An NSL is typically reserved for companies who can give broad access to user data, such as requiring all previous and any future data for x amount of time for 3-hops from a single persons social network (which could be hundreds of people).
That plus obscure the target. So an NSL wouldn't be necessary if they could hit up the regulators for large data dumps. The only question then is providing real-time access/future data.
I'm not sure Uber fits the profile for NSLs. Primarily given the fact that Uber likely doesn't have social network data on their riders so a simple court order for a single users rides and GPS locations is probably all that's available for an NSA/FBI investigations. Unlike an email provider like Yahoo/Lavabit, or an ISP for example, which could provide multi-hop data.
I'm curious if they built the NSA/FBI a full realtime data feed access system the way Blackberry did [1] for their BBM system during G20 in Toronto in 2010. Since the founder of Uber spoke about having a "god-mode" system [2] in place to do pretty much the same. It wouldn't be hard to expose that same system to federal agencies (even voluntarily).
[1] http://www.bloomberg.com/news/articles/2013-06-17/blackberry...
[2] http://www.buzzfeed.com/johanabhuiyan/uber-is-investigating-...