.
26 19. The Accused Product prompts the user with several contextually-sensitive
27 locations they can pick as a destination. Once selected, the Accused Product shows the
28
3
COMPLAINT FOR PATENT INFRINGEMENT
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 5 of 23 Page ID #:5

1 user a distinctly-colorized marker for their desired destination, which appears on a map
2 from data made available by Uber remotely. See Exhibit B, p. 4.
3 20. Once a destination is selected, the Accused Product presents the user with
4 an approximate cost for the ride, the confirmed number of seats the user is requesting,
5 and the method of paying for the ride that the independent operator is required to honor.
6 See Exhibit B, p. 5.
7 21. When the user presses the "REQUEST" button in the user interface of the
8 Accused Product, Uber distributes a request to selected independent operators to
9 provide their vehicle for the fare. See Exhibit B, p. 6.
10 22. Once an independent operator accepts Uber's request for providing their
11 vehicle in satisfaction of the user's fare, the Accused Product shows the approximate
12 location of the operator's vehicle and the estimated time of the vehicle's arrival to their
13 location. See Exhibit B, p. 7.
14 23. Each preprogrammed aspect of the Accused Product, itemized in
15 paragraphs 15-22 above, is a limitation in Claim 1 of the '619 Patent. See Exhibit B.
16 24. Defendant Uber, including its agents and assigns, distributes the Accused
17 Product, which is preprogrammed to practice the method of Claim 1 of the '619 Patent.
18 25. Defendant Uber practices at least one step of the method of Claim 1 of the
19 '619 Patent. See Exhibit B, p. 6.
20 26. Thus, Uber infringes at least Claim 1 of the '619 Patent.
21 27. Plaintiff has been, and will continue to be, irreparably harmed by Uber's
22 ongoing infringement of the '619 Patent.
23 28. As a direct and proximate result of Uber's infringement of the '619 Patent,
24 Plaintiff has been and will continue to be damaged in an amount yet to be determined,
25 including but not limited to Plaintiff's lost profits and/or a reasonable royalty.
26 ///
27 ///
28
4
COMPLAINT FOR PATENT INFRINGEMENT
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 6 of 23 Page ID #:6

1 PRAYER FOR RELIEF

2 WHEREFORE, Plaintiff prays for relief against Defendant as follows:
3 A. In favor of Plaintiff that Defendant has infringed one or more claims of the
4 '619 Patent, either literally or under the doctrine of equivalents;
5 B. Requiring Defendant to pay Plaintiff its damages, costs, expenses, and
6 prejudgment and post-judgment interest for Defendants infringement of the '619 Patent
7 as provided under 35 U.S.C. 284, but not less than a reasonable royalty; and
8 C. For such other and further relief, as may be just and equitable.
9
10 DEMAND FOR TRIAL BY JURY
11 Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby
12 demands a jury trial on all issues and causes of action triable to a jury.
13
14
15 Dated: April 21, 2017 Respectfully submitted,
16 COTMAN IP LAW GROUP, PLC
17
/s/Rasheed M. McWilliams
18 ________________________________
19 Rasheed M. McWilliams
Obi Iloputaife
20 Jayson S. Sohi
21 Counsel for Plaintiff
Hailo Technologies, LLC d/b/a Bring
22
23
24
25
26
27
28
5
COMPLAINT FOR PATENT INFRINGEMENT
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 7 of 23 Page ID #:7

US005973619A
United States Patent [19] [11] Patent Number: 5,973,619
Paredes [45] Date of Patent: Oct. 26, 1999

