Seagulls are very much a type of bird to beware of.
Apparently, research has shown that they generally have no airborne predators because of their large size. Also, because they fly in ragged and competitive flocks they are quite used to roughing it with other birds so they don't seem to mind airborne collisions with other seagulls.
In other words they are too stupid to know or care that you are about to make mincemeat of them and may leave it all to you to avoid the mid-air.
The only worse type I can recall is a certain species of hawk in Central America that is so territorial that it will actually "tip in" with wings half-closed to attack anything else it sees as a threat to its patch, including aircraft.
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