DCT

1:25-cv-00160

Elliptic Works LLC v. Fluidra SA

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00160, D. Del., 10/17/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Zodiac Pool Systems LLC is a Delaware limited liability company, and all Defendants are alleged to market, manufacture, import, and sell products, including the accused product, within the district.
  • Core Dispute: Plaintiff alleges that Defendants’ Polaris FREEDOM Plus cordless robotic pool cleaner infringes patents related to underwater visual light communication systems.
  • Technical Context: The technology at issue is visual light communication (VLC) for wirelessly controlling and monitoring underwater devices, enabling Internet-of-Things (IoT) functionality for the swimming pool industry.
  • Key Procedural History: The complaint alleges a detailed history preceding the litigation, including that the parties engaged in collaboration discussions under a non-disclosure agreement, during which Plaintiff disclosed confidential and trade secret information about its VLC technology. Plaintiff further alleges that Defendants, after feigning a lack of interest, used this information to develop the accused product and file their own patent application, leading to additional claims for breach of contract, trade secret misappropriation, and correction of inventorship on a patent assigned to Defendants.

Case Timeline

Date Event
2015-11-17 Earliest Priority Date for ’913 and ’081 Patents
2016-07-01 Plaintiff Elliptic and Defendant Zodiac USA begin discussions
2016-11-17 Plaintiff files PCT patent application (’602 Application)
2017-01-18 Plaintiff and Zodiac USA execute Mutual Nondisclosure Agreement
2017-09-15 Plaintiff presents and demonstrates its VLC technology to Zodiac USA
2017-10-12 Zodiac USA informs Plaintiff it cannot proceed with a relationship
2018-06-15 Plaintiff files U.S. national phase of its PCT application
2018-07-02 Zodiac USA merges with Zodiac North America, a subsidiary of Fluidra Spain
2019-11-01 R&D director of Fluidra Spain contacts Plaintiff to inquire about its progress
2020-02-26 Plaintiff participates in a technical call with Zodiac Europe representatives
2020-03-30 Plaintiff sends a copy of allowed claims from its pending application to Fluidra Spain
2020-08-06 Defendant Zodiac Europe files a U.S. provisional patent application
2024-10-30 Plaintiff notifies Fluidra Spain of impending issuance and infringement of the ’913 Patent
2024-11-05 U.S. Patent No. 12,134,913 Issues
2024-12-06 Plaintiff provides Defendants with an infringement claim chart for the ’913 Patent
2025-05-06 U.S. Patent No. 12,291,890, assigned to Zodiac Europe, issues
2025-07-22 U.S. Patent No. 12,366,081 Issues
2025-10-17 Complaint Filed

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

U.S. Patent No. 12,134,913 - "System for visual light communication and related methods"

  • Patent Identification: U.S. Patent No. 12,134,913, "System for visual light communication and related methods," issued November 5, 2024. (’913 Patent)

The Invention Explained

  • Problem Addressed: The patent addresses the need to collect, process, and transmit data related to swimming pools and their components without requiring hard-wired connections, which are challenging in an underwater environment ('913 Patent, col. 2:54-62).
  • The Patented Solution: The invention provides a system using visual light communication (VLC), where a light transmitter, such as an LED, rapidly turns on and off to generate a light signal containing encoded information. This light signal travels through the pool water to a light sensor, which converts the signal back into electronic data to monitor or control a pool component ('913 Patent, Summary, col. 2:58-65; Fig. 5).
  • Technical Importance: This approach enables wireless data communication for submerged pool devices, which is difficult for conventional radio-frequency signals, thereby facilitating the integration of "smart" or IoT capabilities into pool systems (Compl. ¶17).

Key Claims at a Glance

  • The complaint asserts independent claims 1, 9, 16, and 24 (Compl. ¶94).
  • The essential elements of independent claim 1 include:
    • a pool device operable in fluid in a pool and configured to perform one or more actions;
    • a light sensor operable when submerged in the fluid, configured to receive a light signal with encoded information about the pool device's operation;
    • a first control device coupled to the light sensor, configured to generate a data signal from the light signal; and
    • a second control device configured to cause an action of the pool device based on the data signal.
  • The complaint reserves the right to assert various dependent claims (Compl. ¶94).

