DCT

8:26-cv-00114

Optimum Vector Dynamics LLC v. SharkNinja Operating LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:26-cv-00114, C.D. Cal., 01/15/2026
  • Venue Allegations: Venue is based on Defendant allegedly maintaining regular and established places of business within the Central District of California, including offices in Chino and Irvine, and conducting substantial business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s intelligent robotic vacuums and their associated mobile application infringe a patent related to vehicle navigation systems that manage route deviations from pre-set waypoints.
  • Technical Context: The technology at issue originates in the automotive navigation field, addressing how a system should respond when a user deviates from a planned route, and is now being applied to the autonomous navigation of robotic home appliances.
  • Key Procedural History: The complaint notes that the asserted patent, U.S. Patent No. 8,649,971, was the subject of an inter partes review (IPR) proceeding where the Patent Trial and Appeal Board denied institution on May 16, 2024, indicating the patent survived an initial validity challenge. The complaint also highlights the patent examiner's Reasons for Allowance, which emphasized the novelty of the claimed system for outputting a deviation message and inputting a user command in response.

Case Timeline

Date Event
2008-04-02 ’971 Patent Priority Date
2014-02-11 ’971 Patent Issue Date
2024-05-16 Decision Denying Institution of Inter Partes Review
2025-05-31 ’971 Patent Assigned to Plaintiff
2026-01-15 Complaint Filing Date

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

U.S. Patent No. 8,649,971 - *"Navigation Device"*

  • Patent Identification: U.S. Patent No. 8,649,971 (“Navigation Device”), issued February 11, 2014.

The Invention Explained

  • Problem Addressed: The patent addresses a user-friendliness problem in conventional navigation systems. When a driver deviates from a pre-planned route with multiple waypoints (e.g., intentionally skipping one), these systems would often automatically re-search for a route back to the missed waypoint, which may be contrary to the driver's intent (’971 Patent, col. 2:48-55).
  • The Patented Solution: The invention proposes a system that detects not just a deviation, but a specific type of deviation: when the vehicle is off the original path but is now traveling on a section of the route that occurs after the missed waypoint (’971 Patent, col. 8:36-40; Fig. 6-1, step ST23). Instead of automatically re-routing, the system outputs a message to the user, asking for a command on whether to return to the missed waypoint or continue on the new path, thereby giving the user control over the navigation logic (’971 Patent, Abstract; col. 2:19-26).
  • Technical Importance: This solution provides a more interactive and user-controlled navigation experience, preventing unwanted automatic re-routing and enhancing the system's utility for complex, multi-stop journeys (Compl. ¶ 16).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 1 (Compl. ¶ 26).
  • Independent Claim 1 of the ’971 Patent recites the following essential elements for a navigation device:
    • A setting unit configured to set waypoints and a destination.
    • A route searching unit configured to search for a whole route to the destination via the set waypoints.
    • A route guidance unit configured to carry out route guidance according to the searched route.
    • An output unit configured to output a message showing a deviation when the device determines the vehicle has deviated a predetermined distance and is traveling on the route after the first next waypoint.
    • An input unit configured to input a command indicating whether to travel via the first next waypoint in response to the message.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

  • The "SharkNinja Accused Products" are a range of intelligent robotic vacuums, including the Shark Matrix, Shark AI, and Shark Navigator series, which operate in conjunction with the SharkClean mobile application (Compl. ¶¶ 7, 9).

Functionality and Market Context

  • The accused products are autonomous cleaning devices that use "AI Laser Navigation" to create an interactive map of a user's home within the SharkClean app (Compl. ¶ 27; p. 11). Users can define specific rooms, create "no-go zones," and schedule targeted cleaning sessions (Compl. ¶ 28). The complaint alleges that these features for customized cleaning paths correspond to the claimed navigation technology (Compl. ¶ 27). The complaint includes an infographic from Defendant's website claiming "$5.5bn Net Sales" and "5,200+ Patents" to establish SharkNinja as a "major presence in the home cleaning and robot space" (Compl. ¶ 8; p. 4). A screenshot from a product manual illustrates the robot's ability to navigate around obstacles and follow user-defined "no-go zones" (Compl. p. 11).

