UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

AERITAS, LLC, 

 Plaintiff 

 v. 

CATHAY PACIFIC AIRWAYS LTD 

 Defendant 

Case No. 6:20-cv-00141 

JURY TRIAL DEMANDED 

COMPLAINT FOR PATENT INFRINGEMENT 

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

infringement against Cathay Pacific Airways LTD (“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, Cathay Pacific Airways LTD is a foreign 

corporation. 

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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). 

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. 

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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 CATHAY PACIFIC APP 

7. Defendant provides for its customers use the Cathay Pacific App, which 

is available for use with iOS and Android devices: 

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https://apps.apple.com/us/app/cathay-pacific/id305038764 

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https://play.google.com/store/apps/details?id=com.xs2theworld.cxmobile&hl=en_US 

The Cathay Pacific App requires a connection to a server in order to operate: 

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The Cathay Pacific App provides notifications to the user: 

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

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

 

The Cathay Pacific App provides notifications that deliver messages to the 

user based on notification criteria: 

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The Cathay Pacific App shows currently tracked flights and booked flights: 

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When location access is enabled, the Cathay Pacific App provides 

notifications, such as delays, cancellations, etc: 

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After providing a notification, the Cathay Pacific App receives additional data 

from the user when the user accesses the notification: 

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The Cathay Pacific App allow users to search for a destination using spoken 

input: 

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The Cathay Pacific App obtains access to and uses the location of the user’s 

device: 

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The Cathay Pacific App uses the spoken input in the process of searching for a 

location: 

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The Cathay Pacific App uses spoken input in the process of booking a flight: 

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The Cathay Pacific App uses the spoken input to obtain a list of possible 

airports: 

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The Cathay Pacific App provides additional information after the process of 

booking a flight using the spoken input: 

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The Cathay Pacific App provides for mobile check-in and generation of a 

mobile boarding pass: 

https://play.google.com/store/apps/details?id=com.xs2theworld.cxmobile&hl=en_US 

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COUNT I 

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

8. Aeritas incorporates paragraphs 1 through 7 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 Cathay Pacific 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 Cathay Pacific App to use the user’s iOS or Android devices with the Cathay 

Pacific 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; 

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delivering, to the wireless communication device by a notification 

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 

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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. 

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 Cathay Pacific 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 Cathay Pacific App to use the user’s iOS or Android devices with the Cathay 

Pacific 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: 

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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, receive information identifying a determined 

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. 

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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. 

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 Cathay Pacific 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 Cathay Pacific App to use the user’s iOS or Android devices with the Cathay 

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Pacific 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: 

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 

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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 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. 

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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 Cathay Pacific 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 Cathay Pacific App to use the user’s iOS or Android devices with the Cathay 

Pacific 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; 

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; 

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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 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 

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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 Cathay Pacific 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 Cathay Pacific App to use the user’s iOS or Android devices with the Cathay 

Pacific App to 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; 

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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. 

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 

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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. 

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

compliance with Title 35 of the United States Code. 

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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 Cathay Pacific 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 Cathay Pacific App to use the user’s iOS or Android devices with the Cathay 

Pacific 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 configured such that it is capable of 

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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 Cathay Pacific 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 two-dimensional bar code image, which is displayable by the mobile 

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device for access to the 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 Cathay Pacific 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 Cathay Pacific App to use the user’s iOS or Android devices with the Cathay 

Pacific 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: 

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22. A method facilitating a wireless transaction, said transaction 

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

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. 

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

Patent. On information and belief, when used, the Cathay Pacific 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 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. 

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Dated: February 24, 2020 Respectfully submitted, 

/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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