SP Plus Corporation v. IPT, LLC

SP Plus Corporation v. IPT, LLC 2-16-cv-02474 (E.D. La., May 19, 2017) 


  • 7,950,570 | Entitled “Parking Management System and Method”
  • 7,988,046 | Entitled “Vehicle Violation Enforcement System and Method”


Motion for Judgment on the Pleadings under FRCP 12(c) Granted

Abstract Idea:


Something More:



Process for enforcing parking violation penalties through self-release parking boots 


The patents were found to be directed to the abstract idea of expediting the vehicle immobilization process via self-service. Although Defendant argued that the patents claimed the “novel apparatus” of a self-releasing boot, the Court noted that the claims themselves never go into the technical specifications of the self-releasing boot. Rather, the claims describe the boot with no more specificity than “a locking boot having a unique code.” Further, neither patent claimed an inventive concept. The Court found that there was nothing inherently inventive about the inclusion of several technological devices, such as RFID, and reciting their functions.