Open Parking, LLC v. ParkMe Inc.

Open Parking, LLC v. ParkMe Inc., No. 2-15-cv-00976 (Hornak, D.J.) (W.D. Pa. Jun. 30, 2016) 


6,501,391 | Entitled, “Internet communication of parking lot occupancy” 
6,750,786 | Entitled, “Systems and methods for internet communication of parking lot information”


Grant of Defendant’s Motion to Dismiss for ineligible subject matter under § 101.  

Abstract Idea:


Something More:



Systems for gathering data on parking availability and notifying portable devices.  


The court rejected plaintiffs’ constructions, finding the plain and ordinary meaning sufficient to resolve the patents’ validity. The court concluded the claims were directed to the abstract idea of “the transmission of substantially real time data of whether there are any open parking spaces in a given lot.” Such claims are part of a long tradition or organizing human activity, analogous to maintaining medical records or collecting clinical trial data, subject matter that has been found patent ineligible. The claims were not directed to problems unique to the Internet or mobile devices. No inventive concept was added.