DCT
9:25-cv-81326
Shenzhen Mammotion Innovation Co Ltd v. Futuregen Tech Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Mammotion Innovation Co., Ltd. (People's Republic of China)
- Defendant: FutureGen Technologies Inc. (Delaware, U.S.)
- Plaintiff’s Counsel: Arch & Lake LLP
- Case Identification: 9:25-cv-81326, D.D.C., 06/20/2025
- Venue Allegations: Plaintiff Mammotion alleges venue is proper in the District of Columbia because Defendant FutureGen purposefully directed its patent enforcement and monetization activities there, including retaining D.C.-based counsel (Ropes & Gray LLP) to engage in licensing negotiations and analyze accused products.
- Core Dispute: Plaintiff seeks a declaratory judgment that its robotic lawn mowers do not infringe three of Defendant's patents related to autonomous robot navigation and control, and/or that those patents are invalid.
- Technical Context: The dispute centers on autonomous robotic lawn mowers, a growing consumer market where key technologies involve defining virtual boundaries and monitoring robot operations without physical guide wires.
- Key Procedural History: The action follows pre-suit communications initiated by FutureGen's submission of patent infringement complaints to the Amazon marketplace against Mammotion's products. The parties subsequently engaged in licensing discussions under a Non-Disclosure Agreement, during which FutureGen provided infringement claim charts and Mammotion provided product samples for analysis. FutureGen's refusal to withdraw the Amazon complaint during negotiations prompted this declaratory judgment action.
Case Timeline
| Date | Event |
|---|---|
| 2009-06-18 | Priority Date for ’164, ’297, and ’776 Patents |
| 2013-04-23 | U.S. Patent No. 8,428,776 Issued |
| 2014-04-22 | U.S. Patent No. 8,706,297 Issued |
| 2016-01-01 | Mammotion Founded |
| 2019-11-26 | U.S. Patent No. 10,485,164 Issued |
| 2025-04-25 | FutureGen submits patent infringement complaint on Amazon |
| 2025-04-30 | FutureGen provides infringement claim chart to Mammotion |
| 2025-05-23 | Parties execute a Non-Disclosure Agreement |
| 2025-06-02 | Mammotion transmits non-infringement memorandum to FutureGen |
| 2025-06-06 | FutureGen proposes a license agreement to Mammotion |
| 2025-06-20 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,485,164 - "System and method for controlling and monitoring operation of an autonomous robot"
- Patent Identification: U.S. Patent No. 10,485,164, "System and method for controlling and monitoring operation of an autonomous robot," issued November 26, 2019 (’164 Patent).
The Invention Explained
- Problem Addressed: The patent background describes the challenges with autonomous robots that rely on physically defined perimeters (e.g., perimeter wires), which can break or fail, leading to failed coverage or the robot leaving the desired area (’164 Patent, col. 1:35-51).
- The Patented Solution: The invention proposes a system architecture consisting of an autonomous robot, a server, and an external user device (’164 Patent, Fig. 17). The robot performs a task (e.g., cutting grass) within a defined area and transmits location and status data to the server, which then relays this information to the external device, allowing a user to monitor the work session remotely (’164 Patent, col. 2:4-30).
- Technical Importance: This system enables remote monitoring and control of an autonomous robot operating within a virtually, rather than physically, defined space.
Key Claims at a Glance
- The complaint identifies independent claims 1 and 8 as representative (Compl. ¶¶ 33, 35).
- Independent Claim 1 requires a system comprising:
- a server;
- an external device with a display for receiving data from the server;
- an autonomous robot with a location tracking unit, transceiver, and central processing unit (CPU);
- the robot's CPU configured to transmit its location data to the server while performing a task;
- the server configured to transmit this location data to the external device;
- the external device displaying a visual representation of the work session status and a graphical representation of the boundary and worked area; and
- the CPU being configured to detect grass thickness by comparing a current sensor value to a threshold.
- Independent Claim 8 requires a similar system, but instead of detecting grass thickness, the CPU is further configured to:
- determine the distance between the robot and the confinement area boundary;
- move the robot at a first velocity when the distance is greater than a threshold; and
- reduce the velocity when the distance is less than the threshold.
- The complaint notes that dependent claims are also not infringed (Compl. ¶¶ 34, 36).