[54] AUTOMATED VEHICLE DISPATCH AND Primary ExaminerBrent A. Swarthout

PAYMENT HONORING SYSTEM Attorney, Agent, or FirmMcHale & Slavin PA

[76] Inventor: Alexis Paredes, 1901 Park Lake St., [57] ABSTRACT
Orlando, Fla. 32803
An automated vehicle dispatch and payment honoring sys
[21] Appl. No.: 08/872,084 tem which is comprised of a computerized system with
specialized software which enables a user to select a par
[22] Filed: Jun. 10, 1997 ticular Taxi or vehicular transport company from a menu,
[51] Int. Cl.6 ................................................... .. G08G 1/123
along with the desired destination and number of passengers
[52] US. Cl. ........................ .. 340/994; 235/384; 340/434;
traveling. The software provides multi-lingual, user-friendly
705/5 menu driven choices, which might include advertising for
[58] Field of Search ................................... .. 340/994, 988,
restaurants, hotels, etc. The system then displays the
approximate fare and provides alternative forms of payment
340/434, 995; 235/384; 705/5, 13; 701/200, which are honored by that particular transport company.
211, 1
This system might include individualized computerized
[56] References Cited stands or wall unit strategically positioned in such crowded
places as airports, hotels, and banks. Such stands could
U.S. PATENT DOCUMENTS electronically receive and scan credit or debit cards. The
4,092,718 5/1978 Wendt ................................... .. 340/994 software system might also be accessed via computer or
4,928,099 5/1990 Drake 340/307 telephonic link. The ?nalized request for service is relayed
5,168,451 12/1992 Bolger ................ .. 340/994 to a dispatcher via telecommunication, satellite, or computer
5,197,009 3/1993 Hoffman, Jr. et al. .. 340/995 link. The dispatcher can then route the appropriate vehicle to
5,726,885 3/1998 Klein @181. ............ .. 235/384
5,732,398 3/1998 Tagawa ........ . . . . . . .. 705/5
the requesters location whereby a pre-printed credit voucher,
5,799,263 8/1998 Culbertson ............................ .. 340/994
as veri?ed and generated by the system could be exchanged
for the transportation services rendered.
FOREIGN PATENT DOCUMENTS
2674355 9/1992 France ................................. .. 340/994 7 Claims, 6 Drawing Sheets

SECURTITY CAMERA
1800
EQUIPMENT SYSTEM
MONITOR
1000
m /1B00
2000
1800
O
CONTROL 1000 1300
UNIT 1100 1 1 O0 1400
VIDEO
L Q COMPUTER
1200
TELEPHONE LINE
[EIU 1500 I200
SOFTWARE \t POWER SUPPLY 1700
PROGRAM MODEM I900
I210 1220 1700
I
PRINTER
I400

FIXTURE UNIT 2000A

EXHIBIT A
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 8 of 23 Page ID #:8

U.S. Patent Oct.26, 1999 Sheet 1 of6 5,973,619

/
START \ . .

W95? .
Plck a
TaX1L1nk
unguage Flow Chart
20 prepared 5-21-96

[Spal?sh] I Frelxch 1 [lapalnesgj I Italian I 1

L l I I I J -

L I I l I l
COMPANY COMPANY COMPANY FOMPANY COMPANY COMPANY
A B C F G H
I I I l 1 J

F l l l
[Am-actions] IHOLCEI IRsstamams] [Flzighborhoodil

l l I l
Amen'can . . ,
Cash Express Dlscovcr TanCard
I I l J

Select incorrect
information \1,
9O0

Your taxi has

been dispatched

Thank yo|._1 for using

910 TamLmk

EXHIBIT A
Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 9 of 23 Page ID #:9

U S Patent Oct.26, 1999 Sheet 2 of6 5,973,619

xF.@EF562 9.1

I-I. I- I-

EXHIBIT A
Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 10 of 23 Page ID #:10

U.S. Patent Oct. 26, 1999 Sheet 3 of6 5,973,619

FIG. 1B

The TaxiLlNK Card offers corporate customers a direct billing option for payment
of services rendered within a billing cycle. Personal customers can also use the prepaid Taxilink Card to
debit an account for services.

