UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

 DIVISION 

AERITAS, LLC, 

 Plaintiff 

 v. 

AIR CANADA 

 Defendant 

Case No. 6:20-cv-00061 

JURY TRIAL DEMANDED 

COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff Aeritas, LLC (“Aeritas” or “Plaintiff”) files this Complaint for patent 

infringement against Air Canada (“Defendant”), and alleges as follows: 

NATURE OF THE ACTION 

1. This is an action for patent infringement arising under 35 U.S.C. § 1 et seq. 

PARTIES 

2. Aeritas is a limited liability company organized and existing under the laws 

of the State of Texas with its principal place of business in Dallas, Texas. 

3. Upon information and belief, Air Canada is a corporation organized and 

existing under the laws of Canada. 

JURISDICTION AND VENUE 

4. This Court has original jurisdiction over the subject matter of this action 

pursuant to 28 U.S.C. §§ 1331 and 1338(a). 

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5. Upon information and belief, Defendant is subject to personal jurisdiction 

of this Court based upon it having regularly conducted business, including the acts 

complained of herein, within the State of Texas and/or deriving substantial revenue from 

goods and services provided to individuals in Texas and in this District. 

6. Venue is proper in this District under 28 U.S.C. § 1400 because Defendant 

has committed acts of infringement and has regular and established places of business 

in this judicial district. 

OVERVIEW OF THE AIR CANADA APPs 

7. Defendant provides for its customers use the Air Canada App, which is 

available for use with iOS and Android devices: 

https://apps.apple.com/us/developer/air-canada/id326459700

https://play.google.com/store/search?q=air%20canada

The Air Canada App requires a connection to a server in order to operate: 

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The Air Canada App provides notifications to the user: 

https://developer.android.com/guide/topics/permissions/requesting.html 

https://developer.android.com/guide/topics/permissions/normal-permissions.html 

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The Air Canada App provides notifications that deliver messages to the user based on 

notification criteria: 

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The Air Canada App shows currently tracked flights and booked flights: 

When location access is enabled, the Air Canada App provides notifications, such as 

delays, cancellations, etc: 

 

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After providing a notification, the Air Canada App receives additional data from the user 

when the user accesses the notification: 

 

The Air Canada App shows different data attributes, such as availability, schedule, and price: 

 

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The Air Canada App allow users to search for a destination using spoken input: 

The Air Canada App obtains access to and uses the location of the user’s device: 

The Air Canada App uses the spoken input in the process of searching for a location: 

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The Air Canada App uses spoken input in the process of booking a flight: 

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The Air Canada App uses the spoken input to obtain a list of possible airports: 

The Air Canada App provides additional information after the process of booking a flight 

using the spoken input: 

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The Air Canada App provides for mobile check-in and generation of a mobile boarding 

pass: 

 

 

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COUNT I 

(Infringement of U.S. Patent No. 7,706,819) 

8. Aeritas incorporates paragraphs 1 through 10 as though fully set forth 

herein. 

9. Plaintiff is the owner, by assignment, of U.S. Patent No. 7,706,819 (the 

“’819 Patent”), entitled MIXED-MODE INTERACTION, which issued on April 27, 2010. 

A copy of the ’819 Patent is attached as Exhibit PX-819. 

10. The ’819 Patent is valid, enforceable, and was duly issued in full compliance 

with Title 35 of the United States Code. 

11. Defendant has been and is now infringing one or more claims of the ’819 

Patent under 35 U.S.C. § 271 by making and using the Air Canada App with users’ iOS 

and Android devices in the United States without authority. 

12. Defendant has also infringed the ’819 Patent by encouraging users of the 

Air Canada App to use the user’s iOS or Android devices with the Air Canada App to 

practice the claims of the ’819 Patent. Defendant has notice of the ’819 Patent at least as 

of the date of service of this complaint. 

13. Claim 1 recites: 

1. A method comprising: 

receiving spoken input from a wireless communication device; 

obtaining data identifying a current location of the wireless 

communication device; 

based on the current location of the wireless communication device 

and the spoken input, retrieving information; 

delivering, to the wireless communication device by a notification 

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server, a non-verbal response to the spoken input, the nonverbal response based on the retrieved information and 

including a drill-down menu by which additional information 

related to the retrieved information can be obtained; and 

providing additional information related to the retrieved 

information in response to receipt of at least one additional 

input provided via the drill-down menu. 

