Levine’s Infringement Contentions per Local Patent Rule 120
`
`Levine ‘618
`4. An aircraft maintenance system
`for use on an aircraft having a flight
`data recorder, the maintenance
`system comprising:
`
`Boeing AHM System
`Boeing Aircraft Health Management (AHM) is an aircraft maintenance system designed to
`provide airlines timely information about aircraft conditions to enable them to more
`efficiently manage aircraft maintenance.
`
`[LEV000002]
`
`All Boeing aircraft have a flight data recorder. See 14 C.F.R. §121.343.
`AHM uses the onboard ACARS system to transmit digital aircraft performance data while
`the aircraft is in flight, using one or more different communication networks.
`
`a transmitter portable to be placed
`on an aircraft, said transmitter
`configured for transmission of
`digital aircraft performance data
`across a communication network
`while said aircraft is in flight; and
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 1
`
`BOEING
`Ex. 1012, p. 1
`
`
`
`Levine ‘618
`4. An aircraft maintenance system
`for use on an aircraft having a flight
`data recorder, the maintenance
`system comprising:
`
`Boeing AHM System
`Boeing Aircraft Health Management (AHM) is an aircraft maintenance system designed to
`provide airlines timely information about aircraft conditions to enable them to more
`efficiently manage aircraft maintenance.
`
`[LEV000002]
`
`All Boeing aircraft have a flight data recorder. See 14 C.F.R. §121.343.
`AHM uses the onboard ACARS system to transmit digital aircraft performance data while
`the aircraft is in flight, using one or more different communication networks.
`
`a transmitter portable to be placed
`on an aircraft, said transmitter
`configured for transmission of
`digital aircraft performance data
`across a communication network
`while said aircraft is in flight; and
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 1
`
`BOEING
`Ex. 1012, p. 1
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`[LEV000002]
`
`
`
`[LEV000008]
`
`[LEV000013]; See also, LEV000016
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`The ACARS system uses VHF, HF or satellite communications, depending on the location
`of the aircraft relative to the ground station and the configuration of the aircraft. Each of
`Exhibit A
`Page 2
`
`BOEING
`Ex. 1012, p. 2
`
`
`
`Levine ‘618
`
`Boeing AHM System
`the VHF, HF and satellite transceivers is “portable” in the sense that it is a modular line
`replaceable unit (LRU).
`
`[LEV000018]
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 3
`
`BOEING
`Ex. 1012, p. 3
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`a central station connected to said
`communication network configured
`to receive and analyze said digital
`aircraft performance data to
`generate maintenance advice for
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`[LEV000020]
`AHM includes a ground component connected to the one or more communication
`networks the aircraft uses to transmit ACARS messages. The ground station is configured
`to receive the digital aircraft performance data transmitted from the aircraft; to analyze that
`data and generate maintenance advice that is provided to the aircraft operator by, for
`example, sending alerts and notifications “through the Internet, fax, mobile devices, e-mail
`Exhibit A
`Page 4
`
`BOEING
`Ex. 1012, p. 4
`
`
`
`Levine ‘618
`said aircraft while said aircraft is in
`flight,
`
`Boeing AHM System
`and pager services” and making the information available on MyBoeingFleet.com.
`[LEV000002]
`
`AHM information also goes to Boeing Operations Control Centers,
`which are staffed 24/7 to support airline operations teams. When the
`centers receive data from the AHM system and other sources, Boeing
`responds quickly, engaging suppliers, technical experts and
`engineering resources as needed to provide its airline customers with
`information, guidance and solutions.
`[LEV000022]
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 5
`
`BOEING
`Ex. 1012, p. 5
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`[LEV000022]
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 6
`
`BOEING
`Ex. 1012, p. 6
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`[LEV000025]
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 7
`
`BOEING
`Ex. 1012, p. 7
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`[LEV000002]
`
`The digital aircraft performance data transmitted from the aircraft and received at the
`central station includes an “Airplane Identifier” that is unique to the particular aircraft that
`sent the data.
`
`wherein said digital aircraft
`performance data includes an
`identifier unique to a particular
`aircraft and a configuration label,
`and at least a portion of said digital
`aircraft performance data comprises
`data directed to the flight data
`recorder
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 8
`
`BOEING
`Ex. 1012, p. 8
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`[LEV000007]
`
`On information and belief, the digital aircraft performance data transmitted from the
`aircraft and received at the central station also includes a configuration label indicating, for
`example, the specific make and model of modules currently installed on the aircraft and/or
`the software version and/or software updates currently installed on any such modules or on
`any other system on the aircraft.
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 9
`
`BOEING
`Ex. 1012, p. 9
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`At least some of the digital aircraft performance data transmitted from the aircraft to the
`ground stations as part of AHM is also directed to the aircraft’s flight data recorder (FDR).
`For example, 14 CFR §121, Appendix M requires hydraulic pressure and certain fluid
`levels to be recorded on the FDR. LEV000033-34. These same parameters are transmitted
`via AHM.
