DCT
1:17-cv-07599
Airbus SAS v. Rockwell Collins Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Airbus, S.A.S. (France)
- Defendant: Rockwell Collins, Inc. (Delaware)
- Plaintiff’s Counsel: Greer, Burns & Crain, Ltd.
- Case Identification: 1:17-cv-07599, N.D. Ill., 10/20/2017
- Venue Allegations: Venue is alleged to be proper based on Defendant having an established place of business within the district and maintaining continuous and systematic general business contacts with Illinois.
- Core Dispute: Plaintiff alleges that Defendant’s "Horizon 8" aircraft seat configuration infringes a patent related to high-density, lie-flat seating arrangements, and also alleges trademark infringement.
- Technical Context: The technology concerns premium-class aircraft cabin layouts designed to maximize the number of lie-flat sleeper seats without compromising passenger space, a critical competitive factor for airlines on long-haul routes.
- Key Procedural History: The complaint alleges that Defendant Rockwell Collins acquired B/E Aerospace, the original seller of the accused product, in 2017. Plaintiff alleges it sent notice letters regarding potential infringement to B/E and subsequently Rockwell Collins prior to filing suit, which may form the basis for its willfulness allegations.
Case Timeline
| Date | Event |
|---|---|
| 2004-02-26 | ’446 Patent Priority Date |
| 2008-01-22 | ’446 Patent Issue Date |
| 2016 | Plaintiff becomes aware of accused "Horizon 8" product |
| 2017 | Defendant Rockwell Collins acquires B/E Aerospace |
| 2017-05-11 | Plaintiff's counsel sends letter to B/E Aerospace re: ’446 Patent |
| 2017-06-26 | Defendant's counsel replies to Plaintiff's letter |
| 2017-08-08 | Plaintiff's counsel sends follow-up letter to Defendant |
| 2017-10-20 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,320,446 - "Interior layout of an aircraft cabin"
- Patent Identification: U.S. Patent No. 7,320,446, "Interior layout of an aircraft cabin," issued January 22, 2008.
The Invention Explained
- Problem Addressed: The patent's background section describes the dual challenge faced by airlines: accommodating the largest possible number of passengers while simultaneously offering maximum comfort, particularly in business and first-class sections where seats that convert into lie-flat sleepers are expected (U.S. Patent No. 7,320,446, col. 1:29-40).
- The Patented Solution: The invention proposes a high-density seating arrangement where all seats face the same direction. The seats are designed to convert into sleepers with a wider portion (for the passenger's torso) and a narrower portion. By "staggering" the seats in neighboring columns, the wider portion of one seat aligns with the narrower portion of the adjacent seat, allowing for a tighter, interlocking fit that optimizes cabin space (U.S. Patent No. 7,320,446, Abstract; col. 2:1-5). This arrangement is intended to increase passenger count without negatively affecting comfort (U.S. Patent No. 7,320,446, col. 2:6-9).
- Technical Importance: This design approach seeks to solve the geometric problem of fitting more non-rectangular lie-flat seats into the fixed, curved space of an aircraft fuselage, a key issue in competitive cabin design (U.S. Patent No. 7,320,446, col. 1:41-52).
Key Claims at a Glance
- The complaint asserts claims 14 and 15, which depend from independent claim 10 (Compl. ¶29).
- Independent Claim 10 recites the following essential elements for an aircraft seat arrangement:
- An arrangement of at least three columns of seats, arranged one behind the other.
- Each seat is convertible into a sleeper with a stretched-out sleeping surface.
- All seats in the arrangement are turned in the same direction.
- Each sleeper has a "first sleeping portion" and a "second narrower sleeping portion."
- In two neighboring columns, the seats are "staggered" such that the first part of a seat in one column is closer to the second narrower portion of a seat in the neighboring column.
- The first portion of the seat of the first column is at "substantially a same distance from a floor of the cabin" as the first portion of the seat of the second column.
- The complaint does not explicitly reserve the right to assert other claims.
III. The Accused Instrumentality
Product Identification
The "Horizon 8" seat and seating configuration, originally offered for sale by B/E Aerospace, which was acquired by Rockwell Collins (Compl. ¶10, ¶15).
Functionality and Market Context
The complaint alleges the Horizon 8 is a seat configuration for sale for use in wide-body aircraft (Compl. ¶28). The configuration allegedly features seats that are convertible into a sleeper to present a stretched-out sleeping surface (Compl. ¶28). The complaint includes photographs of the Horizon 8 seating configuration as Exhibit D, which depict lie-flat seats in an aircraft cabin setting (Compl. ¶15). These photographs show multiple columns of seats in a dense arrangement. The complaint alleges that Rockwell, via B/E, offered these configurations for sale (Compl. ¶28).
