honeywell du-885 lcd displays free sample

2023-01-03 12:32:11

Honeywell’s Primus Elite Synthetic Vision adds new levels of sophistication and safety enhancements to your cockpit. Synthetic vision realistically depicts the flight path as an easy-to-understand overlay on the primary flight display, just as it would appear out the cockpit windscreen.

honeywell du-885 lcd displays free sample

The baseline upgrade package includes situational awareness capabilities and safety enhancements, including electronic split screen Jeppesen charts* and enhanced graphical features capable of XM weather, the most advanced weather tool with extended range to find the best routes during flight. The new LCD displays are lightweight and twice as reliable as CRT units and allow operators to take full advantage of future technologies previously only available on new aircraft. The moving map feature is capable of overlaying XM graphical weather and video display features which support up to 8 cameras including an Enhanced Vision System (EVS).

Offered as an option with this upgrade is Honeywell SmartView™ synthetic vision system (SVS), a decision-making tool which helps crews make necessary short-term decisions while maintaining enhanced safety in all phases of flight. The SmartView™ features will become second nature for pilots and increase operational integrity when you need it the most.

honeywell du-885 lcd displays free sample

2 The enclosed technical data is export classified as EAR99. Its export is being transmitted under U.S. Export Administration Regulations designation NLR (No License Required) and is to be used solely by the individual / organization to whom it is addressed. Diversion contrary to U.S. export laws and regulations is prohibited. HONEYWELL CONFIDENTIAL: This copyrighted work and all information are the property of Honeywell International Inc., contain trade secrets and may not, in whole or in part, be used, duplicated, or disclosed for any purpose without prior written permission of Honeywell International Inc. All Rights Reserved. 2

5 Primus Elite Overview A new product designed to meet existing requirements with planned growth functionality to support future situational awareness enhancements and CNS/ATM progression Revolutionary technology allows LCD for CRT replacement Provides general purpose application processing and advanced graphics processing Data storage for application databases integrated in DU Supports a Paperless Terminal Charts and Maps solution I/O compliment meets DU 870 requirements with additional I/O for enhanced applications Ease of installation supports less than 15 day aircraft downtime Supports additional display control capability required for additional functionality for advanced situational awareness features Provides all formats for PFD, ND, EICAS No impact to flight operations due to differences in format appearance No impact to training requirements 5

7 RMU Products Status Name Description Status TSO date STC Date Primus Elite DU 885 Program Primus Elite DU 875 Program Primus Epic CDS/R LCD Display Upgrade for GV In-work Q ASC - 3Q2011 LCD Display Upgrade for GIV In-work Q ASC - 4Q2011 LCD Display Upgrade for GIVSP In-work Q ASC - 4Q2011 Global Express Q STC received - 3/18/2010 Available Now Q Amended STC - July, 2011 Citation X Q Amended TC 5/3/2011 LCD Display Upgrade for Primus Available Now Q Amended TC - July, /2000/2000XP equipped aircraft F-900 C/EX Available Now Q STC received - 3/18/2011 L650 Q Amended TC 10/14/2010 Available Now Q Amended TC Aug 2011 Phase IV C CDS/R - system enhancements Available Now Received Q Amended STC pending AFGS -902 Mod C - resolves TFR lockup issue Available Now March, 2011 Amended STC pending Phase I DUS Software v1.02 Phase II DUs Software v1.03 and later 7

13 Cursor Control Device (MC800) Map Button turns on geopolitical map with uplink Wx overlay Chart Button changes display to show Jepp charts Menu Button displays the MFD menu on the onside display MFD Button Returns the MFD to normal plan mode Data Set Knob zoom and scroll functions 13

14 Baseline Functionality Phase II Function / Feature Data Loader Notes DL-1000 Data Loader A new database loader that will be a form/fit replacement for the current DL-900/950. The DL-1000 and will provide: Secure Digital or USB interface supported Less than 30 minute load time for all databases Growth to support up to 8 displays and 8Gb of data USB Slot Secure Digital Slot 14

