CTAF Solutions LLC v. Aspen Avionics Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CTAF Solutions, LLC (Washington)
  • Defendant: Aspen Avionics, Inc. (Delaware)
  • Plaintiff’s Counsel: Chong Law Firm PA
• Case Identification: 1:20-cv-00534, D. Del., 04/21/2020
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation and therefore resides in the district for purposes of patent venue under 28 U.S.C. §1400(b).
• Core Dispute: Plaintiff alleges that Defendant’s "EVOLUTION 2000" multi-function avionics display infringes a patent related to methods and systems for displaying aircraft situational and terrain awareness information.
• Technical Context: The technology resides in the field of avionics, specifically integrated cockpit displays that provide pilots with enhanced situational awareness of nearby terrain, obstacles, and flight path information to improve safety.
• Key Procedural History: The complaint is the initial pleading in this matter. No prior litigation, administrative proceedings, or licensing history is mentioned. The patent-in-suit claims priority to a chain of applications dating back to 2011, suggesting a developed patent portfolio in this technology area.

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 Aug. 20, 2019)

The Invention Explained

• Problem Addressed: When flying, particularly during an instrument approach to an airport, a pilot must simultaneously track the aircraft's course to a destination while also remaining aware of surrounding geographical features like mountains and buildings to maintain a safe distance (’396 Patent, Abstract; col. 4:45-51).
• The Patented Solution: The patent describes a method and system for an aircraft's electronic display that integrates these two critical data streams. It uses a "terrain awareness and warning system" to identify a "location of interest" (e.g., an airport), calculates the distance and bearing to that location, and then presents this information to the pilot in two specific 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, Claim 1, col. 23:51-col. 24:2).
• Technical Importance: This approach combines a map-like visual representation with precise numerical data, aiming to provide pilots with comprehensive and easily digestible information to enhance flight safety (’396 Patent, col. 4:34-51).

Key Claims at a Glance

• The complaint asserts independent method Claim 1 and independent system Claim 13 (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 functional steps recited in Claim 1.
• Plaintiff reserves the right to modify its infringement theories as discovery progresses (Compl. ¶33).

III. The Accused Instrumentality

• Product Identification: The "EVOLUTION 2000" (the "Accused Product") (Compl. ¶17).
• Functionality and Market Context: The complaint describes the Accused Product as a "self-contained, fault-tolerant, multi-function display" for aircraft navigation (Compl. ¶17). It is alleged to determine an aircraft's situation using terrain maps and to be compatible with any avionics suite, including the capability to "accept input from the TAWS" (Terrain Awareness and Warning System) (Compl. ¶18). The complaint alleges that the Accused Product performs the method of Claim 1 and enables the system of Claim 13, including through "internal testing and usage" (Compl. ¶¶ 16, 18).

IV. Analysis of Infringement Allegations

The complaint references an external claim chart exhibit that was not provided with the pleading; however, the body of the complaint contains narrative allegations that map product features to the limitations of Claim 1.
No probative visual evidence provided in complaint.

’396 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A primary question may be the scope of the phrase "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 and displaying data from an external, third-party TAWS constitutes "using" that system to "determine" a location of interest, as required by the claim, or if the claim requires the accused system to perform the determination step itself.
  • Technical Questions: The claims require providing "first display data" for an "image" and "second display data" for numerical values. The infringement analysis may turn on whether the Accused Product’s display architecture features two distinct data outputs as claimed, or if it presents the graphical and numerical information in a single, integrated data stream or display format that may not map directly onto the claim's structure.

V. Key Claim Terms for Construction

• The Term: "terrain awareness and warning system"

  • Context and Importance: This term appears in the first step of both asserted independent claims and defines a core component of the invention. The case may hinge on whether this term is limited to a specific type of FAA-certified system or can be read more broadly to include any system with geographical databases that provides terrain alerts. Practitioners may focus on this term because the complaint's allegation of infringement rests on the product's ability to "accept input from the TAWS" (Compl. ¶18), making the definition of the system and the action of "using" it central to the dispute.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification does not appear to limit the term to a specific industry standard. Claim 6 states the TAWS is "capable of determining one or more locations of interest... via retrieval of terrain information from the geographical database," suggesting a functional definition rather than a component-specific one (’396 Patent, col. 24:14-19).
    • Evidence for a Narrower Interpretation: The acronym "TAWS" has a particular meaning in the field of aviation, often referring to systems that meet specific FAA technical standard orders (TSOs). A party could argue that a person of ordinary skill in the art would understand the term in this more limited, official sense.

• The Term: "aircraft situation display image"

  • Context and Importance: The claims create a distinction between an "image" (from "first display data") and numerical values (from "second display data"). The viability of the infringement claim depends on the Accused Product providing both, distinctly. The definition of "image" is therefore critical to determining if the product's graphical display meets this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The abstract describes displaying "a representation of nearby terrain," which could support a broad reading of "image" to encompass any map-like or graphical depiction (’396 Patent, Abstract).
    • Evidence for a Narrower Interpretation: A party might argue that the term implies more than a simple icon on a screen, perhaps requiring a more detailed topographical or schematic view as might be understood from the patent's overall context of enhancing terrain awareness. The separation of the "image" from the "distance value and the bearing value" could be argued to require a display where the graphical element is functionally and architecturally separate from the textual data elements.

VI. Other Allegations

• Indirect Infringement: The complaint includes a conclusory allegation of induced infringement, stating Defendant encourages infringement but offers no specific supporting facts, such as references to user manuals or marketing materials that instruct users on an infringing use (Compl. ¶28).
• Willful Infringement: The complaint alleges knowledge of the ’396 Patent "at least as of the service of the present Complaint" (Compl. ¶26). This allegation, on its own, would only support a claim for post-filing willfulness, as no facts supporting pre-suit knowledge are pleaded.

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

• A core issue will be one of functional responsibility: does the claim limitation "determining a location of interest... using a terrain awareness and warning system" require the accused processor to perform the determination itself, or can it be met by a system that simply receives, processes, and displays a location determined by an external TAWS? The resolution will depend on the court's construction of "using" and "determining."
• A key evidentiary question will be one of architectural distinction: does the accused "EVOLUTION 2000" provide "first display data" and "second display data" as two distinct inputs to its display as required by the claims, or does it generate a single, integrated display? The case may turn on technical evidence regarding the product's software architecture and how it renders visual information.