CTAF Solutions LLC v. L3 Aviation Products Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CTAF Solutions, LLC (Washington)
  • Defendant: L3 Aviation Products, Inc. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; Sand, Sebolt & Wernow Co., LPA
• Case Identification: 1:19-cv-01876, D. Del., 10/06/2019
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware and maintains a regular and established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s multi-function aircraft displays infringe a patent related to terrain awareness and warning systems that display navigational data.
• Technical Context: The technology concerns avionics systems that integrate geographical data with aircraft position to provide pilots with enhanced situational awareness, particularly for avoiding terrain and navigating to destinations like airports.
• Key Procedural History: The patent-in-suit was issued on August 20, 2019, less than two months before the complaint was filed. The complaint does not mention any prior litigation, licensing history, or other proceedings related to the patent.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

• Patent Identification: U.S. Patent No. 10,389,396, TERRAIN AWARENESS AND WARNING AIRCRAFT INDICATOR EQUIPMENT, issued August 20, 2019.

The Invention Explained

• Problem Addressed: The patent addresses the need for aircraft pilots to maintain awareness of their surroundings to avoid colliding with mountains, buildings, or other geographical features, particularly when flying an instrument approach to an airport ('396 Patent, Abstract; col. 4:45-51).
• The Patented Solution: The invention describes a system and method that uses a "terrain awareness and warning system" to identify a "location of interest" (e.g., an airport) and calculate the aircraft's distance and bearing to it. This information is then presented on an electronic display in two ways: first, as a graphical "aircraft situation display image" showing the location relative to the aircraft, and second, as explicit numerical values for the calculated distance and bearing ('396 Patent, Abstract; col. 23:51-65).
• Technical Importance: This approach consolidates critical navigational and safety information onto a single display, which may enhance pilot situational awareness and reduce workload during critical phases of flight by integrating GPS location with a geographical database ('396 Patent, col. 4:34-51).

Key Claims at a Glance

• The complaint asserts independent claims 1 (a method) and 13 (a system) (Compl. ¶¶13-14).
• Independent Claim 1 (Method):
  • determining a location of interest relative to an aircraft using a terrain awareness and warning system;
  • calculating a distance value and a bearing value for the location of interest relative to the aircraft;
  • providing first display data to an electronic display, configured to show an aircraft situation display image indicating the location of interest; and
  • providing second display data to the electronic display, configured to show the calculated distance and bearing value.
• Independent Claim 13 (System):
  • an electronic display; and
  • an electronic processor configured to perform the steps functionally identical to those recited in method claim 1.

III. The Accused Instrumentality

Product Identification

• The accused product is the "PANTHR LAD," which the complaint describes as a "self-contained, fault-tolerant, multi-function display" (Compl. ¶16).

Functionality and Market Context

• The complaint alleges the PANTHR LAD provides displays to assist pilots with aircraft navigation (Compl. ¶17). Its accused functionality includes determining the aircraft's real-time situation using terrain maps, calculating the distance and bearing to a "designated waypoint or destination," and showing both a situation display image and the specific distance and bearing data on its screen (Compl. ¶¶17-20). The complaint does not provide further detail on the product's market position.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint. The complaint states that a claim chart is attached as Exhibit B, but that exhibit was not filed with the complaint (Compl. ¶16). The following analysis is based on the narrative allegations in the complaint body.

'396 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The complaint alleges the accused product calculates distance and bearing to a "designated waypoint or destination" (Compl. ¶18). A central question will be whether a general-purpose "waypoint" falls within the scope of the claim term "location of interest," which the patent repeatedly frames in the context of safety-critical terrain avoidance and instrument approaches to airports ('396 Patent, Abstract; col. 4:45-51).
  • Technical Questions: What evidence demonstrates that the accused "PANTHR LAD" functions as a "terrain awareness and warning system" as required by the claims, rather than a more generic flight management or navigation system? The complaint's allegations on this point are conclusory and not supported by technical documentation (Compl. ¶17).

V. Key Claim Terms for Construction

• The Term: "terrain awareness and warning system"

  • Context and Importance: This term appears in both asserted independent claims and is foundational to the invention's context. Practitioners may focus on this term because its construction will determine whether the patent applies narrowly to specialized safety systems (like TAWS/EGPWS) or more broadly to any modern avionics display that shows terrain.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not explicitly define the term or limit it to a specific regulatory standard. The specification refers generally to enabling a user to maintain awareness of "surrounding mountains, buildings, obstructions, or other geographical features" ('396 Patent, col. 22:8-12), which could be argued to cover a wide range of systems.
    • Evidence for a Narrower Interpretation: The patent title is TERRAIN AWARENESS AND WARNING AIRCRAFT INDICATOR EQUIPMENT, and the claims require the system to be used for "determining a location of interest" ('396 Patent, col. 23:51-53). This context, tied to instrument approaches and safety, may support a narrower construction limited to systems whose primary purpose is warning, not just general navigation.

• The Term: "location of interest"

  • Context and Importance: The infringement theory depends on equating the accused product's use of a "waypoint or destination" (Compl. ¶18) with the claimed "location of interest." The breadth of this term is therefore critical.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself is generic. Dependent claim 2 defines the location of interest as "terrain," suggesting the independent claim is not limited to any specific type of location ('396 Patent, col. 23:66-67). This may support an interpretation that includes any user-defined waypoint.
    • Evidence for a Narrower Interpretation: The patent's Abstract explicitly provides examples of a "location of interest" as "an airport, a runway, a landing zone, etc." The detailed description consistently discusses the term in the context of navigating safely to an airport while avoiding terrain ('396 Patent, col. 4:45-51). This could support a narrower construction tied to official or safety-related geographical points, rather than any arbitrary waypoint.

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendant has had knowledge of infringement "at least as of the service of the present Complaint" (Compl. ¶25). This allegation supports a claim for post-filing willfulness but does not plead any facts to suggest Defendant had knowledge of the patent prior to the lawsuit's filing.

VII. Analyst’s Conclusion: Key Questions for the Case

• A core issue will be one of definitional scope: Can the claim term "location of interest", which the patent primarily describes in the context of airports and instrument approaches, be construed broadly enough to read on the accused product's use of a generic "waypoint or destination"?
• The case will also present a key evidentiary question: What technical evidence will Plaintiff provide to demonstrate that the accused "PANTHR LAD" is a "terrain awareness and warning system" as claimed, and not simply a general-purpose multi-function display that happens to show terrain, and how will that evidence map to the court's construction of that term?