18 Primus Elite Baseline Functionality Function / Feature Video Select Nose Wheel Tail Cabin Bar RIB Digital Video Analog Video (NTSC) DU-885/875 Video Includes: Notes Two Analog Video Inputs NTSC, PAL, RS-170 One Digital Video Input Honeywell Remote Image Bus (Similar to DVI) Video control allows display of one selected video input port Discrete Outputs to control a Video Distribution Amplifier (Honeywell VDA-880) User Configurable Video Menu Video images are fixed size and cannot be zoomed. The entire image will fit within the page (no scrolling is necessary) and may be rotated 90 degrees Video select drop down to allow the selection of video source Can support up to 8 cameras when using a multiplexer. 18

20 XM WX Satellite Weather Option Function / Feature Electronic Moving Map w/ XM WX Satellite Weather Notes Initial release supports XM WX Satellite Weather XM receiver provides streaming data for the following Wx displays: NEXRAD NEXt-Generation RADar Storm Tops Satellite Imagery Winds AIRMETs - AIRman s METeorological Information SIGMETs SIGnificant METeorological Information Echo Tops Lightning Clear Air Turbulence Selected views are turned on and off using the check boxes next to the menu items CONUS (Continental United States) coverage map Multiple concurrent display formats Allows replay of NEXRAD with Winds, CAT and Satellite Imagery Drop down menus allow selection of weather views Geopolitical and water boundaries - no terrain. 20

22 Advanced Map - Future Option Future Capability Advanced Map Display Advanced Map Notes The Advanced Map Display feature will add obstacles, terrain, a vertical profile view and other select elements from Honeywell s Interactive Navigation (INAV) Display. This upgrade will further enhance the situational awareness display capabilities of the Primus Elite Flight Deck Upgrade. Lateral Map Vertical Map Sensor Data Overlay Interactivity, Display of NDB data Geopolitical, and Terrain data as layers Display of Terrain along the flight plan or aircraft track. Display of EGPWS or Weather features. Display of EGPWS, TCAS (incl. ADS-B), and Weather (airborne and uplink) as layers on top of lateral map. Controlled via CCD, allows selection / viewing of map information. 22

23 SmartView (SVS) Future Option Future Capability SmartView (SVS) SmartView (SVS) Notes SmartView reduces the pilots mental workload of trying to create this same picture by interpreting the information in current flight deck displays. The display blends symbology like runway centerlines and range rings with surrounding terrain in a display that is easy for flight crew to use without appearing cluttered. Accumulated more than 500 hours of flight simulator testing and 300 hours of flight test on Honeywell aircraft. EGPWS terrain database with >800 million flight hours FAA Certified World-wide coverage 23

25 Feature Improved Situational Awareness / Safety Reduced Cost of Ownership Primus Elite Value Proposition Primus 1000/2000/2000XP Primus 1000/2000/2000XP w/ Primus Elite Upgrade Electronic Charts and Maps Not available on primary displays Displays own ship position / Supports Paperless Terminal Charts and Maps Solution System Weight Reduction (*for Global Express) XM Weather Not available on primary displays Overlaid on Moving Map Video Display Not available on primary displays Up to 8 cameras available (Embraer not implementing feature) Display Reliability ~4000 MTBF ~8000 MTBF Display Warranty 2010 Yearly HAPP Pricing (A/C out of New Factory Warranty but within Primus Elite Upgrade Warranty) 2010 Yearly HAPP Pricing (A/C out of New Factory Warranty and out of Primus Elite Upgrade Warranty ) N/A Remaining New Factory Warranty Standard HAPP Contract Standard HAPP Contract lbs Maintenance - Cooling Filters Periodic change required Not required 24 months or Remaining New Factory Warranty (which ever is greater) ~$8,000 - $10,0000 savings per year on Standard HAPP Contract (based on 300 flight. hours) ~$4,000 - $6,0000 savings per year on Standard HAPP Contract (based on 300 flight. hours) 25