14. More particularly, Defendant infringes at least claim 1 of the ’819 Patent. 

Defendant receives spoken input from a wireless communication device (e.g., when a user 

searches for a location or specific airport using voice input). Defendant obtains data 

identifying the current location of the mobile device (e.g., as evidenced by permissions 

required to access the device’s location and subsequent provision of location-based 

information). Based on the location and the spoken input, Defendant retrieves 

information (e.g., the nearby airport subject to the voice search). Defendant delivers to 

the wireless device by a notification server, a non-verbal response to the spoken input, 

the non-verbal response based on the retrieved information and including a scroll-down 

menu by which additional information related to the retrieved information can be 

obtained (e.g., the nearby airport subject to the voice search). Defendant provides 

additional information related to the retrieved information in response to receipt of at 

least one additional input provided via the scroll-down menu (e.g., price, availability and 

other flight information). 

15. Aeritas has been damaged by Defendant’s infringing activities. 

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COUNT II 

(Infringement of U.S. Patent No. 10,362,160) 

16. Aeritas incorporates paragraphs 1 through 7 as though fully set forth 

herein. 

17. Plaintiff is the owner, by assignment, of U.S. Patent No. 10,362,160 (the 

“’160 Patent”), entitled MIXED-MODE INTERACTION, which issued on July 23, 2019. 

A copy of the ’160 Patent is attached as Exhibit PX-160. 

18. The ’160 Patent is valid, enforceable, and was duly issued in full compliance 

with Title 35 of the United States Code. 

19. Defendant has been and is now infringing one or more claims of the ’160 

Patent under 35 U.S.C. § 271 by making and using the Air Canada App with users’ iOS 

and Android devices in the United States without authority. 

20. Defendant has also infringed the ’160 Patent by encouraging users of the 

Air Canada App to use the user’s iOS or Android devices with the Air Canada App to 

practice the claims of the ’160 Patent. Defendant has notice of the ’160 Patent at least as 

of the date of service of this complaint. 

21. Claim 1 recites: 

1. Apparatus, comprising: 

a processor; 

computer memory holding computer program instructions to: 

receive first data indicating a permission to provide a mobile device 

user a notification, the notification having an associated 

notification criteria; 

at a given time, receive information identifying a determined 

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location of a mobile device; 

based at least in part on a determined location of the mobile device 

and the notification criteria, to provide to the mobile device 

the notification, the notification being associated at the 

mobile device with one of: an audible, visual and tactile alert; 

receive second data as a result of an input being received at the 

mobile device following the notification; 

retrieve information associated with the input and the determined 

location of the mobile device; and 

provide to the mobile device a response to the input, the response 

based on the retrieved information. 

22. More particularly, Defendant infringes at least claim 1 of the ’160 Patent. 

On information and belief, Defendant employ a processor and computer memory holding 

computer program instructions to perform the functions described herein. Defendant 

receives information indicating that the user has provided permission to provide 

notifications to the user. Defendant asks for permission to obtain the user’s location and 

obtains the user’s location if permission is granted. When location access is granted, the 

Defendant provides a notification to the user, based on the location, alerting that the user 

can check into a flight, that there is a delay, a flight cancelation, or a change in departure 

location. Defendant receives additional data in the form of touchscreen input when the 

user responds to the notification, which launches a page corresponding to the notification. 

Defendant then displays a relevant page and provides additional information related to 

the notification. 

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23. Aeritas has been damaged by Defendant’s infringing activities. 

COUNT III 

(Infringement of U.S. Patent No. 9,390,435) 

24. Aeritas incorporates paragraphs 1 through 7 as though fully set forth 

herein. 

25. Plaintiff is the owner, by assignment, of U.S. Patent No. 9,390,435 (the 

“’435 Patent”), entitled MIXED-MODE INTERACTION, which issued on February 6, 

2018. A copy of the ’435 Patent is attached as Exhibit PX-435. 

26. The ’435 Patent is valid, enforceable, and was duly issued in full compliance 

with Title 35 of the United States Code. 

27. Defendant has been and is now infringing one or more claims of the ’435 

Patent under 35 U.S.C. § 271 by making and using the Air Canada App with users’ iOS 

and Android devices and servers in the United States without authority. 

28. Defendant has also infringed the ’435 Patent by encouraging users of the 

Air Canada App to use the user’s iOS or Android devices with the Air Canada App to 

practice the claims of the ’435 Patent. Defendant has notice of the ’435 Patent at least as 

of the date of service of this complaint. 

