DCT

1:24-cv-12569

Brain Corp v. Avidbots Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-12569, N.D. Ill., 12/06/2024
  • Venue Allegations: Venue is alleged to be proper in the Northern District of Illinois because Defendants maintain a regular and established place of business in Rolling Meadows, Illinois, and have committed alleged acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s autonomous floor-scrubbing robots infringe five patents related to autonomous navigation, robotic mapping, and optical object detection.
  • Technical Context: The technology at issue addresses fundamental challenges in commercial robotics, specifically how autonomous machines map dynamic environments, navigate around unexpected obstacles, and perceive objects.
  • Key Procedural History: The complaint does not mention prior litigation or inter partes review proceedings. It does allege that Plaintiff’s products are marked with the patents-in-suit via a patent marking website.

Case Timeline

Date Event
2014-07-01 Priority Date for ’436 Patent
2016-11-01 Priority Date for ’325 and ’576 Patents
2016-11-02 Priority Date for ’780 and ’539 Patents
2017-01-01 Accused Product "Neo" First Launched
2018-06-19 ’780 Patent Issued
2019-04-30 ’325 Patent Issued
2019-08-13 ’539 Patent Issued
2020-07-28 ’436 Patent Issued
2020-09-01 Accused Product "Neo 2" Launched
2020-11-03 ’576 Patent Issued
2023-04-01 Accused Product "Neo 2W" Launched
2024-04-01 Accused Product "Kas" Launched
2024-12-06 Complaint Filed

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

U.S. Patent No. 10,001,780 - “Systems and Methods For Dynamic Route Planning In Autonomous Navigation,” issued June 19, 2018

The Invention Explained

  • Problem Addressed: The patent addresses the problem of robotic navigation in dynamic environments where unexpected blockages can impede a pre-planned path, potentially causing the robot to stop, collide with objects, or make suboptimal adjustments (’780 Patent, col. 1:29-44; Compl. ¶31).
  • The Patented Solution: The invention proposes a method for dynamic route planning where a robot generates one or more "route poses" along a path. These poses act as a footprint of the robot's size and shape (’780 Patent, Abstract). The system then computes "repulsive forces" from detected objects and "attractive forces" from other route poses onto points within each pose. These forces cause the route poses to reposition, and the robot then interpolates a new, collision-free path between the adjusted poses, allowing it to navigate around obstacles dynamically (’780 Patent, col. 2:1-7; Compl. ¶34).
  • Technical Importance: This approach provides a computationally efficient method for robots to make complex, real-time adjustments to their paths, improving their ability to operate in unpredictable, real-world commercial spaces (Compl. ¶32).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 1 (’780 Patent, col. 21:54-22:22; Compl. ¶39).
  • Independent Claim 1 requires a robot with:
    • One or more sensors to collect data about an environment, including detected points on objects.
    • A controller configured to:
      • Create a map and determine a route.
      • Generate one or more "route poses" on the route, where each pose has a "footprint indicative of poses of the robot" and contains a "plurality of points."
      • Determine forces on the points of each pose, including "repulsive forces" from objects and "attractive forces" from other route poses.
      • Reposition one or more route poses based on these forces.
      • Perform interpolation between poses to generate a collision-free path.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,379,539 - “Systems and Methods For Dynamic Route Planning In Autonomous Navigation,” issued August 13, 2019

The Invention Explained

  • Problem Addressed: As a continuation of the application leading to the ’780 Patent, the ’539 Patent addresses the same technical problem of enabling autonomous robots to dynamically adjust their routes in response to environmental changes like unexpected obstacles (’539 Patent, col. 1:31-48; Compl. ¶48).
  • The Patented Solution: The patented solution is conceptually similar to that of the ’780 Patent, involving the computation of "repulsive forces" from an object onto a "route pose" to alter the robot's navigation path. The system generates a map, determines a route with poses having a footprint and points, computes repulsive forces from an object onto a pose, repositions that pose, and performs interpolation to create a new path (’539 Patent, col. 2:39-50; Compl. ¶50).
  • Technical Importance: This technology aims to enhance the efficiency and reliability of autonomous navigation, allowing for better resource utilization and improved functionality in complex environments (Compl. ¶48).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 1 (’539 Patent, col. 21:55-22:12; Compl. ¶55).
  • Independent Claim 1 requires a robot for maneuvering along a route with:
    • One or more sensors to collect data.
    • A controller configured to:
      • Determine a route on a map, the route including a plurality of points corresponding to a "respective pose of the robot."
      • The respective pose includes a plurality of points and corresponds to the robot's position and orientation.
      • Compute "repulsive forces" from a point on an object onto the plurality of points of the respective pose.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,274,325 - “Systems and Methods for Robotic Mapping,” issued April 30, 2019

  • Technology Synopsis: This patent addresses inaccuracies in robotic mapping that can cause a robot to become lost or collide with objects (’325 Patent, col. 1:29-38). The solution involves creating a map by performing "scan matching" on "extended scan groups" and constraining the resulting map graph to start and end at a substantially similar location, which improves positional accuracy and computational efficiency (Compl. ¶¶64-66).
  • Asserted Claims: At least Claim 1 is asserted (Compl. ¶71).
  • Accused Features: The complaint accuses the mapping and localization functionalities of the Accused Products (Compl. ¶¶69, 71).

