MEMORANDUM & ORDER Plaintiff Hayden AI Technologies, Inc. brought this suit against Safe Fleet Holdings LLC, Safe Fleet Acquisition Corp., and Seon Design (USA) Corp. (a subsidiary of Safe Fleet Holdings LLC). Hayden holds certain patents for an automated bus lane enforcement, or “ABLE,” system — a system to detect and report traffic violations in bus lanes.1 The Safe Fleet defendants offer a competing product called “ClearLane.” Hayden alleges that ClearLane infringes one of its patents, and has moved for a preliminary injunction, contending that post-trial damages cannot adequately compensate for the harms Safe Fleet’s alleged infringement will cause while this suit is pending. As set forth below, the motion is denied because Hayden has not shown a reasonable likelihood of success on the merits. I. Background2 A. Hayden’s ABLE System Hayden’s ABLE system is a mobile platform designed to detect potential bus-lane violations (e.g., a car driving or parked in a bus lane) and facilitate enforcement. Decl. of Christopher Carson (“Carson Decl.”)
2-9, ECF No. 16-13.3 According to Hayden’s Chief Executive Officer, its ABLE system has five primary features: (1) it uses cameras mounted inside buses, together with “AI technology” to identify the road, vehicles, and other objects; (2) it detects potential traffic violations based on “traffic rules” that the system has “learned”; (3) after detecting a potential violation, the system captures license plate information and processes the relevant data into an “evidence package”; (4) it sends that package to Hayden’s AI-supported cloud server for processing; and (5) Hayden then transmits the package to the relevant law enforcement agency for review and enforcement. Id. 9. In October 2022, the Metropolitan Transit Authority (“MTA”) awarded Hayden a contract to install its ABLE system on 300 New York City buses, with an option to expand to an additional 200 buses. Id. 27. Hayden installed the initial 300 units between August and December 2022. Id. 28. B. The Patents-in-Suit Since its founding in 2019, Hayden has obtained three patents; in its Third Amended Complaint, ECF No. 80, it references two patents covering its ABLE system — U.S. Patent No. 11,003,919 (the “’919 patent”) and Patent No. 11,164,014. Only the ’919 patent is at issue for the purposes of Hayden’s preliminary injunction motion. Pl. Br. in Supp. of Prelim. Inj. (“Pl. Br.”) 5, ECF No. 16-1.4 The ’919 patent is entitled “Systems and Methods for Detecting Traffic Violations Using Mobile Detection Devices” and was issued on May 11, 2021. ECF No. 1-1. The patent application describes “an improved traffic violation system” that “addresses the challenges faced by traditional traffic violation detection systems” in order to “improve traffic safety and enable transportation efficiency.” Id. at 1:47-53. Generally, the ’919 patent system collects and processes video data, uses that data to assess potential traffic violations, and transmits that information to a centralized server which can “generate a simulation of the traffic violation utilizing a game engine.” Id. at 6:18-21. That server then uses its “reasoning engine” to decide whether any “mitigating events” should preclude a determination that a traffic violation occurred, and arrives at an assessment. Id. at 6:21-25. C. Safe Fleet’s ClearLane System and the Siemens ABLE System In 2018, Seon Design (USA) Corp. — a wholly owned subsidiary of defendant Safe Fleet Holdings LLC — began discussions with the MTA about supplying an ABLE system. Decl. of Daniel Pulskamp (“Pulskamp Decl.”)