29. Claim 1 recites: 

1. Apparatus, comprising: 

a processor; 

computer memory holding computer program 

instructions to: 

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receive first data indicating a permission to provide a 

mobile device user a notification, the notification having an 

associated notification criteria; 

at a given time, determine a location of a mobile 

device; 

based at least in part on a determined location of the 

mobile device and the notification criteria, to provide to the 

mobile device the notification, the notification being 

associated at the mobile device with one of: an audible, 

visual and tactile alert; 

receive second data as a result of an input being 

received at the mobile device following the notification; 

retrieve information associated with the input and 

the determined location of the mobile device; and 

provide to the mobile device a response to the input, 

the response based on the retrieved information. 

30. More particularly, Defendant infringes at least claim 1 of the ’435 Patent. 

On information and belief, Defendant employs a processor and computer memory holding 

computer program instructions to perform the functions described herein. Defendant 

receives information indicating that the user has provided permission to provide 

notifications to the user. Defendant asks for permission to obtain the user’s location and 

obtains the user’s location if permission is granted. When location access is granted, the 

Defendant provides a notification to the user, based on the location, alerting that the user 

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can check into a flight, that there is a delay, a flight cancelation, or a change in departure 

location. Defendant receives additional data in the form of touchscreen input when the user 

responds to the notification, which launches a page corresponding to the notification. Defendant 

then displays a relevant page and provides additional information related to the notification.

31. Aeritas has been damaged by Defendant’s infringing activities. 

COUNT IV 

(Infringement of U.S. Patent No. 9,888,107) 

32. Aeritas incorporates paragraphs 1 through 7 as though fully set forth 

herein. 

33. Plaintiff is the owner, by assignment, of U.S. Patent No. 9,888,107 (the 

“’107 Patent”), entitled MIXED-MODE INTERACTION, which issued on February 6, 

2018. A copy of the ’107 Patent is attached as Exhibit PX-107. 

34. The ’107 Patent is valid, enforceable, and was duly issued in full compliance 

with Title 35 of the United States Code. 

35. Defendant has been and is now infringing one or more claims of the ’107 

Patent under 35 U.S.C. § 271 by making and using the Air Canada App with users’ iOS 

and Android devices in the United States without authority. 

36. Defendant has also infringed the ’107 Patent by encouraging users of the 

Air Canada App to use the user’s iOS or Android devices with the Air Canada App to 

practice the claims of the ’107 Patent. Defendant has notice of the ’107 Patent at least as 

of the date of service of this complaint. 

37. Claim 5 recites: 

5. Apparatus, comprising: 

a processor; 

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computer memory holding computer program instructions to: 

receive first data indicating a permission to provide a mobile device 

user a notification, the notification having an associated 

notification criteria; 

at a given time, determine a location of a mobile device; 

based at least in part on a determined location of the mobile device 

and the notification criteria, to provide to the mobile device 

the notification, the notification being associated at the 

mobile device with one of: an audible, visual and tactile alert; 

receive second data as a result of an input being received at the 

mobile device following the notification; 

retrieve information associated with the input and the determined 

location of the mobile device; and 

provide to the mobile device a response to the input, the response 

based on the retrieved information; 

wherein the computer program instructions comprise a rules engine 

that comprises first and second components, a first 

component that evaluates the notification criteria, and a 

second component that executes notification rules. 

38. More particularly, Defendant infringes at least claim 5 of the ’107 Patent. 

On information and belief, Defendant employs a processor and computer memory holding 

computer program instructions to perform the functions described herein. Defendant 

receives information indicating that the user has provided permission to provide 

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notifications to the user. Defendant asks for permission to obtain the user’s location and 

obtains the user’s location if permission is granted. When location access is granted, the 

Defendant provides a notification to the user, based on the location, alerting that the user 

can check into a flight, that there is a delay, a flight cancelation, or a change in departure 

location. Defendant receives additional data in the form of touchscreen input when the user 

responds to the notification, which launches a page corresponding to the notification. Defendant 

then displays a relevant page and provides additional information related to the notification. Upon 

matching flight notification with the user’s saved flight based on location, the Defendant provides 

a visual notification based on a rules engine evaluating notification criteria.

39. Aeritas has been damaged by Defendant’s infringing activities. 

COUNT V 

(Infringement of U.S. Patent No. 8,620,364) 

40. Aeritas incorporates paragraphs 1 through 7 as though fully set forth herein. 

41. Plaintiff is the owner, by assignment, of U.S. Patent No. 8,620,364 (the 

“’364 Patent”), entitled MIXED-MODE INTERACTION, which issued on December 31, 

2013. A copy of the ’364 Patent is attached as Exhibit PX-364. 

42. The ’364 Patent is valid, enforceable, and was duly issued in full compliance 

with Title 35 of the United States Code. 

