On September 23, the federal judge overseeing the patent infringement litigation brought by Municipal Parking Services Inc. (MPS) against the parking compliance company Parking Revenue Recovery Services Inc. (PRRS) and parking operator LAZ Parking denied a motion by PRRS to dismiss the case.

In early June, MPS — the maker of the SafetyStick and other automated parking detection and violation enforcement equipment — filed suit in the U.S. District Court for the Western District of Texas alleging that PRRS and its customer LAZ are infringing five MPS patents pertaining to automated parking lot monitoring and management systems. Given the growing use of such systems in the U.S. parking industry, the outcome of the case could significantly affect the automated parking monitoring and enforcement sector. 

The MPS patents 

The suit references the following five MPS patents covering parking lot monitoring and management systems issued between 2018 and 2025:  

• U.S. Patent No. 10,121,172, “Parking Lot Monitoring System” (November 6, 2018)  
• U.S. Patent No. 11,257,302, “Parking Meter System” (February 22, 2022)  
• U.S. Patent No. 11,688,205, “Parking Meter System” (June 27, 2023)  
• U.S. Patent No. 12,142,085, “Parking Meter System” (November 12, 2024)  
• U.S. Patent No. 12,249,187, “Parking Meter System” (March 11, 2025)  

The patents “relate to, among other things, novel methods to monitor parking facilities and enforce violations,” according to MPS’s lawsuit.  

MPS’s Patent ‘172 “relates to lot and ramp payment management systems and payment methods, more particularly, to parking structures monitored by vehicle identification devices interacting with a payment monitoring and acceptance system,” according to the patent.  

Patents ‘302, ‘205, ‘085, and ‘205 relate “to parking meters, and more particularly, to automated parking meter systems,” according to the patents.   

In its suit, MPS alleges that PRRS has infringed its patents by “directly or indirectly, by making, using, offering to sell, selling, and/or importing automated parking monitoring and management systems/services… for and/or at parking facilities of its customers throughout the United States,” according to the lawsuit. 

As for LAZ, MPS alleged that the company “uses and/or induces others to use automated parking monitoring and management systems/services purchased and/or licensed from PRRS, and in doing so infringes, directly and/or indirectly, claims of the Patents-in-Suit,” according to MPS’s claim. 

PRRS’s motion 

On July 23, PRRS submitted a motion to the court to dismiss the case on the grounds that MPS’s patent claims are “ineligible for patent protection under Supreme Court and Federal Circuit jurisprudence,” according to the motion. 

In a key claim, PRRS contends that MPS’s patents do not satisfy the eligibility framework previously established by the U.S. Supreme Court in the 2014 patent eligibility case Alice Corp. v. CLS Bank International, which is commonly known as Alice. In the case, the Supreme Court held that abstract ideas implemented on generic computer systems are not patentable. To be patentable under 35 U.S.C. Section 101, business methods must demonstrate a specific technological improvement or solve a technical problem, not just automate conventional business practices.  

Citing this precedent, PRRS argues that the claims asserted in MPS’s patents “are directed to the abstract idea of recording information (at two points in time), transmitting it, and presenting certain results from the analysis of the recorded information,” according to the motion. “There is no technological advance, such as novel computer or camera hardware, character recognition software, or other basis to argue the claim is eligible. The Asserted Claims are conventional on their face because they simply recite steps that have long been performed by parking lot personnel using nothing but their eyes, a piece of paper, a pencil and a phone, and simply require those same steps to be performed with conventional cameras and computers.” 

At the same time, the claims in MPS’s patents contain “no inventive step” that would make them eligible under the framework set forth by Alice, according to PRRS’s motion. 

Motion denied 

On September 23, the court indicated in a statement that the presiding judge on the case — Judge Alan D. Albright — intends for the case to proceed. Albright “denies the motion without prejudice for Defendant to reraise at a later stage,” according to the court’s statement.  

Albright “finds issues of patentability under [35 U.S.C. Section 101] are more appropriately resolved at [motion for summary judgment] than under a 12b motion,” according to the court’s statement. [A 12(b) motion refers to Rule 12(b) of the Federal Rules of Civil Procedure, which allows defendants to challenge a lawsuit in various ways early in the case, before having to file a full answer to the complaint.] 

The judge’s ruling suggests that Alice challenges may be revisited later via motion for summary judgment, though the specific timing and procedural steps will depend on how the parties and court choose to proceed. 

Meanwhile, the court has yet to rule on a separate motion filed by PRRS on July 23 to dismiss the case on the grounds of improper venue or transfer it to the U.S. District Court for the District of Colorado. PRRS is incorporated within Colorado and maintains its principal place of business there, according to the motion. 

The court also has not ruled on a separate motion to dismiss filed by PRRS and LAZ on September 3. 

PRRS responds to ‘false’ statement 

When contacted by Parking Today for this story, PRRS declined to comment on the court’s action, which occurred just days after the company issued a news release related to the ongoing litigation. In its September 18 release, PRRS noted it was responding to what it said were “false, misleading, and threatening statements” made by MPS related to the lawsuit. 

In particular, PRRS maintained “employees of MPS have publicly stated that PRRS and its customers can’t provide video monitoring any longer,” according to the September 18 release. “This statement is false.” 

“PRRS has been in the business of monitoring and ensuring compliance with facility use rules for much longer than MPS, including prior to the dates of the MPS Patents,” the company said in its release.  LAZ did not respond to a request for comment for this story.

“Our patents and our case speak for themselves,” said Joe Caldwell, the CEO for MPS, in a statement provided to Parking Today. He declined to elaborate further, citing the pending litigation. 

Jay Landers is the editor-in-chief of Parking Today. He can be reached at [email protected].   

Editor’s note: The court’s ruling sets the stage for continued litigation in the case on potentially multiple fronts, so be sure to check regularly for updates on parkingtoday.com.