EXHIBIT A
Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 11 of 23 Page ID #:11

U.S. Patent 0111.26, 1999 Sheet 4 0f 6 5,973,619

Fl G _ 2 1581-1003001111 CAMERA
EQUIPMENT mm)
READEFI
A
2000
?mo
1300 1000

1000 1300
1100
VIDEO 1400
I_ COMPUTER TELEPHONE LINE _
1200 [E __U 1500 T200
SOFTWARE 1% POWER SUPPLY mo
PROGRAM ) MODEM) 1900
1210 I220
.
PRINTER
1400

FIXTURE UNIT 2000 A

FIG. 3
TYPES OF EMBODIMENTS
/
I1 5 EDGEx EXISTING
U Q,E SUFTW
IXTU NlT WALL MOUNTED BANK UNIT HOST UNIT INTERACTIVE ON-LINE
l2000 UNIT 2000 B 2000 C 2000 D TV. 2000 E 2000 F

EXHIBIT A
Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 12 of 23 Page ID #:12

U.S. Patent Oct.26, 1999 Sheet 5 of6 5,973,619

2UF0INXTUARE

F3AIG.

EXHIBIT A
Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 13 of 23 Page ID #:13

U.S. Patent Oct.26, 1999 Sheet 6 of6 5,973,619

mo m

.UEmm

EXHIBIT A
Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 14 of 23 Page ID #:14

5,973,619
1 2
AUTOMATED VEHICLE DISPATCH AND ef?cient vehicle by calculating the total travel distance in
PAYMENT HONORING SYSTEM relation to previously assigned dispatches. A service request
is dispatched to the particular vehicle Which Would have the
FIELD OF THE INVENTION minimum added travel distance. A geographical display map
The present invention involves an Automated Vehicle of the area With the various dispatch requests can be pro
Dispatch and Payment Honoring system distributed to serve vided for vieWing the vehicle operator. The vehicle operator
numerous locations and users. This computerized vehicle can thereby determine the most ef?cient route to service the
stand unit and/or softWare program reprocesses a request for dispatch requests.
service by permitting user to enter and/or change selections Accordingly, What is needed in the ?eld is a computeriZed
10 vehicle summoning stand or unit Which functions indepen
on types of transportation companies, destinations, forms of
payment, and number of passengers travelling before reg dently from other units and can send request information to
istering a dispatch or service to an authoriZed company on any of a variety of companies. The unit Would contain
the system. The present invention is con?gured to eXtend specialiZed softWare Which prompts the user for such infor
such services as taXis, limousines, private cars, and buses in mation including the language desired for the transaction,
foreign languages to one or more companies on the system. 15 the number of passengers, destination, and the type of
vehicle desired. The approXimate fare could then be calcu
BACKGROUND OF THE INVENTION lated and displayed and the unit Would be capable of
It is knoWn in the prior art to transmit requests for services receiving and processing payment of the fare, With a voucher
for a multiplicity of remote call boXes by radio channel being issued to the user. The free-standing unit might
transmission, transmitting alarms, encoding signals and for similarly be incorporated into a Wall unit or existing com
summoning emergency services to a central dispatch loca puteriZed access system, With a telecommunication, com
tion. Such prior art systems may transfer messages unidi puteriZed or satellite link being used to convey the vehicle
rectional or bidirectional, by radio channel or in digital form. request and payment information.
HoWever, they are generally unitary systems Which can 25 SUMMARY OF THE INVENTION
serve only one company. This invention differentiates itself
from the prior art by offering a host computeriZed vehicle The present invention embodies a computeriZed system
stand unit designed to serve numerous companies and honor Which enables customers to select a transportation company,
payment of services by credit card or by a host card, i.e. a in this eXample a taXi company, from a menu of all permitted
TAXILINK CARD as shoWn in FIG. 1B. The eXample and participating companies. The user can choose a desired
