Vortical Systems LLC v. Delair SAS

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Vortical Systems LLC (New Mexico)
  • Defendant: Delair SAS (France)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01155, E.D. Tex., 11/25/2025
• Venue Allegations: Plaintiff alleges venue is proper because the defendant is a foreign corporation and has committed acts of patent infringement within the district, causing harm there.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to the navigation of unmanned aerial vehicles (UAVs).
• Technical Context: The technology at issue involves systems and methods for remotely controlling a UAV by selecting a destination waypoint through a graphical user interface on a map.
• 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 (’294 Patent).

The Invention Explained

• Problem Addressed: The patent describes the field of prior art UAV navigation as requiring manual control by an operator with specific knowledge of the vehicle's location, waypoint coordinates, and other flight aspects, a process that is not highly automated (ʼ294 Patent, col. 1:19-28).
• The Patented Solution: The invention provides a method where an operator uses a remote control device to select a single pixel on a graphical map display. The system maps that pixel’s location to real-world Earth coordinates, transmits those coordinates to the UAV as a waypoint, and the UAV's onboard navigation computer then autonomously pilots the vehicle from its current position to that waypoint using a navigation algorithm (ʼ294 Patent, Abstract; col. 2:11-21). Figure 4 illustrates this core process flow from pixel selection to UAV piloting (ʼ294 Patent, Fig. 4).
• Technical Importance: This approach simplifies UAV mission planning to a point-and-click operation, reducing the operator’s cognitive load and enabling the creation of complex missions with minimal input (ʼ294 Patent, col. 2:1-9).

Key Claims at a Glance

• The complaint asserts "exemplary method claims" without specifying claim numbers, instead referencing charts in an external exhibit (Compl. ¶11). Claim 1 is the first independent 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.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any accused products by name. It refers to "Exemplary Defendant Products" that are purportedly identified in claim charts attached as Exhibit 2 (Compl. ¶¶11, 13). This exhibit was not provided with the complaint.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context. It alleges that the products "practice the technology claimed by the '294 Patent" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint’s substantive infringement allegations are contained entirely within claim charts in Exhibit 2, which is incorporated by reference but not provided with the filed document (Compl. ¶¶13-14). The narrative alleges that Defendant’s "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶13). Without the referenced exhibit, a detailed analysis of the infringement theory is not possible. No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the patent claims and the general nature of the dispute, litigation may focus on the following questions:
  • Scope Questions: Do Defendant's ground control systems or mission planning software qualify as a "remote control device" as contemplated by the patent? Does the method by which a user designates a target in the accused system constitute a "selection of a GUI map pixel"?
  • Technical Questions: Does the accused system perform the claimed "mapping" step of converting a screen-based selection to Earth coordinates? Does the accused UAV perform autonomous "piloting... in accordance with a navigation algorithm" that is controlled by an onboard "navigation computer," or does it rely on continuous control signals from the ground station?

V. Key Claim Terms for Construction

• The Term: "remote control device"

• Context and Importance: The definition of this term will be critical to establishing the scope of an infringing system. The dispute may center on whether a general-purpose computer (like a laptop or tablet) running software constitutes a "remote control device," or if the term implies more specialized hardware.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification explicitly states that the device can be "a browser in a laptop or personal computer or a microbrowser in a PDA" and lists examples including a "mobile telephone (110), workstation (104), laptop computer (116), and PDA (120)" (ʼ294 Patent, col. 2:48-51, col. 6:18-21).
  • Evidence for a Narrower Interpretation: The specification also refers to a "traditional 'ground control station,'" which could be argued to imply a more dedicated piece of hardware designed specifically for UAV control (ʼ294 Patent, col. 9:35-36).

• The Term: "navigation algorithm"

• Context and Importance: This term is central to the "piloting" limitation of the claim. Its construction will determine what type of autonomous flight control falls within the patent's scope. Practitioners may focus on whether the term requires a specific type of error correction or merely a pre-programmed flight path.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent discloses multiple distinct navigation algorithms, including simple heading-based piloting, a method based on correcting for deviation from a "cross track," and another that calculates a heading based on wind speed and direction (ʼ294 Patent, col. 2:55-60; col. 3:11-20; col. 3:23-31). This variety suggests the term is a generic one not limited to a single embodiment.
  • Evidence for a Narrower Interpretation: Nearly all described embodiments involve "periodically repeating" steps of reading the UAV's current position and recalculating a heading or course correction (ʼ294 Patent, col. 2:55-60; col. 12:60-61). A party might argue that this feedback loop is an essential feature of the claimed "navigation algorithm," excluding systems that simply fly a pre-calculated, static vector.

VI. Other Allegations

• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. It does, however, request in the prayer for relief that the case be declared "exceptional" under 35 U.S.C. § 285, which could lead to an award of attorneys' fees (Compl. p. 4, ¶E.i). No specific facts supporting this request are pleaded.

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

Because the complaint provides minimal detail and relies on an unprovided exhibit, the initial phase of the case will likely focus on clarifying the scope of the allegations through infringement contentions. Based on the patent and the nature of the technology, the dispute appears poised to center on two main issues:

• A core issue will be one of definitional scope: can the term "remote control device," which the patent illustrates with examples ranging from PDAs to workstations, be construed to cover the specific hardware and software architecture of the accused system?
• A key evidentiary question will be one of technical operation: once the accused products are identified, Plaintiff must demonstrate that they perform each claimed step, particularly the automated, onboard "piloting" of the UAV to a waypoint derived from a "pixel" selection, as opposed to alternative methods of remote vehicle operation.