Vortical Systems LLC v. Quantum Systems Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Vortical Systems LLC (New Mexico)
  • Defendant: Quantum-Systems Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:26-cv-00041, D. Del., 01/14/2026
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware and has an established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unnamed products infringe a patent related to navigating an unmanned aerial vehicle (UAV) using a graphical user interface.
• Technical Context: The technology concerns remote navigation systems for UAVs, a domain critical to the commercial, industrial, and military drone markets.
• 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

Date	Event
2003-10-23	’294 Patent Priority Date
2007-06-12	’294 Patent Issue Date
2026-01-14	Complaint Filing Date

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 describes that conventional UAVs were typically manually controlled, requiring an operator to have specific knowledge of the vehicle's starting position, current location, and waypoint locations, with little aid from automation (’294 Patent, col. 1:18-29).
• The Patented Solution: The invention proposes a method where an operator uses a remote control device to select 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 as a waypoint. The UAV’s onboard navigation computer then autonomously pilots the vehicle from its current position to that waypoint using a navigation algorithm (’294 Patent, Abstract; col. 2:11-21). Figure 4 of the patent illustrates this core process flow.
• Technical Importance: This approach simplifies UAV mission planning by abstracting complex coordinate entry into a simple point-and-click action on a map, making UAV operation accessible to users without specialized navigation skills (’294 Patent, col. 2:31-35).

Key Claims at a Glance

• The complaint asserts "one or more claims" including "exemplary method claims" without specifying particular claim numbers (Compl. ¶¶11-12). Independent claim 1 is the patent's broadest method claim.
• Independent Claim 1 Elements:
  • 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.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers generally to "Defendant products identified in the charts incorporated into this Count below (among the 'Exemplary Defendant Products')" (Compl. ¶11).

Functionality and Market Context

The complaint does not describe the functionality of the accused products. It alleges in a conclusory manner that the "Exemplary Defendant Products practice the technology claimed by the '294 Patent" (Compl. ¶13). No details regarding the products' features, operation, or market position are provided.

IV. Analysis of Infringement Allegations

The complaint states that "Exhibit 2 includes charts comparing the Exemplary '294 Patent Claims to the Exemplary Defendant Products" and incorporates these charts by reference (Compl. ¶¶13-14). However, Exhibit 2 was not filed with the complaint. The narrative infringement theory is limited to the assertion that the unnamed "Exemplary Defendant Products" practice the claimed technology and "satisfy all elements of the Exemplary '294 Patent Claims" (Compl. ¶13). The complaint alleges infringement occurs through Defendant's acts of making, using, offering to sell, selling, and importing the products, as well as through internal testing by employees (Compl. ¶¶11-12). No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the patent's claim language and the general nature of the allegations, the infringement analysis may raise several questions for the court.
  • Scope Questions: A central question will be how the term "GUI map pixel" is construed and whether it reads on modern touch-screen interfaces where a user might tap a location on a map rather than select a discrete pixel with a cursor. The complaint provides no facts to bridge this potential gap.
  • Technical Questions: The complaint does not specify which "navigation algorithm" used by the accused products allegedly meets the corresponding claim limitation. The patent discloses several specific algorithms for course correction based on cross-track distance or angle (’294 Patent, col. 3:11-30). A key question will be whether the accused products must practice one of these disclosed algorithms, or if any autonomous navigation function suffices.

V. Key Claim Terms for Construction

• The Term: "mapping the pixel's location on the GUI to Earth coordinates"

  • Context and Importance: This term is central to the invention, defining the core translation step from a user's screen input to a real-world location for the UAV. The construction of this term will determine whether the claim covers any system that converts a screen tap to GPS coordinates or if it is limited to the specific mathematical transformations disclosed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The language of claim 1 itself is broad, not reciting any specific mathematical formula. This may support an interpretation that covers any method of associating a point on a digital map with geographic coordinates.
    • Evidence for a Narrower Interpretation: The specification provides a detailed, multi-step process for this mapping, which includes "multiplying the range of longitude represented by each pixel by a column number of the selected pixel," adding multiplicands, and repeating for latitude (’294 Patent, col. 2:42-55; col. 12:20-51). A defendant may argue that the claim should be limited to this disclosed method or equivalents thereof.

• The Term: "piloting the UAV... in accordance with a navigation algorithm"

  • Context and Importance: This element defines the autonomous action taken by the UAV after receiving the waypoint. Its construction will be critical to determining whether the claim is infringed by any UAV that autonomously flies to a designated point or if it requires a more specific method of navigation and course correction.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim term itself does not specify the type of algorithm. Plaintiff may argue this term should be given its plain and ordinary meaning, covering any algorithm that directs the UAV from a starting point to a waypoint.
    • Evidence for a Narrower Interpretation: The specification dedicates significant discussion to several distinct navigation algorithms, such as periodically correcting course based on distance from a "cross track" or an angular deviation from it (’294 Patent, col. 13:21-14:22, 14:23-15:24). A defendant could argue that "a navigation algorithm" should be construed in light of these specific embodiments, thereby narrowing the claim's scope.

VI. Other Allegations

• Indirect Infringement: The complaint does not provide sufficient detail for analysis of indirect infringement. It does not plead facts showing that Defendant knew of the patent and specifically intended for its customers or users to infringe.
• Willful Infringement: The complaint does not plead facts to support a claim of willful infringement, such as alleging that Defendant had pre-suit knowledge of the ’294 Patent. The prayer for relief requests a finding that the case is "exceptional" for an award of attorneys' fees, but the factual allegations in the complaint do not support this request (Compl., p. 4).

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

• A core issue will be one of procedural sufficiency: given the absence of named accused products and the failure to provide the referenced infringement charts, a primary question is whether the complaint's conclusory allegations provide sufficient notice to survive a motion to dismiss under the pleading standards established by Twombly and Iqbal.
• A second key issue will be one of definitional scope: can the term "GUI map pixel," which originates from cursor-based computer interfaces of the early 2000s, be construed to cover the "tap-to-fly" inputs common on modern drone controller touch screens?
• A third dispositive question will be one of technical implementation: does the claim limitation "piloting the UAV...in accordance with a navigation algorithm" require the use of the specific cross-track correction methods detailed in the patent's specification, or does it read on any form of autonomous point-to-point navigation used by modern UAVs?