Aviation Capital Partners, LLC v. SH Advisors, LLC, 1:22-cv-01556

Plaintiff Aviation Capital Partners (Specialized Tax Recovery) sued SH Advisors (Situs Hawk) asserting infringement of three claims of U.S. Patent No. 10,956,988 and an Alabama tortious-interference claim arising from competing bids for Alabama Department of Revenue services.
The '988 patent claims a computer-implemented method (and system/medium counterparts) that combines FAA air-traffic control data and aircraft transponder data (speed/altitude) to detect gaps in location tracking, infer landings during indeterminate periods, and compute an aircraft's taxability status.
Plaintiff sought a preliminary injunction, which the court denied for lack of likelihood of success on the merits.
Defendant moved to dismiss under Rule 12(b)(6), arguing the asserted patent claims are invalid under 35 U.S.C. § 101 (abstract idea/no inventive concept) and that the state-law claim is barred by competitor's privilege.
The court found the asserted claims (claims 1, 13, 15) directed to an abstract idea and lacking an inventive concept under Alice, dismissed the patent count with prejudice for failure to state a claim, and dismissed the state-law claim without prejudice (declining supplemental jurisdiction).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are the asserted claims directed to an abstract idea (Alice step 1)?	Claims are a specific, multifaceted system for computing taxability using transponder data to fill gaps — not an abstract data-manipulation idea.	Claims merely collect and analyze data from multiple sources to fill gaps and compute taxability, an abstract idea analogous to Elec. Power.	Claims are directed to an abstract idea (collecting/synthesizing/analyzing aircraft data to determine taxability).
Do the claims supply an inventive concept (Alice step 2)?	The use of transponder speed/altitude to infer landings during indeterminate periods is a particular, practical application that supplies an inventive concept.	The steps use conventional, off-the-shelf technology and common-sense physics; no new or nonconventional implementation is claimed.	No inventive concept; the asserted claims add only conventional technology and common-sense application, so invalid under § 101.
Tortious-interference claim and related defenses; should federal court decide it?	Plaintiff alleges SH tortiously interfered with its relationship with the Alabama Department of Revenue.	Defendant raised competitor's-privilege defense; court questioned appropriateness of exercising federal jurisdiction over an Alabama-law claim.	Court dismissed the state-law claim without prejudice, declining supplemental jurisdiction after resolving federal patent issue.

Alice Corp. Pty. v. CLS Bank Int'l, 573 U.S. 208 (U.S. 2014) (establishes the two-step Alice/Mayo framework for patent-eligibility review under § 101)
Mayo Collaborative Servs. v. Prometheus Lab'ys, 566 U.S. 66 (U.S. 2012) (recognizes exceptions to § 101 for laws of nature, natural phenomena, and abstract ideas)
Bilski v. Kappos, 561 U.S. 593 (U.S. 2010) (§ 101 is a threshold legal issue; sets boundaries of ineligible subject matter)
Elec. Power Group, LLC v. Alstom S.A., 830 F.3d 1350 (Fed. Cir. 2016) (collecting/analyzing data from multiple sources held abstract)
Aatrix Software, Inc. v. Green Shades Software, Inc., 882 F.3d 1121 (Fed. Cir. 2018) (§ 101 can be decided at pleading stage when no factual disputes prevent resolution)
Int'l Bus. Machs. Corp. v. Zillow Grp., Inc., 50 F.4th 1371 (Fed. Cir. 2022) (distinguishes claims that improve computer capabilities from those that invoke computers as mere tools)
Thales Visionix Inc. v. United States, 850 F.3d 1343 (Fed. Cir. 2017) (requires sufficiently specific articulation of what claims are directed to for step one)
In re Killian, 45 F.4th 1363 (Fed. Cir. 2022) (claims that lack implementation detail on how to perform a result do not supply an inventive concept)
Bascom Glob. Internet Servs., Inc. v. AT&T Mobility LLC, 827 F.3d 1341 (Fed. Cir. 2016) (practical application of an abstract idea can, in some cases, supply an inventive concept)