DCT

3:25-cv-01946

Beatbot Technology USA Co Ltd v. Zodiac Pool Systems LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-01946, S.D. Cal., 07/31/2025
  • Venue Allegations: Venue is asserted based on Defendant Zodiac's principal place of business being located in Carlsbad, California, within the Southern District of California.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its "Beatbot AquaSense 2 Ultra Robotic Pool Cleaner" products do not infringe three of Defendant's patents related to camera-based navigation for automated pool cleaners.
  • Technical Context: The lawsuit concerns the high-end market for robotic pool cleaners, where advanced navigation and cleaning-path optimization are key competitive features.
  • Key Procedural History: This declaratory judgment action was filed by Beatbot after receiving a demand letter from Zodiac on July 17, 2025. The letter accused Beatbot of infringing the patents-in-suit and demanded that Beatbot cease its allegedly infringing activities, thereby creating the "actual controversy" required for this type of action.

Case Timeline

Date Event
2012-07-10 Priority Date for ’191, ’766, and ’207 Patents
2021-05-11 ’191 Patent Issue Date
2022-03-01 ’766 Patent Issue Date
2024-01-23 ’207 Patent Issue Date
2025-07-17 Zodiac sends demand letter to Beatbot
2025-07-31 Complaint for Declaratory Judgment filed

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

U.S. Patent No. 11,003,191 - "Pool Cleaning System and Method to Automatically Clean Surfaces of a Pool Using Images from a Camera," issued May 11, 2021

The Invention Explained

  • Problem Addressed: The patent identifies the technical challenge of ensuring that automated robotic pool cleaners "satisfactorily clean" all portions of a pool's surfaces, which can be a "tedious and time-consuming task" to monitor and control ('191 Patent, col. 1:23-29).
  • The Patented Solution: The invention is a self-propelled pool cleaner equipped with at least one on-board camera and an on-board controller. The camera captures images of the submerged pool surface, and the controller analyzes these images to generate control signals. These signals direct the cleaner's movement "to, or away from" a portion of the surface, enabling navigation based on real-time visual feedback rather than just pre-programmed patterns ('191 Patent, Abstract; col. 4:45-54).
  • Technical Importance: This technology represents a shift from random or fixed-pattern cleaning to "intelligent" cleaning, where the robot can visually identify areas it has covered or missed and adjust its path accordingly ('191 Patent, col. 4:61-65).

Key Claims at a Glance

  • The complaint seeks a declaration of non-infringement of at least independent claim 1 (Compl. ¶ 18).
  • Essential elements of independent claim 1 include:
    • A vehicle body with a filter and means for moving.
    • "at least one camera positioned on or in the body for capturing an image of at least a first portion of the submerged surface".
    • "a controller (i) positioned on or in the body, (ii) in electronic communication with the at least one camera, and (iii) configured to generate, in response to the captured image, at least one control signal to cause movement of the body".
  • The complaint does not explicitly reserve the right to seek judgment on dependent claims but seeks relief as to "at least the identified claims" (Compl. ¶ 21A).

U.S. Patent No. 11,262,766 - "Pool Cleaning System and Method to Automatically Clean Surfaces of a Pool Using Images from a Camera," issued March 1, 2022

The Invention Explained

  • Problem Addressed: Like its parent patent, the ’766 Patent addresses the challenge of verifying and ensuring complete coverage by automated pool cleaners ('766 Patent, col. 1:24-27).
  • The Patented Solution: The invention describes a self-propelled pool cleaner that integrates an on-board camera and controller. The system uses captured images of the pool surface to generate steering commands, allowing it to navigate intelligently. The specification describes using the camera signals to verify cleaning and steer the robot to missed or unsatisfactorily cleaned spots ('766 Patent, col. 4:55-65).
  • Technical Importance: The approach provides a closed-loop feedback system for pool cleaning, where the device can visually assess its own work and take corrective action, enhancing cleaning effectiveness ('766 Patent, col. 4:45-54).

Key Claims at a Glance

  • The complaint seeks a declaration of non-infringement of at least independent claim 1 (Compl. ¶ 26).
  • Essential elements of independent claim 1 include:
    • A vehicle body with a filter and means for moving.
    • "at least one camera mounted directly or indirectly to the body for capturing an image of at least a first portion of the submerged surface".
    • "a controller (i) positioned on or in the body, (ii) in electronic communication with the at least one camera, and (iii) configured to generate, in response to the captured image, at least one control signal to cause movement of the body".
  • The complaint also notes that Beatbot does not infringe "the other claims of the '766 Patent" (Compl. ¶ 28).

U.S. Patent No. 11,880,207 - "Pool Cleaning System and Method to Automatically Clean Surfaces of a Pool Using Images from a Camera," issued January 23, 2024

  • Technology Synopsis: This patent, from the same family as the others, addresses the problem of ensuring complete automated pool cleaning ('207 Patent, col. 1:23-28). The patented solution involves a self-propelled cleaner with an on-board camera that captures an image of a "first object" in the pool; an on-board controller then uses that image to generate a control signal to move the cleaner relative to that object ('207 Patent, Claim 1).
  • Asserted Claims: The complaint seeks a declaration of non-infringement of at least independent claim 1 (Compl. ¶ 34).
  • Accused Features: Beatbot alleges its products do not have an on-board camera for capturing an image of an object or an on-board controller that generates movement signals in response, as required by the claim (Compl. ¶ 36).

