Lab Technology LLC v. Greenlight Financial Technology, Inc.

I'll research this case and the asserted patent using web searches.

Let me dig deeper into the parties, the patent's litigation history, and related cases.

Let me verify the judge, the docket timeline, and prior rulings on this patent.

Case Overview and Background

The parties. Plaintiff Lab Technology LLC is a New Mexico limited liability company (principal place of business: 1209 Mountain Rd Pl NE, Albuquerque, NM) formed in January 2024 and is, on the available record, a non-practicing patent-assertion vehicle rather than an operating company — it makes no products and its only visible activity is patent enforcement. Its Delaware counsel of record in this matter is Brian E. Lutness (Silverman, McDonald & Friedman), with Isaac Rabicoff (Rabicoff Law LLC) identified in related filings as the campaign's lead filer (VitalLaw, IP Law Daily, July 30, 2026; Mondaq, "Yet Another New Mexico Plaintiff Launches Patent Litigation," May 31, 2024). Defendant Greenlight Financial Technology, Inc. is a Delaware-incorporated, Atlanta-based fintech founded in 2014 by Tim Sheehan and Johnson Cook. Greenlight sells a parent-managed MasterCard debit card plus "Kids & Teen Banking" mobile app (card issued through Community Federal Savings Bank), with roughly $556M raised, a $2.3B 2021 valuation, and a reported ~6.5 million parent/child users; it also licenses the product to banks, credit unions, and employers (TechCrunch, Oct. 12, 2022; Banking Dive interview with CEO Sheehan; CB Insights company profile).

The patent and the accused technology. The sole patent-in-suit is U.S. Patent No. 9,219,982, "Apparatus and Method for Automatically Refreshing a Display of a Telephone," issued December 22, 2015 from Application No. 14/730,866, a continuation of the '084 and '067 applications with a June 22, 2006 priority date; the sole named inventor is Shin Cheung Simon Chiu, and the family originated with TP Lab, Inc. In one sentence: the '982 patent claims a telephone that pings a remote "location server," selects a stored "function" tied to the phone's current location (and user), and automatically refreshes the display with the communication services associated with that function — i.e., a context- or location-aware phone UI. Lab Technology asserted independent claim 13 (the method counterpart to apparatus claim 1) against the Greenlight Kids & Teen Banking app, with a claim chart relying on GPS and network-based triangulation for the location determination (VitalLaw; Justia Doc. 35).

Posture, venue, and why it matters. Filed November 6, 2025 in the District of Delaware as No. 1:25-cv-01356-JCB before visiting Judge John Campbell Barker (E.D. Tex., sitting by designation in D. Del. — one of 11 D. Del. patent cases reassigned to him around May 2025 per the IP/DE blog). Delaware venue was straightforward: Greenlight is a Delaware corporation, so §1400(b)/TC Heartland posed no obstacle — the classic reason NPEs name Delaware entities there even when the operating business is in Georgia. Greenlight first moved to dismiss, Lab Technology amended (Doc. 18, apparently April 6, 2026), and Greenlight moved again on two grounds: prosecution disclaimer and §101 ineligibility. The court denied the disclaimer theory (Doc. 35, reasoning the applicant distinguished a remote "location server" from self-contained GPS/triangulation in the prior art, and that the overlap question was premature), but granted dismissal on §101, holding at Alice step one that the claims are directed to the abstract idea of "displaying different content on a telephone based on that telephone's location," and at step two that filtering content on generic computer components adds no inventive concept. Leave to amend was denied as futile, and the case was dismissed with prejudice on July 23, 2026 (VitalLaw; Justia Doc. 35).

Why it is notable. Three things stand out. First, it is a rare early-stage §101 kill in a Delaware NPE suit decided on the pleadings, and part of a measurable pattern for this judge — IP/DE's "101 Year in Review" tallies Judge Barker at 3/3 patents invalidated on §101 motions. Second, it is a test of dueling precedent on the same patent: the case summary's predecessor sections note that Lab Technology has leaned on two prior rulings sustaining the '982 patent's eligibility — Local Intelligence, LLC v. HTC America (N.D. Cal., Judge Edward J. Davila denied an Alice motion, finding the "specific improvement to user interfaces" not abstract) and an apparently more recent ruling in Lab Technology v. USAA (W.D. Tex., reportedly January 2026) over SafePilot's crash auto-dial feature — yet Judge Barker reached the opposite result, underscoring how outcome-determinative §101 remains on location-based UI claims. Third, it is part of a coordinated multi-defendant campaign over the TP Lab/Chiu family: Lab Technology filed companion D. Del. suits the same day (e.g., Lab Technology v. Everbridge, 1:25-cv-01355, asserting both the '982 patent and 8,503,973), plus actions against Lumen, u-blox, ETA Transit, LifeStation (SDNY, settled Feb. 2026), USAA, Solera (voluntarily dismissed Apr. 2026), MSS Electronics, and Keysight. For fintechs, the case is a data point that context-aware/location-based app features are a live NPE target, but that early §101 challenges can end such suits before claim construction where the claims reduce to a generic-computer abstraction. Commercially, a with-prejudice dismissal here removes a royalty demand from one of the best-funded family-finance apps, though the campaign's other defendants remain exposed.