26 Feature Primus 1000 Increased Aircraft Value Confirmed Growth Path Primus Elite Value Proposition Primus 1000 w/ Primus Elite Upgrade 2010 Aircraft Bluebook 2010 A/C Value as listed (*) Global Express A/C Value as listed / Plus $750, (full list price for upgrade) Advanced Map Display Not available Adds obstacles, terrain, vertical profile view and other select elements from Honeywell s Interactive Navigation (INAV) Display SmartView (SVS) Not available SmartView is built on the reliable foundation of Honeywell s Enhanced Ground Proximity Warning System (EGPWS) terrain database. The merger of the EGPWS database information with Honeywell s advanced HUD symbology provides pilots an ambient, natural and continuous view into their flight path, terrain, and navigational environment without changing the way the crew uses their PFD. 26

28 Feature Why PlaneDeck Improved Situational Awareness / Safety Typical GIV With DU-880 CRT Displays Typical GIV With PlaneDeck LCD Upgrade Electronic Charts and Maps Not available on primary displays Displays own ship position / Supports Paperless Terminal Charts and Maps Solution XM Weather Not available on primary displays Overlaid on Moving Map Video Display Not available on primary displays Up to 16 Cameras 28

29 Feature Why PlaneDeck Reduced Cost of Ownership Typical GIV With DU-880 CRT Displays Typical GIV With PlaneDeck LCD Upgrade Display Reliability ~4000 MTBF ~8000 MTBF System Weight Reduction N/A lbs New Display Warranty Expired 36 months 2010 Yearly HAPP Pricing (A/C within 36 month New PlaneDeck Warranty) 2010 Yearly HAPP Pricing (A/C out of New PlaneDeck Warranty ) $33, (300 hours) $23, (300 hours) $33, (300 hours) $28, (300 hours) 2011 SPEX Pricing DU-880 Display Unit ($37,221) 29

30 Feature Why PlaneDeck Ease of Maintenance Typical GIV With DU-880 CRT Displays Typical GIV With PlaneDeck LCD Upgrade Avionics Cooling System Fans and Ducting Required Eliminated Cooling Filters and Maintenance Periodic change required Task eliminated Display Swapping 100 hour rotation required Task eliminated Procedure (1) Remove fan filters located on forward beam of support tray by removing retaining screws. (2) Using clean dry shop air, clean filter out by directing air into filter cone. (3) Inspect filter for condition and cleanliness. (4) Install filter in forward beam of support tray if it is serviceable or replace if filter was found to be damaged. NOTE: To extend DU Cathrode Ray Tube (CRT) life, it is recommended to rotate DUs at this time. 30

31 Feature Why PlaneDeck Increased Aircraft Value Typical GIV With DU-880 CRT Displays Typical GIV With PlaneDeck LCD Upgrade 2010 Aircraft Bluebook 2010 A/C Value as listed 2010 A/C Value as listed Plus $800, (full retail value of PlaneDeck upgrade) Page A Aircraft Bluebook 31

32 Feature Why PlaneDeck Confirmed Growth Path Typical GIV With DU-880 CRT Displays Typical GIV With PlaneDeck LCD Upgrade SmartView (SVS) Not available SmartView is built on the reliable foundation of Honeywell s Enhanced Ground Proximity Warning System (EGPWS) terrain database. The merger of the EGPWS database information with Honeywell s advanced HUD symbology provides pilots an ambient, natural and continuous view into their flight path, terrain, and navigational environment without changing the way the crew uses their PFD. 32

33 Feature Why PlaneDeck Confirmed Growth Path Typical GIV With DU-880 CRT Displays Typical GIV With PlaneDeck LCD Upgrade Enhanced Navigation Display Not available Adds obstacles, terrain, vertical profile view and other select elements from Honeywell s Interactive Navigation (INAV) Display IntuVue 3D Radar Interface Not available New 3-Dimensional volumetric scan & volumetric buffer weather radar 33

38 XM Weather XM Weather Is a Streaming Commercial Data Source available for U.S. and Canadian operators Provides selected weather data to the avionics system Broadcasts on the XM network Displays on the MFD Data received is a delayed view of weather XM Weather Display When the 1 st XM weather product is selected for display, the map half-range automatically changes to 500 nm Weather data is removed from the display if the half-range is changed to less than 500 nm 38