`
`In addition, AHM can monitor trends in airplane performance
`factors such as fuel burn, oxygen levels, fluid levels, and hydraulic
`pressure so that any off-nominal conditions can be serviced during
`scheduled maintenance.
`[LEV000042]
`
`Boeing aircraft have a Central Maintenance Computer (CMC) and/or a Digital Flight Data
`Acquisition Unit (DFDAU), each of which has a plurality of inputs for receiving signals
`from aircraft sensors, including signals related to both aircraft performance parameters and
`aircraft control parameters. Each of the CMC and DFDAU has at least one output in
`communication with the one or more transmitters in order to provide digital aircraft
`performance data to the transmitter. Each of the CMC and the DFDAU is a sensor
`multiplexer.
`
`5. The aircraft maintenance system
`of claim 4 further comprising:
`a sensor multiplexer located on said
`aircraft, said sensor multiplexer
`having a plurality of inputs for
`receiving aircraft performance and
`control parameters from existing
`aircraft sensors, and an output in
`communication with said
`transmitter for providing said
`digital aircraft performance data to
`said transmitter
`
`[LEV000055]
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 10
`
`BOEING
`Ex. 1012, p. 10
`
`
`
`Levine ‘618
`
`Boeing AHM System
`See, e.g., Teledyne’s DFDAU 2233000-8XX:
`
`8. The aircraft maintenance system
`of claim 4 wherein said digital
`aircraft performance data includes
`aircraft position data directed to
`said flight data recorder.
`
`[LEV000057]
`As set forth in 14 CFR §121, Appendix M, “Latitude and Longitude,” i.e., aircraft position,
`are among the data that must be recorded on the FDR. [LEV000032]
`
`The latitude and longitude data is also sent as part of the aircraft performance data sent to
`the AHM ground station. See, video demonstration of AHM showing its use of aircraft
`position data at
`http://www.boeing.com/boeing/Features/2013/07/bca_airplane_health_mgmt_07_30_13.pa
`ge
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 11
`
`BOEING
`Ex. 1012, p. 11
`
`
`
`Levine ‘618
`9. The aircraft maintenance system
`of claim 8 wherein information
`provided by a GPS receiver is used
`in the calculation of said aircraft
`position data.
`10. The aircraft maintenance system
`of claim 9 wherein information
`provided by an inertial navigation
`system is used in the calculation of
`said aircraft position data.
`14. An aircraft maintenance system
`comprising:
`
`Boeing AHM System
`On information and belief information provided by a GPS receiver is used to calculate the
`aircraft position data transmitted to the AHM ground station.
`
`On information and belief information provided by an inertial navigation system is used to
`calculate the aircraft position data transmitted to the AHM ground station.
`
`Boeing Aircraft Health Management (AHM) is an aircraft maintenance system designed to
`provide airlines timely information about aircraft conditions to enable them to more
`efficiently manage aircraft maintenance.
`
`[LEV000002]
`
`a transmitter positionable to be
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`AHM uses the onboard ACARS system to transmit data while the aircraft is in flight,
`Exhibit A
`Page 12
`
`BOEING
`Ex. 1012, p. 12
`
`
`
`Levine ‘618
`located on an aircraft, said
`transmitter configured for
`transmission of data across a
`communication network while said
`aircraft is in flight;
`
`Boeing AHM System
`using one or more different communication networks.
`
`[LEV000002]
`
`
`
`[LEV000008]
`
`[LEV000013]; See also, LEV000016
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 13
`
`BOEING
`Ex. 1012, p. 13
`
`
`
`Levine ‘618
`
`Boeing AHM System
`The ACARS system uses VHF, HF or satellite communications, depending on the location
`of the aircraft relative to the ground station and the configuration of the aircraft. Each of
`the VHF, HF and satellite transceivers is “positionable” in the sense that it is a modular
`line replaceable unit (LRU).
`
`[LEV000018]
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 14
`
`BOEING
`Ex. 1012, p. 14
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`a ground based station connected to
`said communication network
`configured to receive and analyze
`said transmission of data, while said
`aircraft is in flight, to generate
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`[LEV000020]
`AHM includes a ground component connected to the one or more communication
`networks the aircraft uses to transmit ACARS messages. The ground station is configured
`to receive the digital aircraft performance data transmitted from the aircraft; to analyze that
`data and generate maintenance advice that is provided to the aircraft operators by, for
`example, sending alerts and notifications “through the Internet, fax, mobile devices, e-mail
`Exhibit A
`Page 15
`
`BOEING
`Ex. 1012, p. 15
`
`
`
`Levine ‘618
`maintenance advice for said
`aircraft; and
`
`Boeing AHM System
`and pager services” and making the information available on MyBoeingFleet.com.
`LEV0001 at 2.
`
`AHM information also goes to Boeing Operations Control Centers,
`which are staffed 24/7 to support airline operations teams. When the
`centers receive data from the AHM system and other sources, Boeing
`responds quickly, engaging suppliers, technical experts and
`engineering resources as needed to provide its airline customers with
`information, guidance and solutions.
