CTAF Solutions LLC v. Dassault Falcon Jet Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CTAF Solutions, LLC (Washington)
  • Defendant: Dassault Falcon Jet Corp. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; Sand, Sebolt & Wernow Co., LPA
• Case Identification: 1:19-cv-02322, D. Del., 12/21/2019
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware corporation and therefore resides in the district for purposes of patent venue.
• Core Dispute: Plaintiff alleges that Defendant’s Falcon Eye avionics system infringes a patent related to methods and systems for displaying integrated terrain awareness and navigational information to pilots.
• Technical Context: The technology at issue involves aircraft display systems that improve pilot situational awareness by combining graphical, map-based terrain information with numerical data like distance and bearing on an electronic display.
• Key Procedural History: The complaint notes that Plaintiff is the owner of the patent-in-suit by assignment. No other procedural events, such as prior litigation or administrative proceedings before the USPTO, are mentioned.

Case Timeline

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

U.S. Patent No. 10,389,396 - TERRAIN AWARENESS AND WARNING AIRCRAFT INDICATOR EQUIPMENT

The Invention Explained

• Problem Addressed: The patent describes the challenge pilots face during instrument approaches, where they must maintain awareness of their aircraft's position relative to the destination airport as well as to surrounding mountains, buildings, or other obstacles ('396 Patent, col. 4:45-51).
• The Patented Solution: The invention addresses this by using a "terrain awareness and warning system" to identify a "location of interest" and then presenting information to the pilot in two distinct ways on an electronic display. It provides a graphical "aircraft situation display image" showing the location of interest relative to the aircraft, and it separately provides numerical data showing the calculated distance and bearing to that location ('396 Patent, Abstract; col. 23:51-64).
• Technical Importance: This integrated approach seeks to enhance flight safety by presenting both high-level graphical context and precise numerical data on a single display, thereby improving a pilot's situational awareness during critical flight phases.

Key Claims at a Glance

• The complaint asserts independent method Claim 1 and independent system Claim 13 ('Compl. ¶14, 15).
• Claim 1 (Method): The essential steps are:
  • 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 that location;
  • Providing first display data to show an "aircraft situation display image" indicating the location; and
  • Providing second display data to show the calculated distance and bearing values.
• Claim 13 (System): This claim recites a system comprising an electronic display and a processor configured to perform the same essential steps outlined in Claim 1.

III. The Accused Instrumentality

Product Identification

The "Falcon Eye" system ('Compl. ¶17).

Functionality and Market Context

The complaint describes the Falcon Eye as a "self-contained, fault-tolerant, multi-function display" ('Compl. ¶17). Its alleged function is to assist pilots in navigation by determining the "real time situation of the aircraft using terrain maps" and providing corresponding displays ('Compl. ¶18). The complaint does not provide further details on the product's market position.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

'396 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question for the court may be whether the accused product's alleged use of "terrain maps" (Compl. ¶18) satisfies the "terrain awareness and warning system" limitation. The proper construction of this term, and whether it is a general term or a term of art with a more specific technical or regulatory meaning, will be a key issue.
• Technical Questions: The claims require "providing first display data" for an image and "providing second display data" for numerical values. This raises the evidentiary question of whether the Falcon Eye system architecturally performs two distinct data-provisioning actions that result in two types of display outputs, or whether it generates a single, integrated display that may not map directly onto the claim's two-part structure.

V. Key Claim Terms for Construction

"terrain awareness and warning system"

• Context and Importance: This term appears in both asserted independent claims and defines the core component used to identify the "location of interest." Infringement will depend on whether the functionality of the Accused Product, which allegedly uses "terrain maps" ('Compl. ¶18), falls within the scope of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification suggests this can be a system including a GPS receiver and a geographical database used for "retrieval of terrain information" ('396 Patent, col. 24:14-19). This could support an argument that any system using a digital map database for navigation qualifies.
  • Evidence for a Narrower Interpretation: A party could argue that "Terrain Awareness and Warning System" (TAWS) is an established term of art in the aviation industry that implies specific functions and compliance with regulatory standards beyond simply displaying a map. The patent’s title uses this phrase, which may suggest an intent to invoke its specialized meaning.

"aircraft situation display image"

• Context and Importance: This term defines the output of the "first display data." Practitioners may focus on this term because the dispute will likely involve distinguishing this graphical "image" from the numerical data generated by the "second display data." The clarity of this distinction is central to the infringement theory.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not provide an explicit definition, which could support applying the term's plain and ordinary meaning to cover a wide variety of graphical depictions of an aircraft's position relative to a location of interest.
  • Evidence for a Narrower Interpretation: The separation in the claim between the "image" and the "calculated distance value and... bearing value" suggests the "image" is primarily graphical and does not itself contain the specific numerical data of the second display element. A party might argue that if the accused display integrates this information into a single visual element, it does not meet the claim's required structure.

VI. Other Allegations

Indirect Infringement

The complaint alleges that Defendant contributes to and induces infringement by "providing the Accused Product to its customers who directly infringe" ('Compl. ¶28). The pleading does not allege specific acts of inducement, such as providing user manuals or specific instructions that direct customers to use the product in an infringing manner.

Willful Infringement

The allegation of willfulness is based on knowledge of the '396 Patent obtained "at least as of the service of the present Complaint" ('Compl. ¶26). The complaint does not allege any pre-suit knowledge of the patent or the alleged infringement.

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

• A core issue will be one of definitional scope: does the term "terrain awareness and warning system," as used in the patent, read on the accused product's alleged function of using "terrain maps" for navigation, or does the term carry a more specific technical meaning in the field of avionics that the accused product does not meet?
• A key evidentiary question will be one of functional operation: does the accused Falcon Eye system perform two distinct "providing" steps to generate a graphical "image" and separate numerical data, as recited in the claims, or is there a fundamental mismatch between the accused product's integrated display architecture and the patent's claimed two-part data presentation method?