39 XM Weather Subscription Operators can subscribe through XM or Honeywell GDC GDC Subscription Only Aviator Pro Subscription available Go to Select Forms Select Flight Support Services Application Page 3 $1500/year $150 activation fee XM Subscription Must have U.S. address Aviator Lite (LT), Aviator and Aviator Pro Subscriptions Prices range from $34.99 to $99.99/month plus a one-time activation fee $75 Honeywell recommends the Aviator Pro which enables all available weather products to be displayed Note that packages show U.S. and Canada but Primus Elite will only display U.S. for more information 39

59 AIRMET Display This displays a graphical representation of AIRMETs (Airmen s Meteorological Information) on the map display When the cursor is placed on the AIRMET graphic for more than 1 second, the AIRMET type and expiration time is displayed Graphics are displayed in different colors The AIRMET Legend can be overlaid on the Moving Map 59

104 Display Unit (DU) Maintenance Page Primary purpose of DU maint function is to continuously scan all tests of DU DU Maint page displays list of all failed tests 104

106 Note on Loading Charts Phase I DUs do not support DL-1000 (use RJ45 connection and Dataloading Tool) Phase II DUs can use DL1000 and PreProcessor Tool Formats DB files downloaded from so they can be copied to USB stick or SD card Do not copy files directly from memory stick without using tool PreProcessor Tool does not support Windows 2000 To order Dataloader tool for use w/ RJ45 connection (Phase I DUs) or PreProcessor Tool (DL1000) contact Honeywell at or After DL-1000 is powered up, wait min of 15 sec before inserting USB 106

107 Service Information Letter (SIL) SIL Pub #D Rev 2 June 2011 Applicable to Primus Elite Display System DU-875 with SW v1.07 and prior (check maint. page for SW ver) Allows display of up to 50,625 charts which has recently been exceeded When user attempts to access chart beyond total limit, message UNABLE TO RETRIEVE CHART is displayed Charts that are inaccessible are in China, Mongolia and North Korea (ICAO code starting with Z ) and 50% of Australia (ICAO code starts with Y ) Honeywell has defined SW change that will increase chart limit Will be introduced as part of SW v1.08 Honeywell is working on an interim fix (Jepp Services Update Mgr JSUM) to allow operators to remove unneeded chart data from database Consult the SIL for JSUM Software Instructions 107

108 Potential Issues / Write-ups No Geopolitical lines on enhanced map Database not loaded FMS position not initialized FMS data not received Check that next waypoint, distance to go, etc displayed No XM displayed Verify subscription is valid Re-enable receiver subscription (through XM website) No XM will be displayed if aircraft is out of XM coverage area Red X or Display Blanking Have maintenance record data in troubleshooting sheets to be supplied S/W update in 2011 to address NVM Download have DM contact Honeywell for further instructions. TFRs not displayed Removed in SW 1.7 to be added back in 2011 METARS/TAFs not displayed Per design 108

honeywell du-885 lcd displays free sample

104 Display Unit (DU) Maintenance Page Primary purpose of DU maint function is to continuously scan all tests of DU DU Maint page displays list of all failed tests 104

honeywell du-885 lcd displays free sample

*494 *495 Thomas C. Grimm, Esquire, and Jack C. Schecter, Esquire, Morris, Nichols, Arsht & Tunnell, Wilmington, DE, for Plaintiffs, Honeywell International Inc., and Honeywell Intellectual Properties Inc.

This is a patent infringement case involving technology in the aviation industry. Plaintiffs, Honeywell International Inc. and Honeywell Intellectual Properties Inc. ("Honeywell"),[1] filed suit alleging infringement[2] of five patents (U.S. Patent Nos. 5,839,080 ("the "080 patent"), 6,219,592 ("the "592 patent"), 6,122,570 ("the "570 patent"), 6,138,060 ("the "060 patent"), and 6,092,009 ("the "009 patent")) against defendants, Universal Avionics Systems Corp. ("Universal")[3] and Sandel Avionics ("Sandel").[4]

The display patents teach two methods for displaying the alert information on a visual screen in the cockpit. The "060 patent claims a system which causes certain information, including the severity of an alert, to "pop-up" on the pilot"s screen. Similarly, the "009 patent claims a system which displays terrain information, as well as, compares the terrain and aircraft altitude and colors certain parts of the display based on this comparison.

