Vortical Systems LLC v. Teledyne FLIR LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Vortical Systems LLC (NM)
  • Defendant: Teledyne FLIR, LLC (DE)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00390, D. Del., 03/28/2025
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated there, has an established place of business in the district, and has committed alleged acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s Unmanned Aerial Vehicle (UAV) products infringe a patent related to navigating a UAV by selecting a destination point on a graphical user interface.
• Technical Context: The technology concerns simplified remote control systems for UAVs, a field critical for both military and commercial drone operations, where reducing operator workload can improve mission effectiveness and safety.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 7,231,294 - Navigating a UAV

• Patent Identification: U.S. Patent No. 7,231,294, “Navigating a UAV,” issued June 12, 2007.

The Invention Explained

• Problem Addressed: The patent addresses the complexity of conventional UAV operation, which typically requires manual control and specific operator knowledge of the vehicle's location, waypoint coordinates, and flight dynamics, with little aid from automation (U.S. Patent No. 7,231,294, col. 1:17-31).
• The Patented Solution: The invention proposes a method where an operator on a remote device selects a single pixel on a graphical user interface (GUI) map. This pixel selection is then automatically mapped to real-world Earth coordinates, which are transmitted to the UAV. An onboard navigation computer then pilots the UAV from its current position to the new waypoint according to a navigation algorithm, all initiated by a single user action like a mouse-click (’294 Patent, col. 1:35-43, Fig. 4).
• Technical Importance: This approach significantly simplifies mission planning and execution by abstracting complex navigational calculations away from the operator and replacing them with a simple point-and-click interface (’294 Patent, col. 2:1-9).

Key Claims at a Glance

The complaint alleges infringement of "one or more claims" and "exemplary claims" without specifying particular claims (Compl. ¶11). Independent claim 1 is a representative method claim.

• Independent Claim 1:
  • receiving in a remote control device a user's selection of a GUI map pixel that represents a waypoint for UAV navigation, the pixel having a location on the GUI;
  • mapping the pixel's location on the GUI to Earth coordinates of the waypoint;
  • transmitting the coordinates of the waypoint to the UAV;
  • reading a starting position from a GPS receiver on the UAV; and
  • piloting the UAV, under control of a navigation computer on the UAV, from the starting position to the waypoint in accordance with a navigation algorithm.
• The complaint does not explicitly reserve the right to assert dependent claims, but its broad reference to "one or more claims" suggests this possibility (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products. It refers generally to "Exemplary Defendant Products" that are identified in claim charts attached as Exhibit 2 (Compl. ¶11, ¶16).

Functionality and Market Context

• The complaint does not provide specific details about the functionality or market context of the accused products, other than to allege that they "practice the technology claimed by the ’294 Patent" (Compl. ¶16). Without access to the referenced Exhibit 2, no further analysis of the accused instrumentality is possible based on the complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts in an incorporated Exhibit 2 (Compl. ¶16-17). As this exhibit was not provided with the complaint, the specific factual basis for the infringement allegations is not available for analysis in a claim chart format. The narrative of the complaint asserts that the "Exemplary Defendant Products incorporated in these charts satisfy all elements of the Exemplary ’294 Patent Claims" (Compl. ¶16).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Factual Questions: A primary question will be what evidence Plaintiff can produce to show that Defendant's accused products perform each step of the asserted claims. The complaint's lack of detail on this point suggests discovery will be focused on the specific operational software and hardware of Defendant's UAV control systems.
  • Technical Questions: A key technical question is how Defendant's systems designate a destination. The analysis will likely focus on whether the accused functionality constitutes "mapping the pixel's location on the GUI to Earth coordinates" as described in the patent, or if it uses a technically distinct method for translating a user's input on a map into a navigational command for the UAV (’294 Patent, col. 17:10-12).

V. Key Claim Terms for Construction

• The Term: "GUI map pixel"
• Context and Importance: This term appears in the first limitation of independent claim 1 and is foundational to the claimed invention, as the entire process begins with its "selection" by a user (’294 Patent, col. 17:6-9). The definition of what constitutes a "GUI map pixel" in the context of modern mapping interfaces will be critical to determining the scope of the claims and whether they read on the accused products.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the user's action as a "single interface operation, a mouseclick or joystick button click" (’294 Patent, col. 1:36-38). This language may support an argument that any point-and-click or tap-to-select action on a digital map, regardless of the underlying display technology (e.g., raster vs. vector), constitutes selecting a "GUI map pixel".
  • Evidence for a Narrower Interpretation: The detailed description explains a specific mathematical process for mapping the pixel, which involves its row and column number on the GUI, the total number of rows and columns, and the latitude/longitude range of the map (’294 Patent, col. 11:1-col. 12:52). A defendant may argue this disclosure limits the term to a discrete, grid-based element of a raster image, as opposed to a location selected on a more abstract, vector-based map common in modern systems.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end-users on how to use the accused products in an infringing manner (Compl. ¶14).
• Willful Infringement: The complaint bases its allegation of knowledge, and therefore willfulness, on the service of the complaint itself (Compl. ¶13, ¶15). This frames the willfulness claim as being based on post-filing conduct.

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

1. An Evidentiary Question of Infringement: Given the complaint's lack of specific factual allegations mapping product features to claim limitations, a threshold issue will be whether Plaintiff can produce evidence demonstrating that Defendant’s unnamed products actually perform the claimed steps of receiving a "pixel" selection, mapping it to Earth coordinates, and transmitting those coordinates to a UAV for autonomous navigation.
2. A Definitional Question of Scope: The case may turn on claim construction, specifically whether the term "GUI map pixel," described in a patent from the early 2000s, can be construed to cover the target selection mechanisms used in Teledyne FLIR's contemporary UAV control interfaces. The outcome of this definitional dispute will likely determine the reach of the patent into modern technology.