Sourcing caveats (not fully verified). I could not confirm the existence of any IPR/PGR at the PTAB against the '982 patent, and USPTO assignment records reportedly did not reflect the transfer of the '982 family from TP Lab to Lab Technology as of the May 2024 Mondaq report — so Lab Technology's chain of title rests on its pleading. Several case-history details (the exact dates of the first amended complaint and the USAA eligibility ruling) come from secondary litigation-analytics sources rather than PACER or a primary opinion, and the underlying Rule 12(b)(6) opinion excerpts I relied on are from Justia's copy of Doc. 35; where dates beyond the complaint (11/06/2025) and dismissal (07/23/2026) matter, they should be confirmed against the PACER docket.

I'll research this case and the asserted patent across the sources you named. Let me start with several parallel searches.

Good — I've confirmed the core outcome. Now let me pull the docket, PTAB activity, and prior litigations on the '982 patent.

Bottom line

This case never got past the pleadings. Filed 2025-11-06, it was resolved on 2026-07-23 when Judge Barker (D. Del., case suffix -JCB) granted Greenlight's Rule 12(b)(6) motion, held claim 13 of U.S. Patent No. 9,219,982 ineligible under 35 U.S.C. §101 at both Alice steps, denied leave to amend, and dismissed with prejudice. There was no answer, no counterclaims, no Markman, no discovery, no trial, no PTAB proceeding that I can find, and (as of today) no evidence of an appeal.

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Chronological developments

1. Filing and initial pleadings

Plaintiff's counsel: Brian E. Lutness (Silverman, McDonald & Friedman); Rabicoff Law LLC (Isaac Rabicoff) also appeared per the complaint analysis. Defendant's counsel: Gregory Erich Stuhlman (Chipman Brown Cicero & Cole LLP).

There was no answer and no counterclaims. Greenlight never had to plead; the §101 motion disposed of the case at the pleading stage. I found no Rule 12(b)(3) transfer motion, no stay motion, and no summary-judgment practice — consistent with a case that lived roughly 8.5 months.

2. The dispositive motion — Alice and prosecution disclaimer

Opinion: Doc. 35 (D. Del. 2026-07-23). Reported at Lab Technology LLC v. Greenlight Financial Technology, Inc., No. 1:25-cv-01356-JCB (D. Del. July 23, 2026); VitalLaw/IP Law Daily summary published 2026-07-30.

The court's two holdings:

(a) Prosecution disclaimer — defendant's motion DENIED on this ground. The court held the patentee did distinguish a remote "location server" from the self-contained location tracking of the prior art, and that the examiner had rejected only the applicant's characterization of the prior art, not the applicant's characterization of "location server." Because the record did not show an unequivocal disavowal of all GPS/triangulation techniques — only those in the cited prior art ('313 Patent) — the disclaimer theory failed at the pleading stage. The court expressly reserved the infringement overlap question: "How those techniques overlap with defendant's alleged infringement, though, is a question better resolved at a later stage." It also rejected plaintiff's argument that prosecution history can't be considered on a 12(b)(6) motion (citing Amgen).

(b) Patentable subject matter — GRANTED, claim ineligible.