Honeywell, the assignee of these patents, uses the technology of the patents in its Enhanced Ground Proximity Warning System ("EGPWS"). Honeywell asserts that each defendants" Terrain Awareness and Warning System ("TAWS") infringes.

Honeywell asserts that the claim construction precludes a grant of summary judgment because the accused Sandel and Universal products literally and/or equivalently infringe the patents-in-suit. To the extent that defendants disagree, Honeywell contends that the non-infringement motions should be denied as genuine issues of material fact exist.

Before analyzing the parties" arguments regarding literal infringement, the court must address the dispute regarding whether the doctrine of equivalents is applicable to this case. Sandel and Universal argue that Honeywell should be precluded from relying on equivalents because its expert report, authored by Dr. Hansman, contains no mention of this doctrine. In addition, Sandel contends that Dr. Hansman"s "belated doctrine of equivalents testimony" should be stricken since it resulted from improper coaching in violation of court rules.[30]

*500 According to the scheduling order entered in this matter, the exchange of initial expert reports operated on who had the burden of proof. Therefore, when the initial exchange of those reports occurred, Honeywell had the obligation to provide a "complete statement of all opinions to be expressed" by the expert "and the bases and reasons therefor," as well as, the data or other information considered by the expert in forming his opinions.[32] Since Honeywell"s position on the doctrine of equivalents is only supported by Dr. Hansman"s deposition testimony on direct examination and is not contained in his expert report, Honeywell is precluded from relying on his deposition testimony to argue infringement by equivalents.

Sandel asserts that at least five different limitations common to all the asserted claims are missing from its accused device, the ST3400 TAWS, as construed by the court. Universal asserts that its TAWS system does not include "flight path angle," "look ahead distance," "terrain floor boundary" and "highest hmax and lowest hmin terrain levels" expressed as numeric values as construed by the court. Defendants contend that Honeywell has failed meet its burden to provide evidence sufficient to raise a genuine issue of material fact with regard to each and every one of the claim limitations, and therefore, there can be no infringement.

Honeywell asserts that Universal"s system uses a flight path angle that varies depending on whether the aircraft is in level flight, climbing or descending. Honeywell points to Universal"s Software Requirements specification, which illustrate the envelopes for climb, level flight and descent as proof that the envelopes of Universal"s TAWS vary as a function of the flight path angle. Honeywell notes that nothing in its claims requires precluding the use of preset values.

Sandel argues that its TAWS system does not contain alert envelopes, while Honeywell contends that Sandel"s "search volume" satisfies the construed definition of an alert envelope. An "alert envelope" is a "term of art in avionics and means an at least 2-dimensional region in the vertical plane surrounded by a continuous boundary." In construing this limitation, the court relied on the claim language, which recognizes that an alert envelope is an area around the plane that is a danger zone.

Nevertheless, Sandel"s search volume arguably may constitute an alert envelope because the system defines a vertical clearance below the flight path of the aircraft. Honeywell cites to diagrams set forth in Sandel"s Design Requirements which suggest that the Sandel TAWS may create a two-dimensional region in the vertical plane surrounded by a continuous boundary. The documents provide that Sandel"s Forward Looking Terrain Avoidance ("FLTA") capability looks ahead along and ahead below the aircraft"s lateral and vertical flight path and provides an appropriate alert if a CFIT threat exists.

According to Sandel, the figure and text as set forth in the design requirements relied upon by Honeywell, are conceptual in nature and do not reflect the system"s actual implementation. Sandel notes that Honeywell has failed to challenge its explanation of how the TAWS operates, despite *503 reviewing the source codes, which show the accurate implementation of the system. However, the issues related to the figure and text set forth in the design requirement go to the weight of the evidence, as the parties dispute the proper operation of the Sandel system. As a result, disputed issues material to the function of Sandel"s system in relation to this claim term (alert envelope) exist.