U.S. Patent No. 12,366,081 - "System for visual light communication and related methods"

  • Patent Identification: U.S. Patent No. 12,366,081, "System for visual light communication and related methods," issued July 22, 2025. (’081 Patent)

The Invention Explained

  • Problem Addressed: As this patent shares a common specification with the ’913 Patent, it addresses the same technical problem of enabling wireless communication and control for underwater pool equipment (’081 Patent, col. 2:50-59).
  • The Patented Solution: The invention claimed is a system for controlling a pool vacuum using VLC. It comprises a vacuum, a light sensor to receive an encoded light signal through the water, and a control device with a processor that converts the light signal into an electronic signal to cause a mechanical action of the vacuum (’081 Patent, Claim 1; Fig. 5).
  • Technical Importance: The technology provides a wireless control mechanism specifically for submerged, mobile pool maintenance devices like robotic cleaners, an application where wired control is cumbersome (Compl. ¶17).

Key Claims at a Glance

  • The complaint asserts independent claims 1, 12, 23, and 31 (Compl. ¶95).
  • The essential elements of independent claim 1 include:
    • a vacuum operable in fluid in a pool and configured to perform a mechanical action;
    • a light sensor configured to receive a light signal with encoded information concerning the vacuum's operation; and
    • a control device electronically coupled to the sensor, with a processor and memory, configured to convert the light signal into an electronic signal that in turn causes a mechanical action of the vacuum.
  • The complaint reserves the right to assert various dependent claims (Compl. ¶95).

III. The Accused Instrumentality

Product Identification

  • The accused product is the Polaris FREEDOM Plus cordless robotic cleaner (Compl. ¶2).

Functionality and Market Context

  • The FREEDOM Plus is a cordless, robotic pool cleaner designed for underwater operation (Compl. ¶93). It is controlled by a handheld remote that uses "cutting-edge LiFi technology," a form of VLC, to communicate with the cleaner through the water (Compl. ¶93). This communication link gives the user the ability to start and stop the cleaner, direct its movement, and activate an "Easy Lift System" for removal from the pool (Compl. ¶93). The complaint references the product's marketing materials on the Polaris website, which describe its remote control and LiFi communication features (Compl. ¶93).
  • The complaint alleges the product is manufactured in Malaysia and imported into the United States for sale (Compl. ¶¶92, 110).

IV. Analysis of Infringement Allegations

The complaint references external claim-chart exhibits (Exhibits 10 and 16) that were not provided for this analysis. A narrative summary of the infringement theories is presented below.

  • ’913 Patent Infringement Allegations
    • The complaint alleges that the FREEDOM Plus system infringes claims of the ’913 Patent directed to monitoring and controlling pool components via VLC (Compl. ¶¶82, 94). The infringement theory suggests that the handheld remote, the robotic cleaner, and its onboard electronics collectively form the claimed system. The remote acts as a light transmitter sending control signals, the cleaner contains the submerged "pool device" and the "light sensor," and the combination of the remote and the cleaner's internal processor function as the "first" and "second" control devices that translate the light signal into a device action (Compl. ¶93).
  • ’081 Patent Infringement Allegations
    • The complaint alleges that the FREEDOM Plus infringes claims of the ’081 Patent directed to a pool maintenance system controlled by VLC (Compl. ¶¶86, 95). The theory posits that the robotic cleaner itself is the claimed "vacuum" configured to perform a "mechanical action" (i.e., cleaning). The cleaner contains the "light sensor," and its onboard processor serves as the "control device" that receives light signals from the remote and, in response, controls the cleaner's actions (Compl. ¶93).
  • Identified Points of Contention:
    • Scope Questions: A potential issue for the ’913 Patent is whether the accused system, consisting of a single integrated robot and a remote, meets the claim 1 limitation of a "pool device," a "first control device," and a "second control device" as distinct elements. For the ’081 Patent, a question may arise as to whether the term "vacuum," as used in the patent, reads on the specific cleaning mechanism of the accused robotic cleaner.
    • Technical Questions: The complaint's allegations are centered on direct user commands via the remote. It is a question for discovery whether the accused system performs functions that would meet limitations in dependent claims, such as reacting to changes within the pool environment autonomously, which is a feature described in the patents (’913 Patent, col. 11:15-24).

