Agis Software v. Lyft: Federal Circuit Affirms Patent Unpatentable (23-2237)
Agis Software Development, LLC asserted US10299100B2 — covering methods for ad hoc and password-protected digital and voice networks — against Lyft, Inc. The Federal Circuit issued a Rule 36 affirmance, upholding the finding of unpatentability after 676 days of appellate proceedings. The ruling extinguishes the patent’s enforceability.
Federal Circuit kills Agis Software’s ad hoc network patent via Rule 36
Agis Software Development, LLC, a patent assertion entity holding US10299100B2, brought an appeal before the United States Court of Appeals for the Federal Circuit (Case No. 23-2237) after a lower-level invalidity or cancellation proceeding found the patent unpatentable. The patent, filed under application number US15/722660, covers methods for providing ad hoc and password-protected digital and voice networks — a technology area with relevance to mobile coordination platforms including ride-hailing services such as those operated by defendant Lyft, Inc.
The Federal Circuit issued its decision on June 9, 2025, affirming the unpatentability finding under Federal Circuit Rule 36 — a summary procedure that disposes of an appeal without a written opinion when the court finds no reversible error. The affirmance means the lower tribunal’s cancellation or invalidity determination stands in full, and US10299100B2 is no longer enforceable. Agis Software’s effort to preserve the patent through appellate review was entirely unsuccessful, while Lyft secured a complete victory on the validity question.
The 676-day duration from filing to disposition is notable for a Rule 36 affirmance, suggesting the court may have required meaningful deliberation before concluding no written opinion was warranted. Because Rule 36 affirmances carry no precedential weight and provide no reasoning, the public record is silent on which specific invalidity grounds prevailed and whether any claim arguments gave the panel pause. The lack of a written opinion limits the ability of third parties to draw doctrinal inferences from this outcome.
Filing to Unpatentable in 676 days
676 days — longer than the Federal Circuit median for Rule 36 summary affirmances
Federal Circuit affirms: what the unpatentability ruling means for both parties
A Rule 36 affirmance: no error found, no opinion issued
Federal Circuit Rule 36 allows the court to affirm a lower decision with a single-line judgment when it unanimously finds no reversible error and no need for a written opinion. The affirmance in this case means the Federal Circuit reviewed the unpatentability determination and found it legally sound. Crucially, it creates no precedent — no claim construction, no § 103 analysis, and no procedural ruling is preserved for future cases. The lower tribunal’s invalidity finding stands in its entirety.
Rule 36 — no written opinionUS10299100B2 is cancelled — Agis loses enforcement leverage entirely
For Agis Software Development, the affirmance is outcome-determinative. US10299100B2 — the foundation of this dispute — has been found unpatentable, stripping Agis of any right to assert it in current or future litigation. Any co-pending cases relying on this patent are now exposed to the same invalidity finding. The Rule 36 form of affirmance also forecloses a meaningful rehearing argument, as there is no written reasoning to challenge on en banc petition.
Patent cancelled — unenforceableLyft secures a clean invalidity win with no written opinion to relitigate
Lyft, represented by Baker Botts LLP, achieved the strongest possible appellate outcome: a full affirmance of unpatentability without any surviving claim or remand instruction. Because the Federal Circuit issued no written opinion, there is no appellate reasoning that Agis could use to reframe arguments in separate proceedings. For Lyft’s legal team, the absence of a written opinion also means no adverse dicta that could complicate future IP disputes in the mobile network or coordination technology space.
Full appellate victory for LyftPAE enforcement risk in mobile coordination tech reduced — but only for this patent
The cancellation of US10299100B2 removes one enforcement vector in the ad hoc digital and voice network space. Companies operating mobile coordination or location-sharing platforms — including ride-hailing, delivery, and fleet management services — should note that Agis Software’s portfolio may contain related patents. The Rule 36 affirmance provides no claim construction guidance that would clarify the scope of related family members, meaning residual portfolio risk from Agis warrants continued monitoring.
Monitor Agis portfolio for related patentsFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Agis Software Development, LLC | Company | Patent assertion entity — holder of US10299100B2 covering ad hoc digital and voice network methodsSearch in Eureka ↗ |
| Defendant | Lyft, Inc. | Company | Lyft, Inc. — U.S. ride-hailing and mobility platform; prevailed on unpatentability challengeSearch in Eureka ↗ |
| Plaintiff counsel | Alfred Ross Fabricant | Attorney | Counsel for Agis Software Development, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Enrique William Iturralde | Attorney | Counsel for Agis Software Development, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Peter Lambrianakos | Attorney | Counsel for Agis Software Development, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Vincent J. Rubino , III | Attorney | Counsel for Agis Software Development, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Fabricant LLP | Law Firm | Representing Agis Software Development, LLCSearch in Eureka ↗ |
| Defendant counsel | Bethany Salpietra | Attorney | Counsel for Lyft, Inc.Search in Eureka ↗ |
| Defendant counsel | Brianna L. Potter | Attorney | Counsel for Lyft, Inc.Search in Eureka ↗ |
| Defendant counsel | Eliot Damon Williams | Attorney | Counsel for Lyft, Inc.Search in Eureka ↗ |
| Defendant counsel | Jeremy Taylor | Attorney | Counsel for Lyft, Inc.Search in Eureka ↗ |
| Defendant law firm | Baker Botts LLP | Law Firm | Representing Lyft, Inc.Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Court of Appeals for the Federal CircuitSearch in Eureka ↗ |
Official order — verbatim text
The single-line judgment — ‘AFFIRMED. See Fed. Cir. R. 36.’ — is the Federal Circuit’s most summary form of disposition. It confirms that a panel of at least three judges reviewed the invalidity or cancellation determination below and found no reversible error under any applicable standard, whether de novo for legal conclusions or substantial evidence for factual findings on patentability. Critically, the Rule 36 form means no claim construction, no prior art analysis, and no procedural holding is articulated. Neither party can cite this judgment as persuasive authority in future proceedings. For Agis, appellate options at this level are exhausted; for Lyft, the cancellation is now final.