U.S. Patent No. 8,706,297 - "Method for establishing a desired area of confinement for an autonomous robot and autonomous robot implementing a control system for executing the same"
- Patent Identification: U.S. Patent No. 8,706,297, "Method for establishing a desired area of confinement for an autonomous robot and autonomous robot implementing a control system for executing the same," issued April 22, 2014 (’297 Patent).
The Invention Explained
- Problem Addressed: The patent addresses the need for an autonomous robot that can perform tasks within a confined area that is easy to use and does not rely on physical barriers (’297 Patent, col. 1:55-65).
- The Patented Solution: The invention is a method for defining a virtual perimeter where a robot records a first location point (P1), is moved to a plurality of additional points (P2-N) which are also recorded, and a central processing unit automatically defines a closed perimeter upon determining one of the additional points is "substantially coincident" with the first point (’297 Patent, Abstract). The complaint highlights that, to overcome prior art, the patent "expressly requires that the closed-geometry be automatically defined by the central processing unit without user intervention" (Compl. ¶18).
- Technical Importance: This method provides a "teach and repeat" system where a user guides the robot once, and the system intelligently and automatically completes the boundary map for future autonomous use.
Key Claims at a Glance
- The complaint identifies independent claims 1, 13, and 18 as representative (Compl. ¶¶ 42, 44, 46).
- Independent Claim 1 requires a method of defining a confinement area comprising the steps of:
- positioning a robot at a first location point P1 and recording it;
- moving the robot to a plurality of points P2-N and recording each;
- defining, with a CPU, a closed-geometry from points P1 and P2-N as the perimeter;
- wherein the CPU automatically performs the defining step when one of the P2-N points is "substantially coincident" with P1; and
- wherein the perimeter is defined as map data and automatically transmitted to a server upon definition.
- Independent Claim 13 requires an autonomous robot with a CPU configured to perform a similar process:
- track the robot's location;
- record a first location point;
- automatically record additional discrete location points while maneuvering along a perimeter; and
- define a closed-geometry, wherein the geometry is automatically defined by the CPU upon determining a point is "substantially coincident" with the first point.
- The complaint notes that dependent claims are also not infringed (Compl. ¶¶ 43, 45, 47).
U.S. Patent No. 8,428,776 - "Method for establishing a desired area of confinement for an autonomous robot and autonomous robot implementing a control system for executing the same"
- Patent Identification: U.S. Patent No. 8,428,776, "Method for establishing a desired area of confinement for an autonomous robot and autonomous robot implementing a control system for executing the same," issued April 23, 2013 (’776 Patent).
Technology Synopsis
This patent addresses defining a virtual confinement area by having the robot first record a starting point (Po) as a reference coordinate (e.g., 0,0) in its memory. The robot's location is then tracked relative to this internal starting point using a "distance-traveled measuring mechanism" and a "directional indicating instrument" as it is manually guided along the perimeter (Compl. ¶20). The perimeter definition is therefore based on relative motion calculations from an internal reference point, not an external positioning system (’776 Patent, Abstract).
Asserted Claims
The complaint identifies independent claims 1, 10, and 20 as representative (Compl. ¶¶ 53, 55, 57).
Accused Features
The complaint alleges non-infringement because the accused products utilize a Real-Time Kinematic (RTK) positioning system, where the robot's position is calculated relative to a fixed external base station, not relative to the robot's own starting position stored in memory (Compl. ¶¶ 54, 56, 58).
III. The Accused Instrumentality
Product Identification
- The "Mammotion Accused Products" include various models of robotic lawn mowers, such as the YUKA 2000, LUBA Mimi AWD 800H, and YUKA Mini 500H (Compl. ¶1).
Functionality and Market Context
- The complaint describes the products as "boundary-free lawn mowers" that integrate "advanced robotics technologies" (Compl. ¶21).
- For purposes of non-infringement, the complaint alleges several key technical functionalities. First, the products determine their position using a Real-Time Kinematic (RTK) system, which relies on a fixed, external RTK base station as the reference point, rather than an internally recorded starting point (Compl. ¶54). Second, while the products contain current sensors, these are allegedly configured solely to detect electrical overload conditions for motor protection and are not designed or programmed to measure or detect grass thickness (Compl. ¶34). Third, the process for defining a confinement area is not fully automatic; after a user outlines the perimeter, the system generates a manual confirmation prompt that the user must affirmatively accept to save and define the area (Compl. ¶45).