V. Key Claim Terms for Construction

  • The Term: "a second control device" (’913 Patent, Claim 1)
  • Context and Importance: This term's construction is important for determining how the claim elements map onto the accused system. The relationship between the "first control device" (which generates a data signal from light) and the "second control device" (which causes the pool device to act) will be a focus. Practitioners may focus on this term because if both control devices are required to be within the submerged unit, it may present a different infringement case than if one can be the external remote control.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes a "computing device 20" communicating with a "communications hub 40," which in turn communicates with the underwater VLC assemblies (’913 Patent, Fig. 2; col. 4:5-9). This architecture, separating the user-facing computer from the underwater hub, may support an interpretation where the control devices can be physically separate components, such as a remote control and an onboard processor.
    • Evidence for a Narrower Interpretation: Figure 3 of the patent depicts a single "pool component 10a" containing both a "component sensor 12a" and a "controller 14a" (’913 Patent, Fig. 3). This could support an argument that the control functions are intended to be integrated within the same general component as the sensor, suggesting a more localized, self-contained control system.
  • The Term: "electronically coupled" (’081 Patent, Claim 1)
  • Context and Importance: The definition of this term will be critical to determining whether the remote control unit is part of the claimed "control device." If "electronically coupled" requires a physical or wired connection, the claim may only read on the internal processor of the robot. If it includes wireless links, the remote may be part of the claimed device.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification broadly describes connections between the communication hub and computing device as potentially being a "wireless connection (e.g. Wi-Fi, Bluetooth... optical, sound...)" (’081 Patent, col. 3:60-64). This may suggest that the patentee envisioned "coupled" to include non-physical, wireless links.
    • Evidence for a Narrower Interpretation: The claim recites a "control device electronically coupled to the light sensor." In the context of the accused product, the light sensor is on the underwater robot. An argument could be made that the most direct coupling is with the robot's onboard processor, not the remote handheld unit, which is separated by a water gap and communicates via modulated light rather than a conventional electronic coupling.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendants’ marketing, user manuals, and instructions encourage customers to use the FREEDOM Plus in an infringing manner (Compl. ¶¶117, 121). It also alleges contributory infringement through the sale of replacement parts specifically for the VLC system, such as a "LiFi Antenna CB" and "Remote Control CB LiFi," which are alleged to have no substantial non-infringing use (Compl. ¶¶99, 126).
  • Willful Infringement: Willfulness is alleged based on both pre- and post-suit knowledge. The complaint asserts that Defendants were aware of the technology underlying the patents-in-suit as early as a September 2017 presentation under an NDA (Compl. ¶101). Furthermore, Plaintiff alleges it provided Defendants with notice of the allowed claims of a parent application in March 2020, formal notice of the issued ’913 Patent in October 2024, and a detailed infringement claim chart in December 2024, all of which allegedly failed to stop Defendants' infringing conduct (Compl. ¶¶101-104).

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

  • A core issue will be one of claim construction and mapping: Can the elements of the asserted claims, particularly the distinct "first control device" and "second control device" of the ’913 Patent, be mapped onto the components of the integrated FREEDOM Plus system, which consists of a single robot and a handheld remote? The interpretation of terms like "electronically coupled" will be central to this dispute.
  • A key evidentiary question will be the impact of the alleged trade secret misappropriation: The complaint weaves a detailed narrative of alleged bad faith conduct. The extent to which Plaintiff can prove that its confidential disclosures were the basis for the accused product's technology may significantly influence the context of the patent infringement analysis, particularly with respect to willfulness and damages.
  • A third question will be one of technical and functional scope: Beyond user-initiated commands, what are the full capabilities of the accused VLC system? Discovery will likely focus on whether the FREEDOM Plus performs functions that meet the more specific limitations of the asserted dependent claims, such as autonomous reactions to the pool environment, which could expand the scope of infringement.