US10299100B2 — Ad Hoc and Password-Protected Digital and Voice Network Methods
US10299100B2, filed under application number US15/722660, claims methods for providing ad hoc and password-protected digital and voice networks — a technology directed at enabling dynamic, on-demand network formation among mobile devices without requiring pre-established infrastructure. This patent sits at the intersection of mobile communications, network security, and real-time coordination, making it relevant to any platform that dynamically connects users or devices in the field. The patent was granted as B2 designation, indicating it was examined with prior art citations considered.
From a competitive intelligence standpoint, ad hoc network patents have attracted significant PAE enforcement activity in the mobile and location services sector. US10299100B2’s claims on password-protected network formation could, if valid, have affected a wide range of coordination applications — from ride-hailing dispatch to fleet management and peer-to-peer communication tools. Its cancellation following Federal Circuit affirmance removes a licensing risk vector for companies in those spaces, though Agis Software’s assertion history suggests it pursues related family members aggressively.
Should your product team run an FTO against US10299100B2?
US10299100B2 has been found unpatentable and is no longer enforceable. However, R&D and product teams building ad hoc networking, mobile coordination, or password-protected device-grouping features should not stop at this single patent. Agis Software Development has demonstrated a pattern of asserting patents in this technology cluster, and related family members or continuation patents may cover overlapping claim territory. Any new product in the dynamic network formation or mobile push-to-talk space warrants a fresh FTO review against the full Agis portfolio.
PatSnap Eureka’s FTO Search Agent can map the claim landscape around ad hoc and password-protected network methods, identify surviving Agis family patents, and surface prior art that has already proven effective against this patent family. By querying US15/722660 and related continuation chains, IP teams can quickly assess residual exposure before product launch — without waiting for the next enforcement letter.
Run a freedom-to-operate analysis on US10299100B2 to assess your product’s exposure
Run FTO in Eureka →Similar Federal Circuit patent invalidity cases in mobile network technology
Explore Federal Circuit appeals involving PAE-asserted mobile networking and ad hoc communication patents with comparable invalidity outcomes and Rule 36 disposals.
What this case signals for the mobile network patent enforcement landscape
A PAE patent on ad hoc network methods is cancelled at the Federal Circuit — here is what IP teams in mobile and coordination technology should take away.
Rule 36 disposals offer defendants certainty but zero doctrinal clarity
When the Federal Circuit affirms under Rule 36, the underlying invalidity holding is final and binding on the parties — but it sets no precedent. IP teams tracking the ad hoc network space cannot extract claim scope or prior art conclusions from this ruling. Monitor the original cancellation or IPR record for the substantive invalidity grounds that persuaded both tribunals.
Agis Software’s remaining portfolio warrants active monitoring post-cancellation
Patent assertion entities typically hold multiple related patents. The cancellation of US10299100B2 does not neutralise Agis Software’s broader portfolio. R&D teams and product counsel at ride-hailing, fleet, and mobile coordination companies should run a freedom-to-operate review against Agis’s remaining holdings to assess whether related family members cover similar ad hoc or location-sharing network methods.
Agis v Lyft — key questions answered
The Federal Circuit affirmed the unpatentability of US10299100B2 under Rule 36, issuing a summary one-line judgment with no written opinion. The affirmance upholds the lower tribunal’s invalidity or cancellation finding in full, and the patent is no longer enforceable. The case was closed on June 9, 2025 after 676 days.
A Rule 36 affirmance means the Federal Circuit found no reversible error in the decision below but declined to write a substantive opinion. The lower ruling — here, that US10299100B2 is unpatentable — is fully upheld and binding on the parties. However, a Rule 36 judgment has no precedential value; it cannot be cited by third parties in future proceedings and provides no guidance on claim scope or prior art.
US10299100B2 covers methods for providing ad hoc and password-protected digital and voice networks — technology enabling dynamic, on-demand mobile network formation. Lyft, as a mobile coordination platform connecting drivers and riders, was presumably alleged to practise features of this network formation method. The patent was filed under application US15/722660 and was asserted by Agis Software Development, a patent assertion entity.
After a Federal Circuit Rule 36 affirmance, Agis Software’s options are narrow. It could petition the Federal Circuit for en banc rehearing, though the absence of a written opinion makes that avenue difficult to frame. A petition for certiorari to the U.S. Supreme Court is theoretically available but rarely granted in patent invalidity cases lacking a circuit split or novel legal question. Practically speaking, the cancellation of US10299100B2 is final.
Agis Software Development was represented by Fabricant LLP, with attorneys Alfred Ross Fabricant, Enrique William Iturralde, Peter Lambrianakos, and Vincent J. Rubino III on record. Lyft was represented by Baker Botts LLP, with Bethany Salpietra, Brianna L. Potter, Eliot Damon Williams, and Jeremy Taylor as counsel of record.
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