IV. Analysis of Infringement Allegations
’446 Patent Infringement Allegations
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| at least three columns of seats, with the seats arranged one behind the other in each of the columns of seats | The accused Horizon 8 seats are offered for sale in an arrangement that includes at least three columns of seats, with the seats arranged one behind the other in each column. | ¶28 | col. 2:58-59 |
| each seat being convertible into a sleeper so as to present a stretched out sleeping surface | Each accused Horizon 8 seat is convertible into a sleeper that presents a stretched-out sleeping surface. | ¶28 | col. 1:62-64 |
| all seats of the arrangement are turned in the same direction | All seats of the accused arrangement are turned in the same direction. | ¶28 | col. 1:56-58 |
| each seat when converted into a sleeper presents a first sleeping portion and at least a second narrower sleeping portion with respect to the first portion | Each accused Horizon 8 seat, when converted to a sleeper, presents a first sleeping portion and at least a second narrower sleeping portion. | ¶28 | col. 1:65-col. 2:2 |
| and in two neighboring columns of said at least three columns, the seats are staggered, so that the first part of a seat of a first column...is closer to the second narrower portion of a seat of a second column... | In two neighboring columns, the accused seats are staggered, so that the first part of a seat of a first column is closer to the second narrower portion of a seat of the second column. | ¶28 | col. 2:1-5 |
| and the first portion of the seat of the first column is at substantially a same distance from a floor of the cabin as the first portion of the seat of the second column. | The first portion of the seat of the first column is at substantially a same distance from a floor of the cabin as the first portion of the seat of the second column. | ¶28 | col. 8:1-4 |
Identified Points of Contention
- Scope Questions: The interpretation of "substantially a same distance from a floor" will be a central issue. The complaint tracks the claim language, but the patent specification provides little to no explicit guidance on the permissible degree of vertical deviation for this limitation. This raises the question of how this term will be defined and proven.
- Technical Questions: A key factual question will be whether the accused "Horizon 8" configuration, as depicted in Exhibit D and offered for sale, actually meets the specific geometric requirements of the claims (Compl. ¶15). This includes not just the "staggered" layout but the specific relationship where the "first part" (wider portion) of one seat aligns with the "second narrower portion" of its neighbor. The evidence presented will need to demonstrate this specific spatial relationship.
V. Key Claim Terms for Construction
The Term: "staggered"
- Context and Importance: This term is the core of the invention's space-saving concept. Infringement hinges on whether the accused Horizon 8 layout meets the patent's specific definition of "staggered." Practitioners may focus on this term because the patent gives it a functional definition tied to the alignment of wide and narrow portions, not just any offset arrangement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The parties might argue the plain and ordinary meaning of "staggered" simply means not aligned in a straight transverse row.
- Evidence for a Narrower Interpretation: The claim itself provides a narrowing definition: "staggered, so that the first part of a seat of a first column... is closer to the second narrower portion of a seat of a second column" (U.S. Patent No. 7,320,446, col. 8:51-58). This suggests that any staggering that does not achieve this specific wide-to-narrow alignment would not infringe.
The Term: "substantially a same distance from a floor"
- Context and Importance: This is a term of degree that creates ambiguity. The outcome of the infringement analysis could depend entirely on how much vertical deviation "substantially" permits. Practitioners may focus on this term because the patent specification does not appear to provide any examples, definitions, or context to guide its interpretation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that in the context of an aircraft cabin, this term simply distinguishes the claimed layout from one with intentionally tiered or bunk-bed style seating, and that any normal variations in floor level or seat mounting fall within its scope.
- Evidence for a Narrower Interpretation: A party could argue that the absence of any qualifying language in the specification means "substantially" implies a very small, insignificant deviation, meaning the sleeping surfaces must be almost perfectly co-planar.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement "through at least the offer for sale of configurations claimed in the ‘446 Patent" (Compl. ¶28). The complaint does not, however, plead specific facts detailing how Rockwell Collins allegedly encouraged or instructed others (e.g., airlines) to assemble or use the seats in an infringing manner.
Willful Infringement
The complaint alleges that infringement was willful, deliberate, and intentional (Compl. ¶31). This allegation is supported by references to pre-suit correspondence dated May 11, 2017, June 26, 2017, and August 8, 2017, which allegedly put Defendant and its predecessor on notice of the ’446 Patent and the alleged infringement (Compl. ¶16-18).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can the term "substantially a same distance from a floor," which lacks explicit support or definition in the patent’s specification, be given a scope that is both definite and broad enough to read on the accused product? The resolution of this question will likely define the battleground for infringement.
- A second central issue will be one of evidentiary proof: what factual evidence, including the photographs in Exhibit D, can Plaintiff present to demonstrate that the accused "Horizon 8" product, as offered for sale, meets every geometric and spatial limitation of the asserted claims, particularly the specific wide-to-narrow "staggered" alignment?