TaXilink card offers corporate customers a direct billing destination and enter the number of passengers travelling.
option for payment of services rendered Within a billing The system Will then display the approXimate fare along
cycle. Personal customers can also use the prepaid TaXilink With forms of payment honored by the taXi company
Card to pay for services. The present invention, among other selected. SpecialiZed softWare enables a customer to make
aspects, further differentiates itself from the prior art by any changes prior to the selection being dispatched as a
35
providing for transmission of the request for services and request for service. The system uses a telecommunication or
payment of services through a telecommunication and sat satellite link to relay the request to the dispatcher While a
ellite link. receipt for the operation is printed. The system improves
The prior art Which primarily uses single communication foreign customer service by offering multi-lingual instruc
channel or a digital signals is also strictly limited to one tions along With provisions for advertising.
language for entering request for services. The present The Way in Which the system displays all of the destina
invention offers the user menu-type options including many tions Will inform and encourage the eXtended use of taXi
foreign languages along With a better means to assist and service. Along With honoring credit cards, the system fea
inform the user on selecting a destination and payment tures a TaXilink card (FIG. 1b) account for corporate or
option before making a request for service. Each system unit 45
personal use Which can be paid by a direct bill or a debit
operates independent and therefore is unaffected by its account. The frequent use of the TaXilink card enables
geographical relationship to one another. drivers to gain corporate market share by encouraging repeat
As an eXample of the prior art, US. Pat. No. 4,928,099 for business. The TaXilink card Will eXpedite the typical trans
a TELEMETRY SYSTEM FOR AUTOMATED REMOTE actions and dispatch times. With cashless fare transaction,
CALLING AND CENTRAL DISPATCH OF SERVICES, driver safety Will be improved in that the ?nancial incentive
PARTICULARLY TAXICABS, discloses a telemetry sys for assault and robbery is reduced. Safety is also improved
tem distributed geographically via call boXes Which syn at busy curbsides Where this system improves traf?c con
chronously transmits digital taxicab requests. Each call boX gestion problems and customer safety by organiZing pas
repeats its transmission at intervals to insure non-con?icting sengers and fares for ready pick-up. This computeriZed taXi
receipt of the message. A central computer receives and 55
stand unit and softWare program can replace taXi hard
processes the messages to eliminate redundancy, display stands, thereby freeing curbspace for metered parking rev
requests to a dispatcher service, and log all requests and enue back to the city.
responses thereto. The call boX can also send messages
BRIEF DESCRIPTION OF THE DRAWINGS
regarding vandalism, loW poWer, and/or the systems gen
eral on-line status. FIG. 1 shoWs a ?oWchart of the vehicle request, or
US. Pat. No. 5,168,451 for a USER RESPONSIVE TaXilink softWare, as eXecuted by the computer and hard
TRANSIT SYSTEM discloses a user responsive transit Ware components of the vehicle dispatch and payment
system Which includes a number of service request terminals honoring system.
located at intervals in areas served by the transit system. FIG. 1A shoWs a beginning menu screen for the program
Passengers use the service request terminals to transmit a 65 of FIG. 1.
request to a central dispatch controller, the controller Steps 100910 shoW various screens Which appear as a
receives the request and automatically dispatches the most result of using the program of FIG. 1.

