CTAF Solutions LLC v. Honeywell Intl Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CTAF Solutions, LLC (Washington)
  • Defendant: Honeywell International Inc. dba BendixKing (Delaware)
  • Plaintiff’s Counsel: Chong Law Firm PA; Sand, Sebolt & Wernow Co., LPA
• Case Identification: 1:20-cv-00535, 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 TC Heartland.
• Core Dispute: Plaintiff alleges that Defendant’s AERONAV GPS NAVIGATION SYSTEM infringes a patent related to aircraft terrain awareness and warning display equipment.
• Technical Context: The technology concerns avionics systems that enhance pilot safety by determining an aircraft's position relative to terrain or other points of interest and displaying that information, including distance and bearing, on a cockpit display.
• Key Procedural History: The complaint does not mention prior litigation or administrative proceedings involving the patent-in-suit. The patent-in-suit claims priority through a chain of continuation-in-part applications, indicating a lengthy development history for the underlying technology.

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: The patent describes the challenge of enhancing pilot situational awareness, particularly during an instrument approach, where a pilot must be aware of the aircraft's distance and bearing to a location of interest (like an airport) while also maintaining a safe separation from surrounding terrain, buildings, or other obstacles (’396 Patent, Abstract; col. 4:45-51).
• The Patented Solution: The invention is an aircraft indicator system that integrates data from a terrain awareness and warning system (TAWS) with navigational calculations. The system determines a "location of interest," calculates the distance and bearing from the aircraft to that location, and presents this information together on an electronic display, showing both a map-like "aircraft situation display image" and the specific calculated values (’396 Patent, Abstract; col. 23:51-64).
• Technical Importance: By combining a visual depiction of the aircraft's situation with explicit distance and bearing data on a single display, the technology aims to reduce pilot workload and improve safety during critical flight phases (’396 Patent, col. 4:42-51).

Key Claims at a Glance

• The complaint asserts independent claims 1 (a method) and 13 (a system) (Compl. ¶¶14-15).
• The essential elements of independent claim 1 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 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 relative to the aircraft; and
  • providing second display data to the electronic display, configured to cause the display to show the calculated distance value and the calculated bearing value.
• The complaint reserves the right to assert additional claims as the case progresses (Compl. ¶33).

III. The Accused Instrumentality

Product Identification

• The "AERONAV GPS NAVIGATION SYSTEM" (the "Accused Product") (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). Its alleged functionality includes determining the aircraft's real-time situation using terrain maps, calculating the distance and bearing to a designated waypoint, and showing an aircraft situation display image (Compl. ¶¶18-21). The complaint alleges the Accused Product "can accept input from the TAWS because it purportedly works with any avionics suite" (Compl. ¶18).

IV. Analysis of Infringement Allegations

The complaint references an exemplary claim chart in "Exhibit B," but this exhibit was not filed with the complaint (Compl. ¶17). The analysis below is based on the narrative allegations in the body of the complaint.

No probative visual evidence provided in complaint.

’396 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central dispute may concern the claim phrase "using a terrain awareness and warning system." The complaint alleges the Accused Product "can accept input from the TAWS" and "works with any avionics suite" (Compl. ¶18). This raises the question of whether merely being compatible with a TAWS is sufficient to meet the "using" limitation, or if the claim requires the accused system to be or to fully integrate a TAWS.
• Technical Questions: The complaint's infringement allegations are based on "internal testing and usage" but provide limited public-facing evidence of how the Accused Product operates (Compl. ¶18). A key factual question will be whether the Accused Product, as sold and operated, actually performs the determining, calculating, and displaying steps as claimed, particularly the step of "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 both asserted independent claims and is foundational to the infringement theory. Its construction will be critical, as the complaint alleges infringement based on the Accused Product’s ability to "accept input from the TAWS" (Compl. ¶18). Practitioners may focus on this term because its definition will determine whether mere compatibility with an external TAWS meets the limitation, or if a more integrated function is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Dependent claim 6 of the ’396 patent states that the TAWS is "capable of determining one or more locations of interest" and includes "at least in part via retrieval of terrain information from the geographical database" (’396 Patent, col. 24:13-18). This could support an argument that any system performing this function, not just a formally certified TAWS, falls within the claim's scope.
  • Evidence for a Narrower Interpretation: The patent title, "TERRAIN AWARENESS AND WARNING AIRCRAFT INDICATOR EQUIPMENT", and the focus on instrument approaches in the specification (’396 Patent, col. 24:26-27), suggest a specific aviation context. A party could argue that "TAWS" should be construed as a term of art limited to the class of systems formally recognized by aviation authorities (e.g., FAA TSO-C151).

The Term: "location of interest"

• Context and Importance: The scope of this term defines what types of geographical points trigger the functionality of the claimed invention. Whether it is limited to specific aviation-related points or includes any generic waypoint could be determinative for infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The complaint alleges the Accused Product calculates distance and bearing to a "designated waypoint or destination," suggesting a broad interpretation (Compl. ¶19). The patent specification discusses a "particular destination" in a general sense, which may support reading the term broadly to include any navigational point (’396 Patent, col. 4:51-54).
  • Evidence for a Narrower Interpretation: The patent's abstract explicitly defines a "location of interest" as "including an airport, a runway, a landing zone, etc." (’396 Patent, Abstract). This specific definition provided in the patent itself could be used to argue for a narrower construction limited to features associated with the terminal phase of flight.

VI. Other Allegations

• Indirect Infringement: The complaint makes a conclusory allegation of induced infringement, stating that Defendant encourages infringement through "the conduct described herein" (Compl. ¶28). It does not, however, plead specific facts, such as references to user manuals or marketing materials, that would allegedly instruct or encourage users to perform the infringing method.
• Willful Infringement: The complaint alleges Defendant has knowledge of its infringement "at least as of the service of the present Complaint" (Compl. ¶26). This pleading supports a claim for post-filing willfulness but does not allege pre-suit knowledge, which is typically required to establish willful infringement from the outset of the litigation.

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

• A core issue will be one of claim scope: can the phrase "using a terrain awareness and warning system," a specific term in aviation, be construed to cover a product that is merely alleged to be compatible with an external TAWS, or does the claim require a deeper level of integration or inherent functionality?
• A key evidentiary question will be one of technical proof: what evidence will Plaintiff produce to substantiate its claim, based on "internal testing," that the AERONAV GPS NAVIGATION SYSTEM actually performs the specific functions of determining a location of interest via a TAWS and displaying the claimed information? The complaint’s allegations are currently framed at a high level of generality.