Both Sandel and Universal assert that their respective systems calculate look ahead distance differently than set forth in the claim. "Look ahead distance" is construed as "a distance along the ground track of the aircraft that marks the outer limit of each alert envelope and that is a function of aircraft speed and time to complete an evasive maneuver." When construing the claim limitation, the court noted that Honeywell presented no evidence that showed a common understanding of "look ahead distance" at the time when the patent was filed in 1995. As such, the specification and prosecution history were used to understand the meaning of the term.

Sandel argues that the court"s construction includes solely the embodiment as disclosed in the specification, which defines look ahead distance in terms of time to complete a specific, corrective maneuver. As a result, Sandel asserts that there is clearly no disclosure in the specification of a fixed time embodiment of look ahead distance. Honeywell argues that the court"s construction did not limit the claim to specific evasive maneuvers or to the calculations in the specification.

Sandel"s TAWS calculates the forward extent of its alerting volume based on fixed times, nominally 60 seconds, which is referred to as a "time to impact" scheme. Sandel"s TAWS provides a "caution" alert at 60 seconds and a "warning" alert at 30 seconds, using the forward-looking extent of its alerting criteria. In certain conditions, such as when the aircraft nears the airport or is in a steep dive, the system can compress these times to eliminate some nuisance warnings. The system is predicated upon a certain predetermined amount of time before impact with the threatening terrain. According to Gibson, Sandel"s expert, the Sandel system provides the pilot time to decide what is the best course of action under the unique circumstances presented. Honeywell contends that this comment by Gibson shows that Sandel"s system calculates the look ahead distance consistent with the court"s construction because the time provided would allow the pilot to avoid terrain.

Universal asserts that its TAWS does not use look ahead distance as required by the patent claims. Like Sandel"s system, rather than calculate look ahead distance based on time to complete an evasive maneuver, Universal"s TAWS also uses a fixed "time to impact" which is a function of flight phase. Universal asserts that its TAWS look ahead distance does not depend on an aircraft"s ability to bank or its bank angle. Honeywell argues that Universal"s System Requirements for the TAWS describes Universal"s envelopes as a function of look ahead distance, which is calculated as a function of ground speed and look ahead time. Honeywell asserts that the look ahead times are set to a default of 30 and 60 seconds so that the boundaries of the envelope will give the pilot time to avoid the terrain.

At the time of the claim construction briefing and oral argument, Honeywell relied solely on the proposition that look ahead distance has a plain and ordinary meaning to one skilled in the art and required no construction. The court disagreed, finding that Honeywell presented no evidence showing a common understanding of the term at the time of the filing of the "080 patent application. As a result, there was no common usage in the art for the term in 1995. In such a circumstance, the patentee"s definition, as seen through the specification, controls the interpretation of the claim language.

When only one embodiment is provided, and the patentee fails to support a broad meaning of the disputed language, as in this case, the court may limit the patentee to that embodiment. In construing look ahead distance, the court turned to the specification and the prosecution history, and found that Sandel"s construction was consistent with the purpose of the invention. The single embodiment in the specification provides that the look ahead distance for a terrain advisory condition is considered first in determining the look ahead distance, on the assumption that the pilot could make a 30 bank turn at any time at a turning radius R. As a result, the look ahead distance is equal to the product of the speed of the aircraft and the total look ahead time. The calculation for the total look ahead time, as well as, equations for the elements within the calculation are described in detail in the specification, along with the calculation for the look ahead distance for the terrain warning. Clearly, the specification references certain equations (including calculations for R, T1, T2 and TG or roll) that are used to compute the time to complete an evasive maneuver. See also, Figure 5 and Table 1. In determining the time to complete an evasive maneuver, the invention provides and relies upon how to calculate the time to complete an evasive maneuver.[36] Although *505 Honeywell is not the moving party, it does have the burden of proving infringement. Therefore, it is obligated to produce facts which show that there is a genuine issue for trial.