EXHIBIT A
Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 15 of 23 Page ID #:15

5,973,619
3 4
FIG. 1B shows an example embodiment of a Taxicard for Restaurants, Hotels, Neighborhoods, etc.) All advertised
automated payment of transportation services. destinations Will appear under the category selected. Here
FIG. 2 shoWs a block diagram of example hardWare the customer can select a desired destination, request Addi
utilized by a vehicle unit stand. tional Information or change the users pick. If Additional
Information is selected, the next screen 600 Will offer more
FIG. 3 shoWs a series of embodiments for implementing details on scheduled events, type of facility or any other
the vehicle dispatch system as described above. advertisement Which Will serve to better inform the cus
FIG. 3A shoWs an embodied free-standing vehicle dis tomer.
patch and payment honoring system. After the destination is entered the folloWing screen 700
FIG. 3B shoWs an embodied multi-screened vehicle dis 10
Will display the approximate fare along With all forms of
patch and payment honoring system as might typically be payment honored by the system. A Con?rmation screen
found in a bank or other such institution. 800 Will appear next displaying all the prior selections along
With a prerecorded video message Thank you for using
DETAILED DESCRIPTION OF THE Taxilink. Please revieW your selections before continuing.
PREFERRED EMBODIMENT The customer can make changes to any prior selection, if he
15
or she desires. The system Will then make a Dispatch of
Although the invention has been describe in terms of a Service call to the respective dispatcher via telecommuni
speci?c embodiment, it Will be readily apparent to those cation or satellite link. The dispatcher Will receive a voice or
skilled in this art that various modi?cations, rearrangements display message from the Taxilink system stating all the
and substitutions can be made Without departing from the information entered along With a request for response time.
spirit of the invention. The scope of the invention is de?ned This response time Will then appear on the screen 900 While
by the claims appended hereto. a print of the entire transaction is produced. A ?nal exit
Referring noW to FIGS. 1, 1A, and the ?oWchart steps message 910 Will con?rm the end.
100910, the How chart shoWn exhibits the Taxilink soft Referring noW to FIG. 1B, an example of a Taxilink card
Ware program executed by the computer and components of is shoWn for automatic debit of a transport fare. After
the automated taxi dispatch and payment honoring system in 25 entering the Taxilink card into an appropriate sloW or reader,
accordance With the present invention. The How steps are the system Will expedite the process by displaying the
described beloW: Destinations screen 500, screen 600; then the Con?rma
tion screen 800; folloWed by Dispatch of service screen
900; ?nal exit screen 910. The Taxilink card offers corporate
FLOW CHART DESCRIPTION: customers a direct billing option for payment of services
rendered Within a billing cycle.
STEP:
Referring noW to FIG. 2, an example hardWare con?gu
100 Displays an animated graphic screen saver, With ration is shoWn for dispatch stand unit and payment honor
solicitation and instruction messages and an ing system. The Operational System Monitor 1000 displays
active START button. to the user all service options, instructions, and advertise
200 Selection of Language screen exhibits all
35
foreign language options for instruction. ments. The control unit 1100 alloWs for the input of a
300 Presents all authorized taxi companies, rotating selection. This information is then processed by the com
advertisements and instructions. puter 1200 using the TAXILINK softWare program 1210.
400 Instructs user to enter the number of passengers Card Reader 1300 is provided to process credit or debit card
travelling.
500 Displays all advertised Destination options in accounts depending on the type of payment desired. This
their respective category Which Will illuminate system Will transmit the information to a dispatcher via
When active. telecommunication lines 1500. A modem 1220 to contained
600 Additional information on destination and change to expedite additional bidirectional communication. A
pick option.
700 Form of Payment screen exhibits an approximate
printer 1400 Will produce a receipt for the entire transaction.
fare, instructions and all payment options 45 All of these component parts are embodied in a Fixture Unit
honored by the system. 1600 along With provisions for Advertisement 1700 and
800 The Conformation screen exhibits and accepts any Security Camera 1800 system. A PoWer Connection 1900
change to previous selections along With playing
a prerecorded video message. supplies the unit and Display light 2000 With electricity.
900 Dispatch of Service, places a dispatch call and Referring noW to FIG. 3, 3A, and 3B, possible distribution
displays approximate arrival time of taxicab or embodiments for the system are shoWn. The Automated
other requested vehicle. Vehicle Dispatch And Payment Honoring System in accor
910 Displays exit message.
dance With the present invention is distributed to serve
numerous locations and users. Request for services can be
As per FIG. 1A and step 100, a customer Would touch the processed via several different types of remote units. The
active START button on the screen to begin the Taxilink 55 ?xture Unit 2000A, as shoWn in FIG. 3A, is designed as a
program. The ?rst option 200 Will alloW the user to select the standing unit to compliment the surroundings Which it
instructions in the language desired from a menu of lan occupies. This units design implements the same types of
guage. On the folloWing screen, all authoriZed taxi compa ?nishes Which may exist in the intended area (i.e. lobbies,
nies Would appear along With other information and/or banks, theme parks, restaurants, stadiums, etc.). FIG. 3
advertisements. On the folloWing screen, all authoriZed additionally shoWs a Wall Mounted Unit 2000B can offer
and/or advertisements. Here the user Will Select a Com service to areas Where space is limited. Another type of
pany 300 Which Will service the request. The next screen embodiment is a Bank Unit System 2000C, as shoWn in FIG.
400 alloWs the user to enter the Number of Passengers 3B, Which is designed to provide more service to high
travelling. This feature Will enable the contacted dispatcher volume areas (i.e.: airports, convention centers, theme parks,
to send the correct vehicle to properly service the request. 65 sporting facilities, etc.).
On the next screen 500, a map of Destinations appears In the event there is already an Existing Host Unit 2000D,
along With the main category types (i.e.: Attractions, the TAXILINK program can process requests for service

