CTAF Solutions LLC v. Scioteq LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CTAF Solutions, LLC (Washington)
  • Defendant: ScioTeq LLC (Delaware)
  • Plaintiff’s Counsel: Chong Law Firm PA; Sand, Sebolt & Wernow Co., LPA
• Case Identification: 1:20-cv-00503, D. Del., 04/13/2020
• Venue Allegations: Venue is asserted in the District of Delaware on the basis that Defendant is a Delaware corporation and therefore resides in the district.
• Core Dispute: Plaintiff alleges that Defendant’s multi-function aviation display infringes a patent related to aircraft terrain awareness and warning systems.
• Technical Context: The technology concerns avionics systems that process and display geographical and navigational data to pilots to enhance situational awareness during flight, particularly for avoiding terrain and other obstacles.
• Key Procedural History: The complaint does not allege any prior litigation, inter partes review proceedings, or licensing history concerning the patent-in-suit. The patent-in-suit is a continuation-in-part of a chain of at least five prior applications, which may provide an extensive prosecution history relevant to claim interpretation.

Case Timeline

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

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

• 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 background describes challenges in aviation communications, such as frequency congestion near airports and the need to filter out irrelevant transmissions based on distance and signal strength (e.g., squelch control) (’396 Patent, col. 5:12-28, col. 6:12-28). It also notes the general problem of pilots needing to maintain a safe distance from terrain and other geographical features, especially during an instrument approach (’396 Patent, col. 12:41-51).
• The Patented Solution: The invention as claimed describes a method and system for improving a pilot's situational awareness by determining a "location of interest" (e.g., an airport), calculating the aircraft's distance and bearing to that location, and presenting this information on an electronic display (’396 Patent, Abstract). The system provides both a graphical "aircraft situation display image" and specific textual data for the distance and bearing values, consolidating critical navigational information for the pilot (’396 Patent, col. 22:51-col. 23:2).
• Technical Importance: This technology aims to enable pilots to more effectively maintain awareness of surrounding terrain and their position relative to key navigational points, thereby increasing safety during critical phases of flight like instrument approaches (’396 Patent, Abstract).

Key Claims at a Glance

• The complaint asserts independent claims 1 (a method) and 13 (a system) (Compl. ¶¶14, 15, 23).
• Independent Claim 1 recites the core elements of the 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... to show an aircraft situation display image indicating the location of interest; and
  • providing second display data to the electronic display... to show the calculated distance value and the calculated bearing value.
• Independent Claim 13 recites a system comprising an electronic display and a processor configured to perform the steps outlined in method claim 1 (Compl. ¶15).

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is Defendant’s "MFD-3068," described as a "self-contained, fault-tolerant, multi-function display" (Compl. ¶17).

Functionality and Market Context

• The complaint alleges the MFD-3068 provides "displays/processors for helping pilots in aircraft navigation" and "determines the real time situation of the aircraft using terrain maps" (Compl. ¶18).
• The accused functionality includes calculating "the distance and the bearing angle to a designated waypoint or destination" (Compl. ¶19), showing an "aircraft situation display image with respect to a waypoint" (Compl. ¶20), and displaying the calculated distance and bearing angle (Compl. ¶21).
• The product is presented as one of the "aviation computing solutions and products" that Defendant commercializes (Compl. ¶5).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the MFD-3068 product directly infringes at least Claim 1 and enables a system that infringes Claim 13 of the ’396 Patent (Compl. ¶¶16, 22-23). The core allegations for Claim 1 are summarized below.

'396 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The complaint’s infringement theory rests on equating the accused product's use of "terrain maps" (Compl. ¶18) and calculation of data for a "waypoint or destination" (Compl. ¶19) with the claim requirement of using a "terrain awareness and warning system" to determine a "location of interest." A central dispute may concern whether the definition of "terrain awareness and warning system" requires specific warning capabilities beyond simple map display and navigation functions.
  • Technical Questions: The complaint provides conclusory allegations about the MFD-3068's functions. What evidence demonstrates that the accused product's standard navigational display constitutes an "aircraft situation display image" as contemplated by the patent? Furthermore, does the accused product's general navigation processing meet the specific limitation of performing these functions "using a terrain awareness and warning system"?

V. Key Claim Terms for Construction

• The Term: "terrain awareness and warning system"

• Context and Importance: This term appears in the first limitation of both independent claims and is foundational to the invention. Its construction will determine whether a wide range of modern avionics systems fall within the scope of the claims or if the claims are limited to a more specialized type of system. Practitioners may focus on this term because the complaint does not specify how the accused product meets this "warning" system limitation beyond general navigation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Dependent claim 6 suggests the term includes a "GPS receiver and geographical database... capable of determining one or more locations of interest" (’396 Patent, col. 23:14-19). This could support an interpretation where any modern GPS navigator with a map database qualifies.
  • Evidence for a Narrower Interpretation: The patent is titled "TERRAIN AWARENESS AND WARNING AIRCRAFT INDICATOR EQUIPMENT" and the term itself includes "warning." This language, combined with specification discussion about maintaining a "safe distance" from "mountains, buildings, or other geographical features" (’396 Patent, col. 12:47-51), could support an interpretation requiring an active alerting or warning capability, akin to an industry-standard TAWS or EGPWS.

• The Term: "aircraft situation display image"

• Context and Importance: This term defines the nature of the graphical output required by the claims. The dispute will likely center on whether a standard moving map display is sufficient to meet this limitation or if a more specific type of visualization is required.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification does not provide a narrow definition, which may support a plain and ordinary meaning that encompasses any graphical depiction of the aircraft's position relative to its surroundings or a destination.
  • Evidence for a Narrower Interpretation: Dependent claim 9 adds a limitation for showing "an indicator line extending from the aircraft to the location of interest" (’396 Patent, col. 23:27-30). A defendant could argue this specific embodiment informs the meaning of the broader term, suggesting the "image" must contain more than just a symbol on a map.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induced infringement by "encouraging infringement" and knowing its acts would lead to direct infringement (Compl. ¶28). The pleading does not, however, provide a specific factual basis for this encouragement, such as references to user manuals or marketing materials.
• Willful Infringement: The complaint alleges Defendant had knowledge of the ’396 Patent "at least as of the service of the present Complaint" (Compl. ¶26) and includes a prayer for enhanced damages (Compl. p. 8, ¶f). This asserts a claim for post-filing willfulness only, as no pre-suit knowledge is alleged.

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

• A core issue will be one of definitional scope: will the term "terrain awareness and warning system" be construed broadly to cover general-purpose aviation GPS navigators with map displays, or will it be limited to systems with the specific hazard-alerting functions typically associated with the "warning" language in the term? The outcome of this construction could be dispositive.
• A second issue will be one of evidentiary proof: the complaint's infringement allegations are conclusory. A key question will be whether discovery can establish a technical mapping between the accused MFD-3068's actual operation and the specific steps recited in the asserted claims, moving beyond the complaint's high-level functional descriptions.
• Finally, the viability of the indirect infringement claim will be an open question. The complaint offers a bare allegation of inducement without factual support. The case may test whether Plaintiff can produce evidence of specific acts by Defendant intended to encourage its customers to use the accused product in a manner that directly infringes the ’396 Patent.