`[LEV000022]
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 16
`
`BOEING
`Ex. 1012, p. 16
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`[LEV000022]
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 17
`
`BOEING
`Ex. 1012, p. 17
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`[LEV000025]
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 18
`
`BOEING
`Ex. 1012, p. 18
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`[LEV000002]
`
`Boeing aircraft have a Central Maintenance Computer (CMC) and/or a Digital Flight Data
`Acquisition Unit (DFDAU), each of which has a plurality of inputs for receiving signals
`from aircraft sensors, including data related to both aircraft performance parameters and
`aircraft control parameters. Each of the CMC and DFDAU has at least one output in
`communication with the one or more transmitters in order to provide this data to the
`transmitter. Each of the CMC and the DFDAU is a sensor multiplexer.
`
`a sensor multiplexer located on said
`aircraft, said sensor multiplexer
`having a plurality of inputs for
`receiving aircraft performance and
`control parameters from aircraft
`sensors as said data and an output in
`communication with said
`transmitter for providing said data
`to said transmitter;
`
`[LEV000055]
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 19
`
`BOEING
`Ex. 1012, p. 19
`
`
`
`Levine ‘618
`
`Boeing AHM System
`See, e.g., Teledyne’s DFDAU 2233000-8XX:
`
`wherein said data further includes
`an aircraft identifier unique to a
`particular aircraft and a
`configuration label.
`
`[LEV000057]
`The data transmitted from the aircraft and received at the central station includes an
`“Airplane Identifier” that is unique to the particular aircraft that sent the data.
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 20
`
`BOEING
`Ex. 1012, p. 20
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`[LEV000007]
`
`On information and belief, the digital aircraft performance data transmitted from the
`aircraft and received at the central station also includes a configuration label indicating, for
`example, the specific make and model of modules currently installed on the aircraft and/or
`the software version and/or software updates currently installed on any such modules or on
`any other system on the aircraft.
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 21
`
`BOEING
`Ex. 1012, p. 21
`
`
`
`Levine ‘618
`
`Boeing AHM System
`
`16. The aircraft maintenance system
`of claim 14 wherein said ground
`based station includes a storage
`system for archiving said aircraft
`performance and control
`parameters.
`
`The Boeing AHM ground component includes a storage system, .e.g., “Data Warehouse”
`and “Fault Database,” for archiving the aircraft performance and control parameters
`received from the aircraft.
`
`[LEV000025]
`
`LEVINE’S INFRINGEMENT CONTENTIONS
`CIVIL ACTION NO. 14-CV-01991-RSL
`
`Exhibit A
`
`Page 22
`
`BOEING
`Ex. 1012, p. 22
`
`
`
`PROOF OF SERVICE
`I am employed in the County of Los Angeles, State of California. I am over the age of
`eighteen years and not a party to the within action; my business address is 865 South Figueroa
`Street, 10th Floor, Los Angeles, California 90017-2543.
`
`On February 27, 2015, I served true copies of the following document(s) described as
`PLAINTIFF SEYMOUR LEVINE’S DISCLOSURE OF ASSERTED CLAIMS AND
`INFRINGEMENT CONTENTIONS on the interested parties in this action as follows:
`
`SEE ATTACHED LIST
`
`BY ELECTRONIC MAIL TRANSMISSION: By electronic mail transmission from
`abbyvalenzuela@quinnemanuel.com on February 27, 2015, by transmitting a PDF format copy of
`such document(s) to each such person at the e mail address listed below their address(es). The
`document(s) was/were transmitted by electronic transmission and such transmission was reported
`as complete and without error.
`
`I declare that I am employed in the office of a member of the bar of this Court at whose
`direction the service was made.
`
`Executed on February 27, 2015, at Los Angeles, California.
`
`/a/ Abigail Valenzuela
`Abigail Valenzuela
`
`1
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`
`
`BOEING
`Ex. 1012, p. 23
`
`
`
`SERVICE LIST
`
`Adam R. Lawton, CSBA # 252546
`adam.lawton@mto.com
`Edward G. Dane, CSBA # 143195
`ted.dane@mto.com
`Peter E. Gratzinger, CSBA # 228764
`peter.gratzinger@mto.com
`MUNGER TOLLES & OLSON LLP
`355 South Grand Avenue, 35th Floor
`Los Angeles, CA 90071-1560
`Tel: 213.683.9100
`
`Ryan J. McBrayer, Esq.
`PERKINS COIE LLP
`RMcBrayer@perkinscoie.com
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101-3099
`Telephone: (206) 359-3073
`Fax: (206) 359-4073
`
`Rohit Singla, CSBA # 213057
`rohit.singla@mto.com
`MUNGER TOLLES & OLSON LLP
`560 Mission Street, 27th Floor
`San Francisco, CA 94105
`Tel: 415.512.4000
`
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`BOEING
`Ex. 1012, p. 24
`
`
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