PTAB

IPR2019-01566

Cirrus Design Corp v. Fleming Hoyt

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Intelligent Ballistic Parachute System That Performs Pre-Activation and/or Post-Activation Actions
  • Brief Description: The ’474 patent describes an aircraft equipped with a whole-aircraft ballistic parachute. The system uses one or more processors that, upon receiving a parachute activation request, determine if a pre-activation action (e.g., repositioning the aircraft) or a post-activation action is required and command its performance in conjunction with parachute deployment.

3. Grounds for Unpatentability

Ground 1: Claims 2, 3, 8, 10, 15, 132, and 135-139 are obvious over the SR22 POH in view of James.

  • Prior Art Relied Upon:
    • POH (Cirrus Design, Pilot’s Operating Handbook for the SR22 aircraft, Revision A7)
    • James (Patent 6,460,810)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of POH and James taught every limitation of the challenged claims. The POH, a publicly available manual for the Cirrus SR22 aircraft, disclosed an aircraft with a whole-aircraft ballistic parachute system (the CAPS) and detailed the manual procedures a pilot should perform for safe deployment. These procedures included pre-deployment actions such as reducing airspeed below 133 KIAS, increasing altitude, and achieving a wings-level attitude, as well as post-deployment actions like activating the Emergency Locator Transmitter (ELT). James disclosed a processor-based "Semiautonomous Flight Director" (SFD) designed to automate pilot actions in any aircraft with an autopilot. Critically, James taught an "emergency shutdown/deploy parachute" function, initiated by a single switch, which executes a customizable, pre-programmed sequence of actions, such as shutting off engines and activating locating beacons. Petitioner contended that POH provided the specific, necessary flight maneuvers for safe parachute deployment, while James provided the known processor-based framework for automating such maneuvers. The combination therefore rendered the claimed methods and systems obvious.
    • Motivation to Combine: Petitioner asserted multiple motivations for a Person of Ordinary Skill in the Art (POSA) to combine the references. The primary motivation was to improve flight safety and reduce pilot workload, an explicit goal of James. A POSA would have been motivated to automate the critical safety procedures taught by the POH using the programmable automation system of James, particularly to ensure proper execution in emergency scenarios like pilot incapacitation. Furthermore, James stated its system was intended for any aircraft with an autopilot, and the SR22 aircraft described in the POH was such an aircraft, making the combination a routine implementation of James for its intended purpose. Automating the POH's manual steps (e.g., reduce speed, level wings, activate ELT) with James's processor-based system was presented as a predictable application of known technology to improve a known system.
    • Expectation of Success: A POSA would have had a reasonable expectation of success. The POH's instructions for parachute deployment involved standard flight maneuvers (e.g., changing pitch, roll, engine power) that were well-known to be controllable by autopilots. James disclosed that its system was specifically designed to be customized for the "unique combination of flight laws of the particular aircraft flown" to ensure safe and logical operation. Therefore, programming James's SFD to execute the specific maneuvers taught by the POH on the SR22's existing autopilot would involve routine software implementation with a predictable and successful outcome.

4. Key Claim Construction Positions

  • "performing an action": Petitioner proposed this term means "carrying out or executing one or more pre- or post-activation changes to the physical status of the aircraft." This construction was argued to be critical because it distinguished the physical execution of a maneuver from the patent's disclosure of simply determining if an action is needed, aligning the claims with the prior art's teachings of automated flight control.
  • "one or more processors is coupled to [aircraft device]": Petitioner proposed this term means "one or more processors connected by communication interfaces that permit sending commands to and/or receiving data from [aircraft device]." This construction was central to mapping James, which described a processor (the APR) sending programming signals to control devices like the autopilot and engine, onto the claim limitations requiring functional coupling.
  • "the attitude of the aircraft": Petitioner proposed this term means "the orientation of the aircraft in three-dimensional space, including pitch, roll, and yaw." This construction, consistent with industry terminology, was important for demonstrating how the prior art's teachings of controlling pitch and roll met the claim limitation of "changing the attitude of the aircraft."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 2, 3, 8, 10, 15, 132, and 135-139 of the ’474 patent as unpatentable.