43. Defendant has been and is now infringing one or more claims of the ’364 

Patent under 35 U.S.C. § 271 by making and using the Air Canada App with users’ iOS 

and Android devices in the United States without authority. 

44. Defendant has also infringed the ’364 Patent by encouraging users of the 

Air Canada App to use the user’s iOS or Android devices with the Air Canada App to 

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practice the claims of the ’364 Patent. Defendant has notice of the ’364 Patent at least as 

of the date of service of this complaint. 

45. Claim 1 recites: 

1. Apparatus, comprising: 

a processor; 

computer memory holding computer program instructions to execute 

a rules engine that correlates data identifying a location of a 

mobile communication device, consumer interest data, data 

associated with one or more inventory attributes, and 

notification criteria that defines when a notification is to be 

delivered to the mobile communications device and a type of 

such notification, and to generate a message for delivery to 

the mobile communication device if at least one matching rule 

in the rules engine is triggered and the notification criteria 

are met, the message identifying one or more suppliers in the 

location with inventory that a user of the mobile 

communication device has expressed an interest in as 

indicated by the consumer interest data; and 

computer memory holding computer program instructions executed 

by the processor to selectively deliver the message to the 

mobile communications device according to the notification 

criteria. 

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46. More particularly, Defendant infringes at least claim 1 of the ’364 Patent. 

On information and belief, Defendant employs a processor and computer memory holding 

computer program instructions to perform the functions described herein. Defendant 

receives information indicating that the user has provided permission to provide 

notifications to the user. Defendant asks for permission to obtain the user’s location and 

obtains the user’s location if permission is granted. When location access is granted, the 

Defendant obtains the user’s location. Defendant stores consumer interest items such as 

booked flights and tracked flights. Defendant stores data associated with available 

inventory, such as whether a flight is available on a certain date, etc. Defendant stores 

notification criteria to define when notifications are to be delivered to the user including 

the type of notification. Defendant utilizes a rules engine to evaluate when notification 

criteria are met. If the notification criteria are met, Defendant generates a message to be 

delivered to the user. The message identifies a supplier, such as an airport in the location 

of interest to the user. If the appropriate criteria are met, Defendant delivers the message 

to the user. 

47. Aeritas has been damaged by Defendant’s infringing activities. 

COUNT VI 

(Infringement of U.S. Patent No. 7,933,589) 

48. Aeritas incorporates paragraphs 1 through 7 as though fully set forth herein. 

49. Plaintiff is the owner, by assignment, of U.S. Patent No. 7,933,589 (the 

“’589 Patent”), entitled METHOD AND SYSTEM FOR FACILITATION OF WIRELESS 

E-COMMERCE TRANSACTIONS, which issued on April 26, 2011. A copy of the ’589 

Patent is attached as Exhibit PX-589. 

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50. The ’589 Patent is valid, enforceable, and was duly issued in full compliance 

with Title 35 of the United States Code. 

51. Defendant has been and is now infringing one or more claims of the ’589 

Patent under 35 U.S.C. § 271 by making and using the Air Canada App with users’ iOS 

and Android devices in the United States without authority. 

52. Defendant has also infringed the ’589 Patent by encouraging users of the 

Air Canada App to use the user’s iOS or Android devices with the Air Canada App to 

practice the claims of the ’589 Patent. Defendant has notice of the ’589 Patent at least as 

of the date of service of this complaint. 

53. Claim 39 recites: 

39. A method for facilitating a wireless transaction, comprising: 

at a first time, receiving a transaction request from a transaction 

requester using a wireless communications device, the 

transaction request associated with a wireless transaction 

defined by an authorization with respect to a product or 

service, and a multi-stage fulfillment action associated with 

the authorization, the fulfillment action including personal 

bodily access into a physical location or structure using the 

wireless communication device; 

transmitting, to said wireless communication device, a transaction 

code in response to the authorization of the transaction 

request, the transaction code being a two dimensional (2D) 

image that encodes information in two dimensions and is 

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configured such that it is capable of being output from the 

wireless communication device and optically scanned for 

authorizing the given action; 

at a second time distinct from the first time, and only if it is 

determined at the second time that a user of the wireless 

communication device is authorized to use the transaction 

code transmitted to the wireless communication device to 

facilitate the wireless transaction, optically scanning the 

transaction code from the visual display of the wireless 

communication device to partially complete the wireless 

transaction; and 

at a third time distinct from the first time and the second time and 

while the wireless transaction remains only partially 

complete, optically scanning the transaction code from the 

visual display of the wireless communication device to 

complete the wireless transaction and authorize personal 

bodily entry into the physical location or structure. 

