Ortiz & Associates Consulting LLC v. Sita Information Networking Computing USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ortiz & Associates Consulting, LLC (New Mexico)
  • Defendant: Sita Information Networking Computing USA, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 3:25-cv-03070, N.D. Tex., 11/11/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Texas because Defendant maintains a regular and established place of business in Irving, Texas, and has committed acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s systems, products, and services for the air transport industry infringe a patent related to brokering data between wireless devices and separate data rendering devices, such as printers or displays.
• Technical Context: The technology addresses methods for a user of a mobile wireless device to locate, authenticate with, and send data to a networked output device for printing or display.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity that has never sold a product. It also notes that Plaintiff and its predecessors have entered into prior settlement licenses and argues at length that these licenses do not create a patent marking obligation under 35 U.S.C. § 287.

Case Timeline

Date	Event
2000-06-27	’285 Patent Priority Date
2017-01-17	’285 Patent Issue Date
2025-11-11	Complaint Filing Date

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

U.S. Patent No. 9,549,285 - Systems, methods and apparatuses for brokering data between wireless devices, servers and data rendering devices

• Issued: January 17, 2017.

The Invention Explained

• Problem Addressed: The patent describes a problem existing at its priority date (June 2000) where users of handheld wireless devices were constrained by small screens and lacked convenient ways to render data, such as documents or images, on larger-format output devices like networked printers or displays (’285 Patent, col. 4:35-48).
• The Patented Solution: The invention proposes a system where a wireless device (WD) user can locate a nearby data rendering device (DRD) through a network server. The user can then select data and request that the server transfer it to the chosen DRD for rendering. For security, the system requires a passcode associated with the wireless device to be entered at the DRD’s user interface to authorize the data rendering (’285 Patent, Abstract; col. 5:39-44; Fig. 10).
• Technical Importance: The patented approach provides a framework for enabling mobile device users to securely access and utilize fixed output hardware in their vicinity, addressing a growing need for "information on the go" and portability (’285 Patent, col. 4:49-54).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-13 of the ’285 Patent (Compl. ¶9). Independent claim 1 is a system claim with the following essential elements:
  • A server in communication with at least one data rendering device (DRD) registered with the server.
  • The DRD includes a user interface for receiving passcodes.
  • Memory within the server, accessible by the DRD, for securely storing data and a passcode associated with a wireless device (WD).
  • The server is configured to send the data from its memory to the DRD for rendering only after a passcode entered at the DRD’s user interface matches the passcode stored in the server’s memory.
• The complaint reserves the right to assert infringement of claims 2-13, which are dependent on the independent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

The complaint accuses "systems, products, and services that performs a method that infringes" the ’285 Patent (Compl. ¶9). It broadly references Defendant’s corporate website (sita.aero) without identifying specific products or services (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the technical functionality of the accused instrumentalities. It alleges that Defendant "maintains, operates, and administers" the accused systems and that infringement occurs through use by Defendant’s customers or in testing (Compl. ¶¶9, 11). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an infringement chart in Exhibit B but does not include it with the pleading (Compl. ¶10). The narrative infringement theory alleges that Defendant’s systems and services, used by customers or in testing, practice the patented method (Compl. ¶¶9, 11). The complaint asserts direct infringement, stating that Defendant "put the inventions claimed by the ’285 Patent into service (i.e., used them)" (Compl. ¶9). Without a claim chart or specific factual allegations, a detailed analysis of the infringement theory is not possible based on the complaint alone.

• Identified Points of Contention:
  • Specificity Question: A threshold issue may be whether the complaint's generalized allegations against unspecified "systems, products, and services" provide sufficient notice of the basis for the infringement claim.
  • Architectural Question: A key technical question will be how the components of Defendant's air transport IT systems map onto the claimed architecture of a distinct "server," "wireless device (WD)," and "data rendering device (DRD)." The claim requires a specific interaction flow where a passcode entered at the DRD authorizes data release from the server, raising the question of whether the accused systems operate in this manner.
  • Functional Question: The claims require the server to render data "after at least one passcode is entered on said user interface that matches said passcode stored in said memory" (’285 Patent, col. 14:14-16). A central factual dispute may concern whether any authentication mechanism in the accused systems performs this specific matching and authorization function as claimed.

V. Key Claim Terms for Construction

• The Term: "passcode associated with said WD" (claim 1)

• Context and Importance: The definition of "passcode" is central to the infringement analysis, as it dictates the type of authentication mechanism covered by the claims. Practitioners may focus on this term because its scope will determine whether modern authentication factors used in the airline industry (e.g., booking references, scannable barcodes on a mobile device, biometrics) meet the claim limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests the term is not limited to numeric or alphanumeric strings, stating that "Passcode capabilities can include the use of passwords/passcodes, biometrics and/or communications security (COMSEC)" (’285 Patent, col. 5:42-44).
  • Evidence for a Narrower Interpretation: The claims require the passcode to be "entered at the user interface" of the DRD (’285 Patent, col. 13:42-44). This language, combined with flowcharts depicting "Enter Passcode" as a distinct step (e.g., ’285 Patent, Fig. 10, element 105), could support a narrower construction limited to information manually entered by a user at the rendering device itself.

• The Term: "data rendering device (DRD)" (claim 1)

• Context and Importance: The scope of this term defines the types of hardware that can be considered part of an infringing system. The dispute may turn on whether the accused airport kiosks, gate printers, or display monitors qualify as DRDs under the patent's definition.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent provides a broad list of examples, including "printers, copiers, displays," "Internet Kiosks," "multimedia projectors," and "automatic teller machines (ATMs)" (’285 Patent, col. 7:7-9; claim 2).
  • Evidence for a Narrower Interpretation: The specification also characterizes DRDs as "generally... 'undedicated' rendering devices (e.g., 'unassigned' as a resource and/or generally available and open to the acceptance and rendering of data from unfamiliar clients)" (’285 Patent, col. 5:7-11). This language may support an argument that the term is limited to general-purpose, publicly-accessible hardware, and excludes specialized, proprietary devices that are part of a closed system.

VI. Other Allegations

• Indirect Infringement: The complaint makes a passing and syntactically ambiguous reference to vicarious liability, stating that "Direct infringement of the method claims by Defendant is established because Defendant infringes vicariously by profiting from its customers use" of its products (Compl. ¶11). The complaint does not plead specific facts to support the elements of knowledge and intent required for a claim of induced infringement.

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

• A core issue will be one of pleading sufficiency: will the complaint's general allegations against unspecified "systems, products, and services," lacking an attached claim chart or specific facts mapping accused features to claim limitations, satisfy federal pleading standards?
• A key technical question will be one of architectural mapping: can the distributed components of Defendant’s air transport IT infrastructure be cleanly mapped onto the patent's distinct architecture of a "server," a "wireless device," and a "data rendering device," particularly given the specific passcode-based authorization flow required by the claims?
• The case will likely involve a significant dispute over definitional scope: can the term "passcode," rooted in the context of 2000-era security, be construed to cover modern authentication credentials used in the accused systems, such as QR codes or booking confirmation numbers?