In calculating look ahead distance, as noted by the specification and testified to by Hansman, Honeywell includes pilot reaction time as a component. Further, the specification does not describe a time to impact application or fixed times in its alerting criteria to calculate look ahead distance as Sandel"s and Universal"s systems do. Moreover, there is no evidence that either Sandel"s or Universal"s system uses pilot reaction time or an assumed or specific pilot reaction time in their determination of look ahead distance.[37] Although Sandel uses the term "look ahead distance" in its Design Requirements, that fact, in and of itself, does not rise to a genuine issue of material fact.[38] Similarly, Universal"s use of "look-ahead" terminology does not rise to a genuine issue of material fact. Therefore, the court finds that the "look ahead distance" of the accused devices do not infringe claims 1 and 9 (the independent claims) of the "080 patent. As a result, Sandel"s and Universal"s look ahead distance does not infringe the remaining asserted claims, since they are dependent of claims 1 and 9 and contain the same claim limitation.[39]

Both Sandel and Universal assert that their respective TAWS do not calculate a clearance below the aircraft in accordance with the construction of the claim limitation "terrain floor boundary." Terrain floor boundary was construed as "a boundary that extends downwardly below the aircraft which is proportional to the distance to the closest runway." When constructing this limitation, the court noted that Honeywell was estopped from asserting its patent against technology which uses some other variable to form the lower boundary of the alert zone.

In responding to Sandel"s motion, Honeywell refers to Sandel"s Design Requirements. Honeywell argues that "Figure 3-4: Search Volume" set forth in the design requirements show that Sandel"s system calculates a clearance below the aircraft. Honeywell asserts that Sandel"s Design Requirements also confirm that its TAWS includes a distance that is proportional to the distance to the closest runway. This argument is reflected in greater detail in Sandel"s "Equation 2: RRTC Level Flight Terrain/Obstacle Clearances," where the Terrain/Obstacle Clearance varies *506 in proportion to the Reff (the Effective Range from the airport/runway threshold and the aircraft). Honeywell cites numerous equations showing that the calculation of the effective range as distance to the runway changes. Honeywell argues that the Reff variable varies in proportion to the distance to the runway, and its patent does not exclude this variation in steps. Rather, according to Honeywell, the stepped variation is exactly what is shown in the example of the Honeywell patent, specifically Figure 6.

Sandel does not argue that its system makes this stepped variation calculation. However, Sandel again notes that Honeywell is trying to create an issue of fact by asserting that the Design Requirements somehow discredit the declaration of Leslie Corn (a software engineer and consultant to Sandel) that the clearance buffer is applied to specific terrain cells rather than as a "boundary ... below the aircraft." According to Sandel, this reliance on a conceptual drawing of its TAWS system is improper. Sandel argues that its system stores a "clearance buffer" in each terrain cell. The buffer is subtracted from the projected altitude for each cell and not used to generate a lower boundary for any part of an "envelope." As previously stated herein, disputed factual issues pertaining to the accuracy of the Sandel"s Design Requirement documents as representative of Sandel"s TAWS, that is, whether the TAWS calculates a clearance below the aircraft, is a question regarding the weight of the evidence that should be left to the finder of fact.

However, the Sandel TAWS does not meet the second part of the limitation which requires that terrain floor boundary be proportional to the distance to the closest runway. Although Honeywell correctly argues that Sandel"s clearance buffer varies as a function of "Effective Range," it has not shown that the calculation of the clearance buffer is proportionate to the distance to the nearest runway.

*507 Unlike the patented system, the focal point of the Universal TAWS is the destination runway. The system determines the phase of flight and ROC based on TERPS recommendations. Thus, a greater protection occurs when an aircraft is in the vicinity of a "closest runway," but not landing at that runway. As a result of its TAWS focal point, the Universal system, when an aircraft is in the vicinity of an airport, would disregard the closest runway and change the ROC only when its destination is reached. In explaining the operation of its system, Universal relies on the deposition of Patrick Krohn, its former Director of Advanced Displays, who testified that the TAWS determines flight phase and distance from the destination airport. Universal"s system does not just default to the closest runway, when the destination is not determined by FMS. As previously stated, the court"s construction defines the boundary as proportional to the distance to the closest runway.