IV. Analysis of Infringement Allegations

’971 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a setting unit configured to set waypoints and a destination The SharkClean app allows users to create a map of their home and define rooms, no-go zones, or high-traffic zones for cleaning, which allegedly function as waypoints and a destination. A screenshot shows the app interface for editing a map to set these zones. ¶28; p. 10 col. 2:1-2
a route searching unit configured to search for a whole route leading to the destination via the waypoints set by said setting unit The robotic vacuum's software plans a cleaning path ("whole route") to cover the designated rooms ("destination") while observing the user-defined zones ("waypoints"). ¶29 col. 2:2-5
a route guidance unit configured to carry out route guidance according to the whole route which is searched for by said route searching unit The robotic vacuum physically executes the planned cleaning path, moving through the home according to the generated map and instructions. ¶30 col. 2:5-7
an output unit configured to output a message showing that a vehicle has deviated from a route... when said route guidance unit determines that the vehicle has deviated... and is traveling along a route after said first next waypoint The complaint alleges that the SharkClean app can be configured to send push notifications to the user if the robot gets stuck or encounters an error, which is alleged to be a deviation message. A screenshot shows the app's setting for "Cleaning error notifications." ¶¶31, 32; p. 15 col. 2:7-12
an input unit configured to input a command indicating whether or not to travel via said first next waypoint in response to the message outputted by said output unit User interactions with the app, such as initiating a "Whole-Home Cleaning" or "Single-Room Matrix Clean," or using features like "Recharge and Resume," are alleged to be commands that control the robot's navigation in response to its status. ¶33 col. 2:12-14
  • Identified Points of Contention:
    • Scope Questions: The infringement theory raises the question of whether the term "vehicle", as used in a patent describing on-road automotive navigation, can be construed to read on a robotic vacuum cleaner operating inside a home. A related question is whether a "no-go zone" (an area to be avoided) or a "room to clean" (an area to be covered) in the accused products functions as a "waypoint" (a point to be transited) as described in the patent.
    • Technical Questions: A central technical question is whether the accused product’s general "error" or "stuck" notification (Compl. ¶ 31) meets the specific, two-part condition required by Claim 1: that the message is triggered only when the device has (1) deviated by a predetermined distance and (2) is currently traveling on a portion of the planned route that comes after the missed waypoint. The complaint does not provide evidence that the accused notifications operate under this specific logic.

V. Key Claim Terms for Construction

  • The Term: "vehicle"

    • Context and Importance: This term's construction is fundamental to the case's applicability. If limited to its context in the patent, it may not cover robotic vacuums. Practitioners may focus on this term because the patent's specification exclusively discusses automotive applications.
    • Intrinsic Evidence for a Broader Interpretation: The term itself is not explicitly defined, which may support an argument for applying its plain and ordinary meaning, which can encompass any machine that transports people or objects.
    • Intrinsic Evidence for a Narrower Interpretation: The entirety of the patent's detailed description, including figures and embodiments, describes the invention in the context of a car with a GPS receiver, speed sensors, and road information systems (’971 Patent, Fig. 1; col. 3:5-10, col. 4:5-13). This context may support a narrower construction limited to automobiles or similar transport.

  • The Term: "output a message showing that a vehicle has deviated from a route... and is traveling along a route after said first next waypoint"

    • Context and Importance: This limitation describes the core inventive concept—the specific condition that triggers the user feedback loop. The infringement case depends on whether a generic error notification from the accused product meets this detailed functional requirement.
    • Intrinsic Evidence for a Broader Interpretation: A party could argue that any notification sent after the robot is no longer on its intended path constitutes a "message showing that a vehicle has deviated."
    • Intrinsic Evidence for a Narrower Interpretation: The claim language is highly specific, requiring not just a deviation, but also that the vehicle is now on a subsequent part of the planned route. The patent's flowchart makes this sequential logic explicit, showing a distinct check for this condition (’971 Patent, Fig. 6-1, step ST23). This may support a construction requiring both logical conditions to be met before the message is output.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant instructs and encourages its customers to use the Accused Products in an infringing manner through user manuals and its website (Compl. ¶¶ 34, 36).
  • Willful Infringement: The complaint alleges knowledge of the ’971 Patent "at least since the filing of the Complaint in this action," which forms the basis for a willfulness claim based on post-suit conduct (Compl. ¶ 35).

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

  • A core issue will be one of definitional scope: can the terms "vehicle" and "waypoint", which are rooted in the patent's context of on-road automotive navigation, be construed broadly enough to cover the operation of a robotic vacuum defining "no-go zones" and cleaning rooms within a home?
  • A key evidentiary question will be one of technical and functional equivalence: does the accused product’s general-purpose "cleaning error" notification system perform the specific, multi-part logical function required by Claim 1—detecting not just a deviation, but a deviation followed by rejoining the route after a missed waypoint—or is there a fundamental mismatch in technical operation?