The U.S. Court of Appeals for the Federal Circuit, on June 7, 2012, released its opinion in In re Bill of Lading Transmission and Processing System Patent Litigation, No. 2010-1493, reversing, for the most part, dismissals of six complaints brought by the same patent owner against different parties. In doing so, the Federal Circuit clarified, and likely greatly liberalized, the pleading standard for many patent infringement cases.
Background
The plaintiff in all six cases, R+L Carriers Inc., owns a patent directed to the trucking industry, specifically to “less-than-a-full-load” trucking. Carriers in the trucking industry pick up freight from different customers, often destined for different locations around the country. To enable efficient delivery, the freight is typically taken to a central terminal, re-sorted by destination, and then re-loaded onto trucks with freight that is destined for a similar location. The patent-in-suit claims a method to make this system more efficient. Specifically, it claims a method that “automates the process of receiving transportation documentation and producing advance loading manifests,” by enabling shipping documents to be sent directly from the truck to the central terminal, so billing and load planning can occur while the driver is en route with the freight.
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