• Representative claim: Claim 13 (method) held representative of all claims; the court found claim 1 (apparatus) contained the same substantive limitations (Bancorp Servs. v. Sun Life, 687 F.3d 1266, 1276–77 (Fed. Cir. 2012)), and dependent claims added only conventional steps. Plaintiff offered no counter-argument (Doc. 32).
• Alice step one: claims directed to the abstract idea of displaying different content on a telephone based on the telephone's location — a long line of Federal Circuit authority. "Mere automation of manual processes using generic computers" is not a patentable improvement in computer technology.
• Alice step two: no inventive concept — the patent "merely claims the abstract idea of filtering content on a set of generic computer components." No preemption-saving ordered combination.
• The opinion cites Mobile Acuity Ltd. v. ..., 110 F.4th 1290–91 (Fed. Cir.), Beteiro, LLC v. DraftKings Inc., 104 F.4th 1350, 1355 (Fed. Cir. 2024) (quoting Aatrix Software), and Bilski.
• Leave to amend denied as futile — plaintiff had already amended once, and the defect was in the patent's claims/specification, not the pleading.

3. Claim construction (Markman) — did not occur

No Markman stage was reached. The only claim-scope question litigated was the "location server" prosecution-disclaimer issue, raised and rejected in the Daubert-style pleading posture, with the court expressly deferring any construction-dependent infringement analysis.

4. Discovery — none

No scheduling order, no Rule 26 conference, no infringement/invalidity contentions, no expert discovery. The case was decided on the face of the amended complaint, the patent, and the prosecution history.

5. Trial, verdict, post-trial motions — none

No trial, no verdict, no JMOL/new-trial motions, and no fee motion or §285 exceptional-case ruling that I can find. Given the dismissal with prejudice on §101 grounds, a fees motion under Octane Fitness would have been the only remaining substantive avenue — no record of one.

6. Final disposition

2026-07-23: dismissed with prejudice; claim 13 (and all claims) held ineligible under §101; leave to amend denied. This matches the case-metadata termination date. The judgment would have triggered a 30-day Federal Circuit appeal clock (roughly to late August 2026); I found no notice of appeal and no Federal Circuit opinion. Caution: an appeal may exist but not be indexed in the sources searched — this should be verified on PACER/the Federal Circuit docket before being treated as final.

7. Parallel PTAB proceedings — none found

I found no IPR, PGR, or CBM involving U.S. 9,219,982. That is structurally unsurprising:

• PGR is unavailable (patent issued 2015, pre-AIA-eligible window long closed).
• An IPR petition would have had to be filed within one year of service of the complaint under §315(b) — a window that had barely opened before the case was dismissed, eliminating any incentive for Greenlight to file.
• Greenlight won outright at the pleadings, so no stay pending IPR was ever sought or needed.

Flag: the PTAB search was not completed before I ran out of research steps, so treat "no IPR" as not found rather than confirmed absent.

8. Related litigation on the '982 patent (context)

Lab Technology appears to be a Rabicoff-style assertion vehicle that filed a cluster of '982 suits:

• Lab Technology LLC v. Everbridge, Inc., No. 1:25-cv-01355 (D. Del., filed 2025-11-06) — companion filing, '982 and '973 patents.
• Lab Technology LLC v. Lumen Technologies, Inc., No. 7:25-cv-00172 (W.D. Tex.) — voluntarily dismissed 2025-06-24/25.
• Later 2026 filings: v. CallCurrent, Inc., No. 1:26-cv-01122 (D. Del.) and v. MetTel, Inc., No. 1:26-cv-01120 (D. Del.).

Per the complaint's own allegations (as summarized in a third-party complaint analysis, not independently verified), the '982 patent's §101 eligibility had previously been upheld in a 2018 HTC America decision and a 2026-01-30 decision involving USAA. If those rulings exist, Greenlight is a contrary district-court outcome on the same patent — a genuine split that would have made an appeal attractive, and which makes the absence of a docketed appeal notable. This is the single most important item to verify independently.

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Verification notes

• Well sourced: the filing date, case number, judge (Barker/JCB), the July 23, 2026 dismissal with prejudice, the §101 holding at both Alice steps, the denial of the prosecution-disclaimer theory, denial of leave to amend, the appearance of the case at Doc. 35, and counsel (VitalLaw IP Law Daily, 2026-07-30; Justia Doc. 35).
• Not independently confirmed: exact docket entry numbers and dates for the first motion to dismiss and answer-stage events; the 2026-04-06 amended-complaint date (from a third-party AI-generated complaint analysis, which also inconsistently lists "04/06/2026" as the complaint filing date); the HTC and USAA eligibility rulings; and any notice of appeal. All of these should be pulled from PACER (D. Del. 1:25-cv-01356) before being relied upon.

Key URLs: opinion text — https://law.justia.com/cases/federal/district-courts/delaware/dedce/1:2025cv01356/91091/35/ ; VitalLaw decision summary — https://www.vitallaw.com/news/patent-d-del-infringement-case-dismissed-after-patent-for-youth-banking-app-ruled-invalid/ipm0107526d0680f64e55bab66a8737e642b2

I'll research the docket and counsel for the plaintiff in this case.

