DCT

2:25-cv-08526

Wybotics Inc v. Zodiac Pool Systems LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-08526, C.D. Cal., 09/24/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants are subject to personal jurisdiction in the district, a substantial part of the events giving rise to the claims occurred there, and Defendants have purposefully directed enforcement activities at the district.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its robotic pool cleaners do not infringe five of Defendant’s U.S. patents and that two of those patents are invalid.
  • Technical Context: The technology concerns automated, self-propelled robotic pool cleaners, specifically addressing mechanical brushing mechanisms, removable filtration systems, and camera-based navigation for systematic cleaning.
  • Key Procedural History: The complaint details a long history of disputes between the parties, starting with a 2016 cease-and-desist letter. This history includes a prior district court lawsuit and an ITC investigation filed by Zodiac in 2022 concerning two of the patents-in-suit, both of which Zodiac voluntarily terminated in 2023. Zodiac subsequently sent new cease-and-desist letters regarding the other three patents-in-suit and filed a new lawsuit in the Eastern District of Texas. This history is foundational to the plaintiff’s assertion of an actual, justiciable controversy for this declaratory judgment action.

Case Timeline

Date Event
2007-12-21 Priority Date for ’029 and ’031 Patents
2012-07-10 Priority Date for ’207, ’766, and ’191 Patents
2013-03-12 Issue Date for U.S. Patent Nos. 8,393,029 and 8,393,031
2016-02-01 Zodiac sends cease-and-desist letter re: ’029 Patent (approx. date)
2021-05-11 Issue Date for U.S. Patent No. 11,003,191
2022-03-01 Issue Date for U.S. Patent No. 11,262,766
2022-07-29 Zodiac files "Prior California Lawsuit" and "Prior ITC Case"
2022-08-01 ITC institutes investigation re: ’029 and ’031 Patents (approx. date)
2023-02-21 Zodiac terminates Prior ITC Case
2023-03-29 Zodiac voluntarily dismisses Prior California Lawsuit
2024-01-23 Issue Date for U.S. Patent No. 11,808,207
2024-06-04 Zodiac sends cease-and-desist letter re: ’207, ’766, ’191 Patents
2025-05-23 Zodiac files "EDTX Lawsuit" re: ’029 and ’031 Patents
2025-06-02 Zodiac sends follow-up letter re: ’207, ’766, ’191 Patents
2025-09-22 Zodiac files amended complaint in EDTX Lawsuit to add other patents
2025-09-24 Complaint for Declaratory Judgment filed in C.D. Cal.

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 8,393,029 - “APPARATUS FOR CLEANING A SUBMERGED SURFACE INCLUDING A BRUSHING DEVICE DRIVEN BY MEMBERS FOR DRIVING THE APPARATUS ON THE SUBMERGED SURFACE”

The Invention Explained

  • Problem Addressed: Prior art robotic pool cleaners either used separate, complex mechanisms for driving the unit and rotating its brushes, or used wheels that also functioned as brushes, which was inefficient and limited material choices (’029 Patent, col. 1:40-56, col. 2:6-21). Separating these functions while maintaining a compact and reliable design was a challenge (’029 Patent, col. 2:39-49).
  • The Patented Solution: The invention discloses a mechanism where the same drive wheel that propels the cleaner also drives the rotating brush. This is achieved by an "internally toothed ring" fixed to the drive wheel, which engages a "brush pinion" connected to the brush assembly, causing the brush to rotate as the wheel turns (’029 Patent, col. 3:20-29; Fig. 4). This design integrates the drive and brushing functions into a single, compact system powered by the wheel's motion.
  • Technical Importance: This approach aimed to simplify the mechanics of robotic cleaners, reducing weight, complexity, and potential points of failure by eliminating the need for a separate motor or complex gear train for the brush (’029 Patent, col. 3:34-44).

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement of one or more claims (Compl. ¶42). The analysis below uses independent claim 1 as a representative claim.
  • Claim 1 of the ’029 Patent includes these essential elements:
    • A swimming pool cleaner with a body, an inlet, an outlet, and a pumping device.
    • A wheel configured for rotation with an internally toothed ring.
    • A brush assembly with a brush and a shaft.
    • A pinion that engages the internally toothed ring and is connected to the shaft, such that the wheel's rotation in a first direction causes the pinion and brush to rotate in the same direction.