IV. Analysis of Infringement Allegations
'164 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality (per Mammotion's Non-Infringement Position) | Complaint Citation | Patent Citation |
|---|---|---|---|
| A system for monitoring operation of an autonomous robot comprising: a server; an external device...; an autonomous robot... | Mammotion's complaint does not contest the presence of a system comprising these basic hardware components. | ¶33 | col. 2:4-11 |
| wherein upon receipt of the data indicative of the location of the autonomous robot... a visual representation of a status of a work session... and a graphical representation of the boundary and a portion of an area within the boundary in which an activity has been performed... is displayed on the display of the external device | The complaint does not contest that its associated mobile application displays the robot's location, boundary, and work status. | ¶33 | col. 2:25-30 |
| and wherein the task is cutting grass and wherein the central processing unit is configured to detect, via a current sensor, a thickness of the grass by comparing a current value received by the current sensor to a threshold current value. | The Mammotion Accused Products allegedly do not meet this limitation. Their current sensors are configured only to detect electrical overload conditions for motor protection and are not designed or programmed to measure or detect the thickness of grass (Compl. ¶34). | ¶34 | col. 31:54-68 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether a current sensor configured for "electrical overload protection" performs the function of "detect[ing]... a thickness of the grass" as required by claim 1. The patentee may argue that increased motor current draw during overload is a direct proxy for thicker grass, bringing the feature within the claim's scope. The patent's description of using current thresholds to identify "Thick Grass" may support this argument (’164 Patent, Fig. 20).
- Technical Questions: Regarding claim 8, which requires changing velocity based on distance to a boundary, Mammotion alleges its products' turning and deceleration are "not governed by any real-time measurement of the robot's distance to the perimeter" (Compl. ¶36). The case may require evidence on the specific algorithms the accused products use for navigation near boundaries to determine if they practice the claimed distance-based velocity reduction.
'297 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality (per Mammotion's Non-Infringement Position) | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method of defining an area of confinement for an autonomous robot comprising: a) positioning... at a first location point P1... and recording the first location point P1... | The complaint does not contest that its products record location points to define a perimeter. | ¶42 | col. 19:1-4 |
| wherein the central processing unit automatically performs step c) [defining a closed-geometry] upon one of the plurality of location points P2-N being determined to be substantially coincident With the first location point P1 | The Mammotion Accused Products allegedly do not perform this step automatically. After the user outlines the area, the interface generates a manual confirmation prompt, and the system does not define or store the perimeter unless the user provides manual confirmation (Compl. ¶45). | ¶45 | col. 21:3-10 |
| and wherein the perimeter... is defined in the memory device as map data, and further comprising automatically transmitting the map data to a server upon the first closed-geometry being defined. | The Mammotion Accused Products allegedly lack this limitation. The complaint asserts that in the accused products, "the memory device does not automatically transmit the map data to a server once the confinement area is defined" (Compl. ¶43). | ¶43 | col. 35:9-12 |
- Identified Points of Contention:
- Scope Questions: The term "automatically performs" will be a key point of contention. The court will need to determine if a system that algorithmically identifies a closed loop and prompts the user for a single confirmation meets the requirement of performing the step "automatically," or if the manual confirmation step breaks the chain of automation required by the claim.
- Technical Questions: Another point of dispute will be whether the accused products "automatically transmit" map data to a server upon defining the perimeter. The analysis will likely depend on the timing and trigger for the data transmission in the accused system's software architecture.
V. Key Claim Terms for Construction
The Term: "detect, via a current sensor, a thickness of the grass" (’164 Patent, Claim 1)
- Context and Importance: This term is critical because Mammotion contends its products' current sensors are for overload protection only, not for detecting grass thickness. The case may turn on whether the function of overload protection can be construed as inherently detecting grass thickness, as thicker grass would increase motor load and current draw.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes a flow chart where a determination of whether the "Value [is] above 10% threshold?" leads to a "Thick Grass detected" state (’164 Patent, Fig. 20). A patentee could argue that any system using current thresholds to react to high load is, in effect, detecting thick grass.
- Evidence for a Narrower Interpretation: Mammotion may argue that the claim requires a specific configuration "to detect" thickness, not merely a generic safety feature that incidentally reacts to it. The patent's explicit branching logic for "Thick Grass," "Thin Grass," and "Obstacle" based on different current thresholds suggests a purpose-built detection scheme, not a simple overload cutoff (’164 Patent, Fig. 20).