Honeywell continues to assert infringement of claim 4 of the "060 patent and claims 27-33 of the "009 patent. The parties agree that these claims include the alerting logic set forth in the specification of the "080 patent. Honeywell and Sandel acknowledge that, pursuant 35 U.S.C. § 112 ¶ 6, claim 4 of the "060 patent includes the structural equivalents to the alerting logic.

[1] Honeywell International Inc. is a Delaware corporation with its principal place of business in New Jersey and Honeywell Intellectual Properties Inc. is an Arizona corporation with its principal place of business in Arizona.

[31] During his deposition, after being initially questioned by defense counsel on his comparison of the claims of the patents to defendants" products as based solely on direct infringement, he was requested to evaluate the alleged infringing products under the doctrine of equivalents during direct examination by Honeywell"s counsel.

[34] In light of this holding, the court need not address Sandel"s arguments regarding alleged improper coaching of Dr. Hansman. Moreover, the court need not resolve whether Honeywell should be estopped as a matter of law, from raising the doctrine of equivalents based on the prosecution history of the patents-in-suit.

[36] Although not part of the exhibits to this motion, in defendants" motion for invalidity based on the public use and on-sale bars, documents, in particular, notes maintained by the inventors (referred to as Muller-Grams) prior to the filing date show that time to impact was initially considered before developing the detailed equations for the time to complete an evasive maneuver. After those computations were developed, they were used rather than time to impact. Any subsequent modifications to or evaluation and testing of the system throughout its development did not rely upon time to impact. In fact, these notes reference the difference between the initial approach and what was eventually used in the Honeywell system and incorporated in the specification. Figure 5 of the patent is basically the same as drawing WX 11D captioned "turn distance calculation" contained in the Muller-Grams.

[37] Honeywell emphasizes Sandel"s Design Requirements as evidence that the TAWS computes look ahead distance consistent with the court"s construction. While the parties dispute whether these documents are an accurate representation of Sandel"s TAWS as implemented, the Design Requirements describe the search volume as consisting of a computed look ahead distance, which is "a lateral distance on both sides of the aircraft"s flight path," and calculated as a function of aircraft speed, with warning and caution times of 30 and 60 seconds, respectively.

[42] The October 16, 2003, memorandum opinion invalidated the the `hmax" claims and relative altitude claims as anticipated by the prior art in the field. However, these claims will also be evaluated regarding non-infringement to complete the analysis. Although Honeywell argued in the invalidity motion, which is repeated in its defense of this motion, that there was no case or controversy and therefore, the court lacks jurisdiction to consider these claims, this argument was rejected by the court in its invalidity opinion. Although case law provides that an infringement analysis is not required since there can be no infringement of an invalid claim, case law also suggests such an instruction is nonsense. See generally,Dow Chemical Co. v. Halliburton Oil Well Cementing Co., 324 U.S. 320, 65 S. Ct. 647, 89 L. Ed. 973 (1945); Smith v. United States, 136 Ct.Cl. 487, 145 F. Supp. 396 (1956); Spectra-Physics, Inc. v. Coherent, Inc., 827 F.2d 1524, 1535 (Fed.Cir.1987).

honeywell du-885 lcd displays free sample

Primus Elite is an upgrade to older SPZ-8000 series and Primus 1000 and 2000/2000XP flight decks. The upgrade includes replacing the cathode ray tube (CRT) display with new lightweight liquid-crystal displays (LCD). The Primus Elite displays also include enhanced capability of SVS (Synthetic vision system), Jeppesen Charts, Enhanced with XM weather, airports, Navaids, TAF, METARs, Geopolitical boundary, Airways, Airspace information, NOTAMs and many more features. The multi-function display will have cursor control device (CCD) to select the various above listed options.

honeywell du-885 lcd displays free sample

You Might Also Be Interested In