54. More particularly, Defendant infringe at least claim 39 of the ’589 Patent. 

On information and belief, when used, the Air Canada mobile app receives a transaction 

request associated with the reservation and purchase of a boarding pass for air travel. 

The mobile boarding pass provides for personal bodily access to the secured area of an 

airport in order to board the plane for travel. The mobile boarding pass includes a twodimensional bar code image, which is displayable by the mobile device for access to the 

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secured area. To gain access to the secured area, the mobile boarding pass is scanned. 

Subsequently, the same mobile boarding pass provides for personal bodily access to the 

plane for the booked flight. To gain access to the plane, the mobile boarding pass is 

scanned. 

55. Aeritas has been damaged by Defendant’s infringing activities. 

COUNT VII 

(Infringement of U.S. Patent No. 7,209,903) 

56. Aeritas incorporates paragraphs 1 through 7 as though fully set forth herein. 

57. Plaintiff is the owner, by assignment, of U.S. Patent No. 7,209,903 (the 

“’903 Patent”), entitled METHOD AND SYSTEM FOR FACILITATION OF WIRELESS 

E_COMMERCE TRANSACTIONS, which issued on April 24, 2007. A copy of the ’903 

Patent is attached as Exhibit PX-903. 

58. The ’903 Patent is valid, enforceable, and was duly issued in full compliance 

with Title 35 of the United States Code. 

59. Defendant has been and is now infringing one or more claims of the ’903 

Patent under 35 U.S.C. § 271 by making and using the Air Canada App with users’ iOS 

and Android devices in the United States without authority. 

60. Defendant has also infringed the ’903 Patent by encouraging users of the 

Air Canada App to use the user’s iOS or Android devices with the Air Canada App to 

practice the claims of the ’903 Patent. Defendant has notice of the ’903 Patent at least as 

of the date of service of this complaint. 

61. Claim 22 recites: 

22. A method facilitating a wireless transaction, said transaction 

involving a payment obligation on behalf of a requester and a fulfillment 

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obligation on behalf of a provider to provide a product or service, 

comprising: 

receiving, by a transaction fulfillment system, a transaction request for a 

product or service from a transaction requester that has indicated 

an acceptance of an obligation to pay for said product or service; 

verifying an identity of the transaction requester; 

communicating a transaction code from the transaction fulfillment system 

to a wireless communication device after verifying the identity of the 

transaction requester, said code representative of said transaction 

requested; 

optically scanning, by the transaction fulfillment system, the transaction 

code from a visual display of the wireless communication device in 

fulfillment of said transaction for a product or service; and 

triggering, by said transaction fulfillment system, a wireless transaction 

fulfillment event in response to optically scanning said first 

transaction code whereby said provider fulfills said obligation to 

provide said product or service and said requested product or service 

is received. 

62. More particularly, Defendant infringes at least claim 2 of the ’903 Patent. 

On information and belief, when used, the Air Canada mobile app receives a transaction 

request associated with the reservation and purchase of a boarding pass for air travel. In 

the process of booking air travel, the user provides user identification information, which 

is verified. The mobile boarding pass provides for personal bodily access to a plane. The 

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mobile boarding pass includes a two-dimensional bar code image, which is displayable by 

the mobile device for access to a plane for travel. To gain access to the plane, the mobile 

boarding pass is scanned. 

63. Aeritas has been damaged by Defendant’s infringing activities. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff respectfully requests the Court enter judgment against 

Defendant: 

1. declaring that the Defendant has infringed the ’819, the ’160, the ’435, the 

’107, the ’364, the ’589, and the ’903 Patents; 

2. awarding Plaintiff its damages suffered as a result of Defendant’s 

infringement of the ’819, the ’160, the ’435, the ’107, the ’364, the ’589, and 

the ’903 Patents; 

3. awarding Plaintiff its costs, attorneys’ fees, expenses, and interest; and 

4. granting Plaintiff such further relief as the Court finds appropriate. 

JURY DEMAND 

Plaintiff demands trial by jury, Under Fed. R. Civ. P. 38. 

Dated: January 27, 2020 Respectfully submitted, 

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/s/ Raymond W. Mort, III 

Raymond W. Mort, III 

Texas State Bar No. 00791308 

raymort@austinlaw.com 

THE MORT LAW FIRM, PLLC 

100 Congress Ave, Suite 2000 

Austin, Texas 78701 

Tel/Fax: (512) 865-7950 

ATTORNEYS FOR PLAINTIFF 

 AERITAS, LLC 

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