EXHIBIT A
Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 16 of 23 Page ID #:16

5,973,619
5 6
from the same unit via incorporation of the Taxilink software thereby alleviating this extra Worry and hassle from the
and telecommunication connection. Another type of host rigors of travel.
system, the Interactive Television System 2000B, can reach Moreover, While private cars might be hailed by this
more customers by offering the service to their homes. The system, the user is able to choose from a reputable transport
ability to prearrange a request for service from another city, company Without being accosted by unscrupulous private
state or country can be offered through the internet via the car operators Which are illegal in some areas. Foreign
On-Line 20001:, which Will extend the systems use World travelers are often targets for overcharging and inef?cient
Wide. routing by some transport operators. By speci?cally being
able to request a vehicle from a chosen company, the user
The bene?ts of the invention, include but are not limited can ignore solicitations from other drivers With the security
to the following: 10
of knoWing that his chosen vehicle Will arrive as requested.
Provides for a more informed customer Other objects and advantages of this invention Will
Displays all permitted Taxi companies at a glance become apparent from the folloWing description taken in
Provides additional information on prospective destina
conjunction With the accompanying draWings Wherein are
tion.
set forth, by Way of illustration and example, certain
15 embodiments of this invention. The draWings constitute a
Displays an Approximate fare part of this speci?cation and include exemplary embodi
Improves driver safety ments of the present invention and illustrate various objects
Improves traf?c congestion and feature thereof.
Increases customer safety I claim:
1. Amethod as implemented on a computer system for use
Promotes taxi industry by a consumer, said method for delivering instructional
Promotes commerce messages to said consumer regarding private transportation
Improves services to foreign customers companies and estimated costs for hiring said transportation
AlloWs taxi companies to better target their advertisement company for transporting said consumer to listed destina
25 tions and further providing an automated taxi dispatch and
to their prospective customers
Enables taxi companies to secure corporate/personal ser payment honoring system, said method comprising the steps
vice accounts of:
Give local merchants another means to prospective cus
(1) displaying a list of authoriZed transportation compa
nies for selection by the operator of the computer;
tomers
2) prompting the consumer to insert the amount of pas
Provides for more Civic Directories
sengers to be traveling in the transportation vehicle;
Increase parking revenue by reinstating metered parking (3) graphically illustrating destination locations;
stalls (4) displaying the approximate fare for the number of
Reduces the parking demand at a facility passengers promoted to a selected destination and types
35
Reduces the risk of taxi fare pirating of payment options honored by said selected company;
Increases dispatchers ef?ciency (5) initiating a dispatch call for an available taxi from said
While the above described embodiments disclose a taxi selected taxi company;
stand unit and related softWare program, the invention could (6) estimate the approximate arrival time for said dis
readily be used to summons any other type of transportation patched taxi.
service, including but not limited to shuttlebuses, 2. The method of claim 1, Wherein said instruction mes
limousines, private cars for hire, city buses and other types sages may be delivered in various foreign languages.
of vehicles for hire. This Would involve yet another menu 3. The method of claim 1, Wherein said destination
choice of the type of service desired. The dispatcher Would locations selected on said computer system illuminate When
then route the appropriate vehicle to the requester, or the 45 selected.
appropriate vehicle might directly respond via receiving 4. The method of claim 1 including the step of displaying
equipment on-board the vehicle. additional information on said destination locations.
Also, as mentioned above, this automated vehicular 5. The method of claim 1 Wherein said destination loca
requesting service could be used WorldWide via on-line tions is characteriZed as attractions, restaurants, hotels and
connection to the internet or some other board-coverage neighborhoods.
transmission medium. The user might maintain On-Line 6. The method of claim 1 Wherein said graphically illus
2000F interface softWare and use it to send an appropriate trating destination locations includes an enlarged map With
request to a corresponding dispatching service. streets names and directions to said locations.
Alternatively, the user could access the interface softWare 7. The method of claim 1 Wherein a con?rmation display
via an internet or telephonic connection Whereby the user is 55 of the transportation company, fare, number of passengers,
cued for information and an appropriate request for a vehicle and selected destination is illustrated.
is processed. This Would alloW the user to place a request
from half-Way across the World for a speci?c date and time,