U.S. Patent No. 8,393,031 - “APPARATUS FOR CLEANING A SUBMERGED SURFACE WITH REMOVABLE FILTRATION DEVICE”

The Invention Explained

  • Problem Addressed: The patent describes that cleaning removable filters in prior art pool cleaners was often inconvenient. Some designs required the user to invert the entire device, risking spillage of collected debris, while others had complex hydraulic paths that were inefficient and consumed more power (’031 Patent, col. 1:37-51).
  • The Patented Solution: The invention proposes a removable filtering device composed of two separable shells: a "first shell" that acts as a debris recovery pocket and a "second shell" that acts as a liquid inlet. The two shells fit together to form an "integral filtering casing" that can be easily removed from the top of the cleaner body (’031 Patent, col. 2:20-40; Fig. 5). Once removed, the shells can be separated, allowing for easy emptying and cleaning of the debris pocket (’031 Patent, col. 2:41-49).
  • Technical Importance: This design provides convenient, top-access removal of the filter assembly without needing to turn the cleaner upside down, simplifying maintenance for the end-user (’031 Patent, col. 2:32-38).

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement of one or more claims (Compl. ¶58). The analysis below uses independent claim 1 as a representative claim.
  • Claim 1 of the ’031 Patent includes these essential elements:
    • A swimming pool cleaner with a body containing a filtration chamber.
    • A filtering device positioned in the chamber, comprising:
    • A first shell with an opening and peripheral filtering walls defining a debris recovery space.
    • A second shell fitted to the first shell to close the opening, except for a water inlet passage.
    • The two shells are configured to be fitted together to form an integral, removable filtering casing.
    • After removal, the shells can be separated for emptying debris.

U.S. Patent No. 11,808,207 - “POOL CLEANING SYSTEM AND METHOD TO AUTOMATICALLY CLEAN SURFACES OF A POOL USING IMAGES FROM A CAMERA”

Technology Synopsis

This patent addresses the challenge of ensuring automated pool cleaners cover all surfaces effectively. The disclosed solution uses at least one camera to capture imagery of the pool surface, a controller to determine a "cleanliness characteristic" from that imagery, and a control signal to direct the cleaner's movement based on that characteristic, for example, to re-clean areas that are not satisfactory (’207 Patent, Abstract).

Asserted Claims

The complaint seeks a declaratory judgment of non-infringement of one or more claims (Compl. ¶73).

Accused Features

Zodiac's allegations target Wybotics' pool cleaners containing "Vision Tech," such as the Wybot M2 (Compl. ¶24).

U.S. Patent No. 11,262,766 - “POOL CLEANING SYSTEM AND METHOD TO AUTOMATICALLY CLEAN SURFACES OF A POOL USING IMAGES FROM A CAMERA”

Technology Synopsis

This patent, part of the same family as the ’207 Patent, also relates to a pool cleaning system that uses camera imagery to guide its operation. The system includes a self-propelled cleaner, a camera, and a controller that analyzes the imagery to determine a "cleanliness characteristic" and directs the cleaner's movement accordingly (’766 Patent, Abstract). It also discloses a portable electronic device for displaying a graphic of cleaned and uncleaned portions of the pool.

Asserted Claims

The complaint seeks a declaratory judgment of non-infringement of one or more claims (Compl. ¶80).

Accused Features

Zodiac's allegations target Wybotics' pool cleaners containing "Vision Tech" (Compl. ¶13, ¶24).

U.S. Patent No. 11,003,191 - “POOL CLEANING SYSTEM AND METHOD TO AUTOMATICALLY CLEAN SURFACES OF A POOL USING IMAGES FROM A CAMERA”

Technology Synopsis

This patent, also in the same family as the ’207 and ’766 Patents, describes a similar camera-based system for automated pool cleaning. It claims a system with a cleaner, camera, and controller that uses camera imagery to assess surface cleanliness and generate control signals to direct the cleaner's movement based on that assessment (’191 Patent, Abstract).

Asserted Claims

The complaint seeks a declaratory judgment of non-infringement of one or more claims (Compl. ¶87).

Accused Features

Zodiac's allegations target Wybotics' pool cleaners containing "Vision Tech" (Compl. ¶13, ¶24).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies a line of robotic pool cleaners as the "Accused Products," including models such as Wybot C1, Wybot C1 Pro, Wybot C1 Max, Wybot C2 Vision, Wybot M2, Wybot S2, Wybot S2 Pro, Wybot S2 Solar, Wybot S2 Solar Vision, AquaClean, Winny HJ3172, Bugson, Bugson Plus, and Aquamoto Scrubo Pro (Compl. ¶8).

Functionality and Market Context

  • The complaint describes these products as robotic pool cleaners designed and manufactured by Wybotics China and sold to distributors in the United States by Wybotics CA (Compl. ¶8, ¶10). Zodiac's allegations specifically mention that some of these products, like the Wybot M2, contain "Vision Tech," which presumably relates to camera-based navigation or cleaning systems (Compl. ¶24). The complaint alleges these products are sold on websites like wybotpool.com and on Amazon (Compl. ¶20-21).