III. The Accused Instrumentality

Product Identification

  • The "Beatbot AquaSense 2 Ultra Robotic Pool Cleaner," referred to collectively as the "Beatbot Products" (Compl. ¶ 3).

Functionality and Market Context

  • The complaint identifies Beatbot as a "manufacturer and seller of robotic pool cleaners" but provides minimal technical detail on the accused products' specific operational features (Compl. ¶ 3). The non-infringement allegations are based on what the products allegedly lack—the claimed on-board camera and controller systems—rather than a description of the navigation technology they employ (Compl. ¶¶ 20, 28, 36). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’191 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
at least one camera positioned on or in the body for capturing an image of at least a first portion of the submerged surface Plaintiff alleges the Beatbot Products do not include this feature. ¶20 col. 2:51-52
a controller (i) positioned on or in the body, (ii) in electronic communication with the at least one camera, and (iii) configured to generate, in response to the captured image, at least one control signal to cause movement of the body... Plaintiff alleges the Beatbot Products do not include a controller that operates in this manner. ¶20 col. 2:52-53

’766 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
at least one camera mounted directly or indirectly to the body for capturing an image of at least a first portion of the submerged surface Plaintiff alleges the Beatbot Products do not include this feature. ¶28 col. 4:48-49
a controller (i) positioned on or in the body, (ii) in electronic communication with the at least one camera, and (iii) configured to generate, in response to the captured image, at least one control signal to cause movement of the body... Plaintiff alleges the Beatbot Products do not include a controller that operates in this manner. ¶28 col. 2:52-53

Identified Points of Contention

  • Technical Questions: The central dispute appears to be factual: what navigation and sensing technology do the Beatbot Products actually use? The case will depend on evidence demonstrating whether the accused products contain an on-board camera and controller that function as claimed, or if they rely on alternative technologies (e.g., gyroscopes, accelerometers, sonar, or different logic) not covered by the claims.
  • Scope Questions: A likely point of contention will be the interpretation of "in response to the captured image." This raises the question of whether the claim requires the image to be the sole or primary input for the control signal, or if it can be one of several factors in a more complex algorithm. The complaint's categorical denial suggests Beatbot may argue its system, if it uses a camera at all, does not generate movement signals "in response to" images in the manner required by the claims (Compl. ¶¶ 20, 28).

V. Key Claim Terms for Construction

  • The Term: "in response to the captured image" (appearing in claim 1 of all three patents-in-suit).

  • Context and Importance: This term is the functional heart of the invention, linking the visual input (the image) to the mechanical output (the movement). Its construction is critical because it defines the necessary causal relationship between seeing and acting. Practitioners may focus on this term to determine if the accused products, even if they have cameras, use the visual data in the specific feedback loop mandated by the claims.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes a system that "utilizes signals from cameras 32 to verify that all of the surfaces of pool 22 have been cleaned" and identifies missed spots, suggesting a monitoring or verification role that may not be the only input for every movement command ('191 Patent, col. 4:61-65).
    • Evidence for a Narrower Interpretation: The specification discloses that the "control signal causes the cleaner to move in a direction... based solely upon signals received from the camera," which could support an argument that the image itself must be the determinative cause of the subsequent movement ('191 Patent, col. 2:19-22).

  • The Term: "camera positioned on or in the body" ('191 Patent) / "camera mounted directly or indirectly to the body" ('766 Patent).

  • Context and Importance: This language defines the physical location of the camera. As the patents also disclose embodiments with external cameras ('191 Patent, col. 4:45-47), the scope of what it means for a camera to be "on," "in," or "mounted... to" the cleaner body will be central. Beatbot's denial of this element suggests its system may not have a camera physically integrated with the main robotic unit.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term "indirectly to the body" in the '766 Patent could be argued to encompass a camera on a tethered or closely associated component that is not part of the main chassis, potentially broadening the claim's reach.
    • Evidence for a Narrower Interpretation: The claims consistently require both the camera and the controller to be "on or in the body," distinguishing them from embodiments where the controller is remote (e.g., a "dry station" or "remote server") ('191 Patent, col. 2:10-16). This may support a construction requiring a self-contained, integrated unit.

VI. Other Allegations

  • Indirect Infringement: The complaint seeks a declaration of non-infringement for indirect infringement, arguing that because the Beatbot Products do not directly infringe, no claim for indirect infringement can be sustained (Compl. ¶¶ 22, 30, 38).
  • Willful Infringement: Willfulness is not alleged by the Plaintiff. However, Zodiac's July 17, 2025 demand letter, which expressly accused Beatbot of infringement, establishes that Beatbot has had pre-suit knowledge of the patents-in-suit (Compl. ¶ 5). This fact would be central to any future willfulness claim Zodiac might bring.

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

  • A core issue will be one of evidentiary proof: Can Zodiac demonstrate that the Beatbot Products' navigation system meets the specific limitations of the asserted claims? The dispute will likely center on a technical deep-dive into how the accused cleaners sense their environment and determine their cleaning path, and whether this operation falls within the patent's scope.
  • The case will also turn on a question of claim construction: What is the precise meaning of generating a movement signal "in response to the captured image"? The court's interpretation will define whether the patent covers only systems where the image is the direct and primary driver of movement, or if it can also read on more complex systems where visual data is one of many inputs.
  • A third key question relates to the physical configuration: What is the scope of a camera "positioned on or in the body" or "mounted directly or indirectly to the body"? The outcome of this construction will determine whether the claims are limited to fully integrated devices or could extend to systems with distinct but connected components.