EXHIBIT A
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 17 of 23 Page ID #:17

EXHIBIT B
Infringement of Claim 1 of U.S. Patent Number 5,973,619 by Uber Technologies, Inc.
Note: References to the numbers used solely for the designation of component figures of a preferred embodiment of the '619 Patent are
omitted from all citations to the patent claims below.

CLAIM LANGUAGE Infringing Application

Uber Technologies, Inc. ("Uber") develops, uses, sells, implements, and distributes systems and software
solutions that connect consumers with independent private car operators. Consumers can choose to group with
others using a passenger application developed by Uber called "Uber," which allows multiple consumers each
potentially with a different destination to share a ride on a single vehicle. Independent private car operators
utilize their own driver-only application called "Uber Driver" that allows the operators to determine their
vehicle's availability, accept service calls, and manage a variety of payment methods used by passengers. Uber
1. A method as implemented on provides the server space, programming integration, and communicative coordination between the
a computer system for use by a independently-operating passenger applications and driver applications, and specifically disseminates passenger
consumer, said method for ride requests to a select fleet of available operators.
delivering instructional
messages to said consumer
regarding private transportation
companies and estimated costs
for hiring said transportation
company for transporting said
consumer to listed destinations
and further providing an
automated taxi dispatch and
payment honoring system, said
method comprising the steps of:

Page 1 of 7

EXHIBIT B
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 18 of 23 Page ID #:18

EXHIBIT B
The Uber passenger application shows the user a graphical representation of the authorized independent car
operators Uber may select for the ride, based on their proximity to the user, their availability, and their service-
type registration (e.g. UberX, SELECT, BLACK, etc.).

(1) displaying a list of authorized

transportation companies for
selection by the operator of the
computer;

Page 2 of 7

EXHIBIT B
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 19 of 23 Page ID #:19

EXHIBIT B
The Uber passenger application prompts the user to indicate how may seats they will need to occupy in the
independent operator's vehicle.

(2) prompting the consumer to

insert the amount of passengers
to be traveling in the
transportation vehicle;

Page 3 of 7

EXHIBIT B
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 20 of 23 Page ID #:20

EXHIBIT B
The Uber passenger application prompts the user with several contextually-sensitive locations they can pick as a
destination. Once selected, the application shows the user a distinctly-colorized marker for their desired
destination, which appears on a map from data made available by Uber remotely.

(3) graphically illustrating

destination locations;

Page 4 of 7

EXHIBIT B
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 21 of 23 Page ID #:21

EXHIBIT B
Once a destination is selected, the Uber application presents the user with an approximate cost for the ride, the
confirmed number of seats the user is requesting, and the method of paying for the ride that the independent
operator is required to honor.

(4) displaying the approximate

fare for the number of
passengers promoted to a
selected destination and types of
payment options honored by said
selected company;

Page 5 of 7

EXHIBIT B
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 22 of 23 Page ID #:22

EXHIBIT B
When the user presses the "REQUEST" button on their passenger application, Uber distributes an open request to
selected independent operators to provide their vehicle for the fare.

(5) initiating a dispatch call for

an available taxi from said
selected company;

Page 6 of 7

EXHIBIT B
 Case 2:17-cv-03028 Document 1 Filed 04/21/17 Page 23 of 23 Page ID #:23

EXHIBIT B
Once an independent operator accepts Uber's request for providing their vehicle in satisfaction of the user's fare,
the user can view the approximate location of the operator's vehicle and the estimated time of the vehicle's arrival
to their location.

(6) estimate the approximate

arrival time for said dispatched
taxi.

Page 7 of 7

EXHIBIT B