In re Bill of Lading Transmission and Processing Sys. Patent Lit.

R+L Carriers, Inc. (R+L) (plaintiff) owned United States Patent No. 6,401,078 (the 078 patent), which described an automated business method for optimizing trucking practices by scanning and sending shipping documents from the truck to a dispatcher while the truck was in use. After suing several companies in federal court for indirect patent infringement of the 078 patent, R+L filed amended complaints against DriverTech LLC; Affiliated Computer Services, Inc.; PeopleNet Communications Corp.; Intermec Technologies Corp; Microdea, Inc.; and Qualcomm, Inc. (collectively, the software companies) (defendants). R+L’s amended complaints made various assertions of fact and included a section for reasonable inferences that R+L explained could be drawn from the pleaded facts, showing that the software companies intended for customers to infringe the 078 patent and knew that the acts were infringing. The amended complaints charged the software companies with both contributory infringement and induced infringement of the 078 patent. The amended complaints stated that the method patented under the 078 patent could be used for purposes such as increasing bill-payment speed, tracking a truck’s location, and monitoring the conditions of a truck. The software companies jointly filed a motion to dismiss R+L’s amended complaints for failure to state a claim. The district court granted the motion to dismiss for all R+L’s claims. R+L appealed.