I have solid initial leads. Let me confirm counsel appearances on the docket and firm details.

Let me verify the docket-level attorney listings and whether Rabicoff appeared in this specific case.

Counsel of Record — Plaintiff Lab Technology LLC

Bottom line: The docketed plaintiff-side representation in Lab Technology LLC v. Greenlight Financial Technology, Inc., No. 1:25-cv-01356-JCB (D. Del.) was Delaware local counsel Brian E. Lutness of Silverman, McDonald & Friedman, with the out-of-state assertion firm Rabicoff Law LLC identified as co-counsel in the complaint papers. I was able to confirm Lutness's role directly from the court's own attorney listing for the July 23, 2026 opinion and from his repeated role in Lab Technology's parallel filings; the Rabicoff identification rests on the complaint's signature-block/counsel line as summarized in a third-party complaint-analysis record rather than a docket entry I could independently verify.

Plaintiff's counsel

Verification notes and caveats

• Confirmed source for Lutness: The attorney line accompanying the court's opinion ("Attorneys: Brian E. Lutness (Silverman, McDonald & Friedman) for Lab Technology LLC. Gregory Erich Stuhlman (Chipman Brown Cicero & Cole, LLP) for Greenlight Financial Technology, Inc."), as published in Bloomberg BNA / VitalLaw's IP Law Daily report of the July 23, 2026 dismissal (PATENT—D. Del.: Infringement case dismissed after patent for youth banking app ruled invalid, Jul. 30, 2026). The opinion itself is Lab Technology LLC v. Greenlight Fin. Tech., Inc., No. 1:25-cv-01356-JCB (D. Del. Jul. 23, 2026) (Barker, J.), available at Doc. 35.
• Not independently confirmed: I could not pull the PACER docket sheet for 1:25-cv-01356 directly (it is not free of charge and the secondary aggregators I reached do not display the attorney block for this specific case). Accordingly, I cannot state Lutness's formal "lead attorney" designation vs. "attorney to be noticed" on this docket as a matter of record; his "lead attorney" designation is confirmed only on the other D. Del. dockets cited above.
• Rabicoff caveat: The Rabicoff Law LLC identification comes from a third-party complaint-analysis record rather than from a docketed appearance notice I verified. It is strongly corroborated by (a) Rabicoff's appearance in every other Lab Technology '982-patent case, and (b) the firm's public pairing with Lutness in the parallel TicketMatrix Delaware campaign, but I have labeled it as such rather than asserting it as docket-confirmed.
• No sealed-filing issue identified. There is no indication in the available record that counsel identities were sealed or that counsel had not yet appeared; a fully briefed motion to dismiss and an amended complaint (Doc. 18) were filed, so appearances were plainly on file. The absence is purely an access limitation on my end, not a sealing issue.
• Attorney count: The record I could reach shows only these two plaintiff-side entities. I found no evidence of a separate "of counsel" or in-house attorney for Lab Technology LLC (an NPE with no in-house legal staff reflected in these filings). I have deliberately not named any individual at Rabicoff Law other than Isaac Rabicoff, whose association with the campaign is documented in the cited reports; if a different Rabicoff attorney signed the 1:25-cv-01356 papers, that would need docket confirmation.
• Minor metadata discrepancy: One automated case-analysis source gives an internal date of "04/06/2026" for this docket, while the complaint was filed November 6, 2025 (the same day as the companion Lab Technology LLC v. Everbridge, Inc., 1:25-cv-01355). The 2026 date appears to correspond to the amended complaint (Doc. 18) in the spring 2026 amendment round. I have treated the November 6, 2025 filing date as authoritative per the case metadata.

I'll research this case's docket and counsel. Let me start with several searches.

Key counsel lead found. Now let me pull the actual docket entries for both this case and the parallel e-Beacon case.

Now let me find the full docket sheet for this specific case to identify all appearances.

Bottom line

I could confirm one attorney of record for Greenlight Financial Technology, Inc. in Lab Technology LLC v. Greenlight Financial Technology, Inc., No. 1:25-cv-01356-JCB (D. Del.): Gregory E. Stuhlman of Chipman Brown Cicero & Cole, LLP (Wilmington, Delaware). I could not retrieve the complete docket sheet (PACER entries / pro hac vice motions) for this specific case, so additional pro hac vice counsel — common in D. Del. patent cases, where a Delaware firm appears as local counsel alongside out-of-state lead counsel — may exist but is unverified. I have flagged below what is confirmed versus what is a lead from a related case; I have not invented any names to fill the gap.

