CTAF Solutions LLC v. Universal Avionics Systems Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CTAF Solutions, LLC (Washington)
  • Defendant: Universal Avionics Systems Corp (Delaware)
  • Plaintiff’s Counsel: Chong Law Firm PA; SAND, SEBOLT & WERNOW CO., LPA
• Case Identification: 1:20-cv-00533, D. Del., 04/21/2020
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a Delaware corporation and therefore resides in the district.
• Core Dispute: Plaintiff alleges that Defendant’s advanced flight display systems infringe a patent related to methods and systems for displaying aircraft terrain awareness and navigation information.
• Technical Context: The technology concerns avionics systems that integrate navigational data (such as GPS and terrain databases) to provide pilots with enhanced situational awareness on a cockpit display, which is critical for safety during flight, particularly during instrument approaches.
• Key Procedural History: The complaint notes that the patent-in-suit was issued after a "full and fair examination" by the USPTO. No other significant procedural history, such as prior litigation or post-grant proceedings, is 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,"

Issued August 20, 2019

The Invention Explained

• Problem Addressed: The patent addresses the need for pilots to maintain awareness of their surroundings, including terrain, obstacles, and other geographical features, particularly when flying an instrument approach to a destination like an airport (’396 Patent, Abstract). The technology also implicitly addresses the challenge of presenting this complex information to a pilot in a clear and useful manner to avoid information overload while ensuring safety (’396 Patent, col. 4:45-51).
• The Patented Solution: The invention is a method and system for an aircraft display that determines a "location of interest" (e.g., an airport) relative to the aircraft using a terrain awareness system. It then calculates the distance and bearing to that location and presents this information to the pilot in two distinct ways: first, as a graphical "aircraft situation display image" and second, as explicit textual or numerical data showing the calculated distance and bearing (’396 Patent, Abstract; col. 23:51-64). This dual-mode display is intended to enhance a pilot's situational awareness.
• Technical Importance: The technology represents an approach to integrating GPS, geographical databases, and display systems to create more intuitive and comprehensive avionics interfaces, improving flight safety (’396 Patent, col. 4:41-51).

Key Claims at a Glance

• The complaint asserts independent claims 1 (a method) and 13 (a system) (Compl. ¶¶14, 15).
• Independent Claim 1 (Method) requires:
  • 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 cause the display to show an aircraft situation display image indicating the location of interest; and
  • providing second display data to the electronic display, configured to cause the display to show the calculated distance and bearing values.
• Independent Claim 13 (System) requires:
  • an electronic display; and
  • an electronic processor configured to perform the steps outlined in method claim 1.
• The complaint does not explicitly reserve the right to assert dependent claims, but this is standard practice.

III. The Accused Instrumentality

Product Identification

The accused product is Defendant's "EFI-890H Advanced Flight Display" (Compl. ¶17).

Functionality and Market Context

The complaint describes the Accused Product as a "self-contained, fault-tolerant, multi-function display" used for aircraft navigation (Compl. ¶17). It allegedly provides displays and processors that help pilots by determining the "real time situation of the aircraft using terrain maps" (Compl. ¶18). A key allegation is that the Accused Product "can accept input from the TAWS [terrain awareness and warning system]" and "purportedly works with any avionics suite" (Compl. ¶18). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an "exemplary claim chart" in Exhibit B, but this exhibit was not attached to the filed document (Compl. ¶17). The infringement theory is therefore drawn from the narrative allegations in the body of the complaint.

’396 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central dispute may arise from the claim limitation "using a terrain awareness and warning system." The complaint alleges the Accused Product "can accept input from the TAWS" (Compl. ¶18). This raises the question of whether merely receiving data from a TAWS, as opposed to being a TAWS or performing the core functions of one, satisfies the claim requirement of "using" a TAWS to make the determination.
• Technical Questions: The claims require two distinct sets of display data: a "first display data" for a graphical "situation display image" and a "second display data" for the numerical distance and bearing values. The court will need to determine if the Accused Product generates and displays these two forms of information as distinct outputs as claimed, or if its display functionality differs from the claimed configuration. The complaint's allegations are general and will require specific evidence of the Accused Product's operation.

V. Key Claim Terms for Construction

The Term: "terrain awareness and warning system"

• Context and Importance: This term is at the heart of the first step of the asserted claims. Its construction will be critical to determining infringement. Practitioners may focus on this term because the complaint's allegation that the accused product "can accept input from the TAWS" (Compl. ¶18) suggests a potential distinction between the accused display product and the TAWS itself, which could be a point of non-infringement. The case may turn on whether "using a...system" requires the accused product to be, or to incorporate, such a system, or whether simply processing its output data suffices.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not appear to provide a specific, narrow definition of the term. The specification broadly discusses integrating location information from various sources, such as a "GPS receiver and geographical database," to maintain awareness of terrain and obstacles, which could support a construction that is not limited to a specific type of certified system (’396 Patent, col. 4:41-51).
  • Evidence for a Narrower Interpretation: The consistent use of the full phrase "terrain awareness and warning system" in the claims, which is a term of art in avionics, may suggest an intent to refer to systems with specific, recognized functionalities (e.g., those meeting FAA TSO standards). A defendant might argue that the invention is an improvement that "uses" a conventional, separate TAWS as an input source.

VI. Other Allegations

Indirect Infringement

The complaint makes a conclusory allegation of induced infringement, stating Defendant encouraged acts that constitute infringement (Compl. ¶28). However, it does not plead specific facts to support the requisite knowledge and intent, such as citing user manuals, marketing materials, or other instructions that direct users to operate the product in an infringing manner.

Willful Infringement

The complaint alleges that Defendant has had knowledge of its infringement "at least as of the service of the present Complaint" (Compl. ¶26). This allegation, on its own, only supports a claim for post-filing willfulness and does not assert that Defendant had knowledge of the patent or its alleged infringement prior to the lawsuit being filed.

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

1. A central issue will be one of claim scope and system architecture: Does the claim phrase "using a terrain awareness and warning system" require the accused "EFI-890H Advanced Flight Display" to be or contain such a system, or is the requirement met if the display merely accepts and processes data from a separate, external TAWS unit? The resolution of this question will likely dictate the outcome of the infringement analysis.

2. A key evidentiary question will be one of functional specificity: Can Plaintiff provide evidence that the accused display generates two distinct sets of data as claimed—one for a graphical "situation display image" and a separate one for textual "distance value and...bearing value"? The infringement case will depend on demonstrating a precise mapping of the product's actual operation onto these separate limitations of the patent claims.