The Term: "automatically performs" / "automatically defined" (’297 Patent, Claims 1 & 13)
- Context and Importance: This term is central to non-infringement of the ’297 Patent, as Mammotion alleges its products require a final user confirmation step to define a boundary. Practitioners may focus on this term because its interpretation will determine whether a human-in-the-loop confirmation step removes the accused method from the scope of a claim requiring automation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the CPU "either automatically recognizes that a closed-geometry has been formed... or the user activates a compute closed perimeter ('CCP') signal" (’297 Patent, col. 12:45-50). A patentee might argue "automatically recognizes" is the key step, and a subsequent confirmation prompt does not negate this initial automatic recognition.
- Evidence for a Narrower Interpretation: The complaint argues the patent "expressly requires that the closed-geometry be automatically defined by the central processing unit without user intervention" to overcome prior art (Compl. ¶18). This prosecution history argument, if supported, could lead to a narrower construction that excludes any mandatory user confirmation step before the geometry is finalized.
The Term: "tracking location of the autonomous robot relative to the reference point Po" (’776 Patent, Claim 1)
- Context and Importance: While not from the two lead patents, this term is fundamental to the dispute for the ’776 Patent. Mammotion's non-infringement argument rests on its use of an external RTK base station, which it argues is not tracking "relative to the reference point Po" which is defined as being recorded "within a memory device of the autonomous robot" (Compl. ¶¶ 53-54).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A patentee might argue that even with an RTK system, the robot's position is still ultimately calculated and processed relative to a starting point or coordinate system managed within the robot's memory, thus meeting the limitation.
- Evidence for a Narrower Interpretation: The specification explicitly describes Po being recorded as "the Cartesian coordinate (0, 0), which will then become the relative reference point" for subsequent locations (’776 Patent, col. 5:3-7). This strongly suggests an internal, self-referential dead-reckoning or odometry-based system, which is technically distinct from a system reliant on an external, absolute positioning reference like an RTK base station.
VI. Other Allegations
The complaint includes counts for invalidity of the ’297 and ’776 patents under 35 U.S.C. §§ 101, 102, 103, and 112 (Compl. ¶¶ 69-87).
- Invalidity Allegations:
- § 101 (Abstract Idea): Mammotion alleges that claims of the ’297 Patent are directed to the patent-ineligible abstract idea of "receiving, comparing, and transmitting information" without a specific inventive means of achieving the result (Compl. ¶71).
- § 112 (Indefiniteness/Enablement): The complaint alleges the term "automatically defined" is not supported by technical details or an algorithmic methodology in the specification, rendering the claims indefinite and non-enabled (Compl. ¶72).
- §§ 102/103 (Anticipation/Obviousness): Mammotion asserts that Japanese Patent Nos. 3,557,176 and 2008,077,670, both alone and in combination, render claims of the ’297 and ’776 patents invalid. The complaint includes a figure from the JP '176 patent that depicts a robot recording discrete points and detecting a closed loop when a new endpoint is within a threshold distance of a starting point (Compl. ¶75, p. 26). This figure illustrates a prior art method for automatically detecting a closed-loop path for an autonomous robot (Compl. ¶75). These allegations suggest a significant validity challenge running parallel to the non-infringement case.
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to hinge on three central questions that will require judicial determination:
A core issue will be one of definitional scope: Can functional claim language, such as a CPU configured to "detect... a thickness of the grass," be construed to cover a general-purpose safety feature (motor overload protection) that indirectly responds to the same physical phenomena? Similarly, how much user interaction is permissible before a process is no longer considered "automatic"?
A second key issue is one of technical mismatch: Is there a fundamental difference in operation between the patented method of navigating relative to an internal starting point ('776 Patent) and the accused products' method of navigating relative to an external RTK positioning system? This raises the question of whether the accused technology falls entirely outside the patent's self-referential positioning paradigm.
A third major question will be patent validity: Independent of infringement, do the asserted claims of the ’297 and ’776 patents represent a patent-eligible application of an idea, or are they directed to the abstract concept of automated boundary detection? Further, does the prior art cited by Mammotion, which appears to disclose automatic closed-loop detection for robot navigation, anticipate or render obvious the claimed inventions?