Confirmed counsel of record (defendant)

Primary sourcing for the appearance: the IP Law Daily / Bloomberg Law report on the July 23, 2026 dismissal expressly attributes counsel as: "Brian E. Lutness (Silverman, McDonald & Friedman) for Lab Technology LLC. Gregory Erich Stuhlman (Chipman Brown Cicero & Cole, LLP) for Greenlight Financial Technology, Inc." — see https://www.vitallaw.com/news/patent-d-del-infringement-case-dismissed-after-patent-for-youth-banking-app-ruled-invalid/ipm0107526d0680f64e55bab66a8737e642b2 and the opinion itself at https://law.justia.com/cases/federal/district-courts/delaware/dedce/1:2025cv01356/91091/35/ (D.I. 35, the § 101 / prosecution-disclaimer opinion).

Stuhlman's firm profile (https://chipmanbrown.com/attorney/stuhlman-gregory-e/) confirms his Wilmington office, Delaware bar admissions, and an IP-litigation practice area, but does not list this case among his representative matters.

Not confirmed — do not rely on these without docket verification

• Pro hac vice / out-of-state lead counsel for Greenlight in 1:25-cv-01356. Not identified. In the companion case filed the same day against the same defendant — e-Beacon LLC v. Greenlight Financial Technology, Inc., No. 1:25-cv-01357 (D. Del., Judge Williams) — the docket shows a May 21, 2026 pro hac vice appearance for three attorneys along with a three-attorney PHV fee, entered around the time Greenlight's reply brief was filed (D.I. 20–22). The individual names were not displayed in the docket text I could retrieve. It is plausible that the same defense team appears in both cases (both are Lab Technology-affiliated plaintiffs asserting patents against Greenlight's Kids & Teen Banking app), but I have no filing evidence tying those three PHV attorneys to 1:25-cv-01356 — treat as unverified.
• In-house counsel. No appearance by in-house counsel for Greenlight was found in any source.
• Monte Terrell Squire / Duane Morris LLP, and PHV attorneys Alissa Watson, John C. McElwaine, and Jeffrey L. Mapen. These attorneys appear for Greenlight in a different Delaware matter — Greenlight Financial Technology, Inc. v. Greenlite Inc., No. 1:25-cv-01029 (D. Del., a trademark case, filed Aug. 15, 2025; D.I. 5 pro hac vice motion granted Aug. 20, 2025). They are not confirmed as counsel in the Lab Technology patent case and should not be listed as such. (Sources: https://dockets.justia.com/docket/delaware/dedce/1:2025cv01029/90322 ; https://cdn.pacermonitor.com/public/case/59613305/Greenlight_Financial_Technology,_Inc_v_Greenlite_Inc)

Gaps in sourcing — how to close them

1. PACER / docket sheet for 1:25-cv-01356 (D. Del., Justia docket ID 91091). Docket entries that would resolve the question definitively: the initial appearances after service, any MOTION for Pro Hac Vice Appearance (with attached firm letterhead naming each attorney and firm), Rule 7.1 disclosure (D.I. in the 01357 case was filed 3/2/2026 by Greenlight; a comparable one likely exists here), and the 12(b)(6) briefing (D.I. 11–12, 16–17 pattern in the companion case).
2. Bloomberg Law / Law360 docket trackers, which usually name all counsel of record and their firms.
3. Chipman Brown firm press releases or docket-mention pages for the Greenlight engagement.

Caveats

• I relied on a July 30, 2026 secondary-source report plus the Justia-posted opinion for the single confirmed name; I was unable to open the raw docket sheet itself, so I cannot rule out additional counsel of record (especially out-of-state lead counsel appearing pro hac vice, or Delaware local counsel replacing or supplementing Stuhlman at any point between November 2025 and the July 23, 2026 dismissal).
• The record in this case was not sealed as far as the sources indicate, but the operative filings I could access were the opinion and complaint materials, not the full docket entry list.
• Note the caption/date inconsistency in the sources: the case was filed Nov. 6, 2025, and the first amended complaint was filed April 6, 2026 (one AI-generated summary mistakenly lists 04/06/2026 as the "case identification" date). The dismissal with prejudice is dated July 23, 2026 (D.I. 35).