IV. Analysis of Infringement Allegations

The complaint, being an action for declaratory judgment of non-infringement, does not contain a claim chart or detailed infringement allegations by the Plaintiff. Rather, it states that Defendant Zodiac has contended that the Accused Products directly and/or indirectly infringe one or more claims of the Patents-in-Suit (Compl. ¶42, ¶58, ¶73, ¶80, ¶87). The complaint does not provide sufficient detail for a claim-chart-based analysis of Zodiac's infringement theories.

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Scope Questions: Based on the technology, a central dispute for the '029 Patent may be whether the mechanical linkage in the Accused Products constitutes an "internally toothed ring" that is "fixedly joined to a wheel" and engages a "pinion" in the manner claimed. For the '031 Patent, a question may arise as to whether the filter assemblies in the Accused Products are formed from two distinct, separable "shells" that fit together to form an "integral filtering casing" as required by the claims.
  • Technical Questions: For the '207, '766, and '191 patents, a key technical question will be what functions the "Vision Tech" in the accused Wybotics products actually performs. Specifically, does it "determine a cleanliness characteristic" based on camera imagery and then "generate a control signal to direct movement" based on that specific determination, or does it use camera data for more general navigation (e.g., obstacle avoidance, wall detection) without performing the claimed cleanliness analysis and responsive control?

V. Key Claim Terms for Construction

Analysis is based on representative Claim 1 of the ’029 and ’031 Patents.

’029 Patent

  • The Term: "internally toothed ring which is fixedly joined to a wheel"
  • Context and Importance: The definition of this term is central to the mechanical operation claimed. The dispute may turn on how rigidly the term "fixedly joined" is interpreted and what structures qualify as an "internally toothed ring." Practitioners may focus on this term because the specific gear interface between the wheel and brush is the core of the claimed invention.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims do not specify the material of the ring or the method of joining, which may support an argument that any method of attachment that causes the ring to rotate with the wheel, whether molded as one piece or attached separately, falls within the claim scope.
    • Evidence for a Narrower Interpretation: The figures, such as Figure 4, show the toothed ring (5) as an integral, peripheral part of the wheel (2) (’029 Patent, Fig. 4). A defendant might argue this embodiment limits "fixedly joined" to a unitary or permanently bonded construction, excluding, for example, a snap-fit or screwed-on component.

’031 Patent

  • The Term: "integral filtering casing"
  • Context and Importance: This term defines the assembled state of the two-shell filter system. Infringement may depend on whether the filter assembly in the Accused Products, when assembled, functions as a single, unified "casing." Practitioners may focus on this term because it links the structural elements ("first shell," "second shell") to their combined function as a removable unit.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the shells being "fitted together so as to form an integral filtering casing" that can be removed "in one piece" (’031 Patent, col. 2:27-35). This language suggests that as long as the two components hold together as a single unit during removal, they meet the "integral" requirement, regardless of how they are latched or clipped together.
    • Evidence for a Narrower Interpretation: The term "casing" itself might imply a more rigid, enclosed structure than a simple basket with a lid. A defendant could argue that the term, read in light of the specification, requires a specific structural relationship between the shells that creates a sealed or semi-sealed hydraulic path, not just two pieces that are removably attached.

VI. Other Allegations

Indirect Infringement

  • The complaint states that Zodiac contends Wybotics "directly and/or indirectly infringes" the Patents-in-Suit (Compl. ¶42, ¶58, ¶73, ¶80, ¶87). However, the complaint does not plead specific facts alleged by Zodiac to support the knowledge and intent elements required for claims of induced or contributory infringement.

Willful Infringement

  • The complaint does not mention any allegations of willful infringement made by Zodiac.

VII. Analyst’s Conclusion: Key Questions for the Case

  1. Jurisdictional and Procedural Posture: A threshold issue, highlighted by the complaint's extensive procedural history, will be whether this declaratory judgment action in the Central District of California should proceed in parallel with, or be stayed or transferred in favor of, Zodiac’s later-filed infringement suit in the Eastern District of Texas.
  2. Mechanical Equivalence: For the ’029 Patent, the case may turn on a question of mechanical operation: does the gear mechanism in the Accused Products, which links wheel motion to brush rotation, function in substantially the same way to achieve the same result as the claimed "internally toothed ring" and "pinion," or does it represent a distinct, non-infringing design?
  3. Functional Scope of "Vision Tech": For the ’207, ’766, and ’191 patents, a core evidentiary question will be one of functional scope: does the accused "Vision Tech" system merely use a camera for general navigation and mapping, or does it perform the specific, claimed process of analyzing imagery to determine a "cleanliness characteristic" and then generating a control signal to direct movement based on that specific characteristic?