Scientific Applications & Research Associates v. International

Background

Scientific Applications & Research Associates (SARA), Inc. sued Zipline International, Inc. for alleged infringement of U.S. Patent No. 7,606,115 and trade-secret misappropriation. The order addressed a claim-construction dispute concerning the word “noise” in claim 1 of the patent, which covers an acoustic collision-detection system for aircraft.

Claim 1 describes a digital signal processor that receives acoustic data, filters out “noise” and the host aircraft’s own acoustic signals, extracts signals from an approaching target, and assesses whether the aircraft and target may collide. SARA proposed that “noise” is not indefinite. Zipline proposed that the term is indefinite because its scope cannot be determined with reasonable certainty.

Court’s Analysis

Patent claims are indefinite when, read in light of the patent’s specification and prosecution history, they fail to inform skilled people with reasonable certainty about the scope of the invention. The party challenging validity must prove indefiniteness by clear and convincing evidence. Claim construction is the process of determining what patent-claim terms mean; indefiniteness is a legal question considered as part of that process.

The court relied primarily on the patent’s intrinsic evidence, meaning the claims, specification, and prosecution history. It identified three categories of acoustic input: signals from the host aircraft, signals from approaching aircraft, and “noise.” Because the claim separately refers to “noise” and the host aircraft’s own acoustic signals, the court concluded that “noise” excludes the host aircraft’s own signals.

The court construed “noise” as signals extraneous to the acoustic signals from the host aircraft or approaching aircraft. That construction gives the term an objective baseline: a signal’s classification depends on its source, not on a person’s subjective view of whether the signal is unwanted. The court also noted that the specification provides examples such as wind noise and noise from external mechanical vibrations.

The court declined to rely on Zipline’s expert testimony to create ambiguity that the patent’s text and specification had resolved. It concluded that a signal is “noise” under claim 1 if it is neither the host aircraft’s own acoustic signal nor an acoustic signal from an approaching aircraft.

Ruling

Judge Jacqueline Scott Corley adopted SARA’s construction and ruled that the term “noise” in claim 1 of the ’115 patent is not indefinite. The order disposed of Docket Nos. 37, 41, 42, and 44. It did not resolve the underlying patent-infringement or trade-secret-misappropriation claims.