U.S. Patent No. 10,823,576 - “Systems and Methods for Robotic Mapping,” issued November 3, 2020

  • Technology Synopsis: As a continuation of the ’325 Patent, this patent also addresses the problem of map inaccuracy in robotic navigation (’576 Patent, col. 1:29-38). The invention provides for generating a map based on measurements taken at multiple nodes, where each node has a range based on a "confidence measure," allowing the robot to reduce uncertainty and enhance navigation reliability by prioritizing more important scans (Compl. ¶¶80-82).
  • Asserted Claims: At least Claim 13 is asserted (Compl. ¶85).
  • Accused Features: The complaint accuses the mapping functionalities of the Accused Products, particularly those that generate a map based on measurements and confidence measures (Compl. ¶¶83, 85).

U.S. Patent No. 10,728,436 - “Optical Detection Apparatus and Methods,” issued July 28, 2020

  • Technology Synopsis: This patent addresses the unreliability and high cost of existing sensors used for object detection, particularly outdoors or in the presence of infrared radiation (’436 Patent, col. 1:34-45). The solution is a sensor apparatus that analyzes images by determining a "contrast parameter" and comparing it to a "threshold being dynamically configured based on one or more parameters" to detect an object, allowing for reliable performance in varied conditions with less expensive hardware (Compl. ¶¶94-96).
  • Asserted Claims: At least Claim 16 is asserted (Compl. ¶99).
  • Accused Features: The complaint accuses the sensor apparatus and object detection methods used in the Accused Products (Compl. ¶¶97, 99).

III. The Accused Instrumentality

Product Identification

  • The accused products are the Avidbots Corp Neo, Neo 2, Neo 2W, and Kas autonomous floor-scrubbing robots (collectively, the "Accused Products") (Compl. ¶20).

Functionality and Market Context

  • The Accused Products are powered by the "Avidbots Autonomy platform," which enables them to map their environment, adapt to new objects, and perform autonomous floor scrubbing (Compl. ¶¶20-21). The complaint includes an image from Defendant's materials showing an Accused Product operating in a modern, spacious indoor environment (Compl. p. 4). This platform is alleged to utilize a "leading-edge combination of obstacle detection and a sophisticated autonomous path planning algorithm" to maximize cleaning productivity while minimizing human intervention (Compl. ¶¶21-22).

IV. Analysis of Infringement Allegations

The complaint references but does not attach claim chart exhibits detailing the infringement allegations for each patent. The narrative infringement theories for the lead patents are summarized below.

  • '780 Patent Infringement Allegations

    • The complaint alleges that the Accused Products, in operation, practice all limitations of at least Claim 1 of the ’780 Patent (Compl. ¶39). It states that this infringement is detailed in an exemplary claim chart in Exhibit 1, which is incorporated by reference but not provided. The complaint further alleges that evidence of this infringement can be found on Avidbots' website, in promotional materials, and in Avidbots' own patent filings (Compl. ¶39). Without the exhibit, a detailed element-by-element analysis of the infringement theory is not possible based on the complaint alone.

  • '539 Patent Infringement Allegations

    • The complaint makes similar allegations regarding the ’539 Patent, stating that the Accused Products practice all limitations of at least Claim 1 (Compl. ¶55). It references an exemplary claim chart in Exhibit 2, also incorporated but not provided, for the detailed mapping of claim elements to accused functionality. The complaint again points to Avidbots' website, promotional materials, and patent filings as evidence of infringement (Compl. ¶55). A specific element-by-element analysis is not possible from the complaint's text.

V. Key Claim Terms for Construction

  • Term: "route pose" (’780 Patent, Claim 1)

    • Context and Importance: This term is central to the patented method of dynamic navigation. Its definition will determine what types of data structures or representations of a robot's planned position and orientation qualify, directly impacting whether the Accused Products' path planning algorithm meets this claim limitation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself does not impose significant structural limitations beyond comprising a "footprint indicative of poses of the robot" and having a "plurality of points disposed therein" (’780 Patent, col. 22:1-4). This could suggest that any data point representing a robot's planned location and extent could be a "route pose."
      • Evidence for a Narrower Interpretation: The specification describes a "route pose" as a "footprint" that can be shaped like the robot and can be adjusted in size based on a "footprint parameter" (’780 Patent, col. 13:3-15). This suggests a "route pose" may need to be a specific data construct that explicitly models the robot's physical dimensions, not just a simple waypoint.

  • Term: "repulsive forces" (’780 Patent, Claim 1; ’539 Patent, Claim 1)

    • Context and Importance: The concept of computing "repulsive forces" is the core mechanism for obstacle avoidance described in both lead patents. The construction of this term will be critical to determining whether the algorithm used by the Accused Products, which the complaint alleges is a "sophisticated autonomous path planning algorithm" (Compl. ¶22), can be characterized as calculating such forces.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim does not specify the mathematical nature of the "forces," only that they are "from... detected points on... objects" and cause the repositioning of route poses (’780 Patent, col. 22:5-12). This could allow the term to cover a wide range of path planning algorithms where proximity to an obstacle influences the path, even if not explicitly modeled as a physical "force."
      • Evidence for a Narrower Interpretation: The specification provides an example of a force function where repulsion is inversely proportional to distance (r(d)×1/d), suggesting a specific, physics-based model (’780 Patent, col. 14:58-67). An argument could be made that "repulsive forces" requires an algorithm that calculates vector-like values with magnitude and direction, rather than any general cost-map or potential-field-based method of path planning.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges active inducement for all asserted patents, based on Defendant providing "directions, demonstrations, guides, manuals, training for use, product support, and/or other materials" that allegedly instruct users to operate the Accused Products in an infringing manner (Compl. ¶¶41, 57, 73, 87, 101). Contributory infringement is also alleged, on the basis that components of the Accused Products are material parts of the inventions, are not staple articles of commerce, and are known by Defendant to be especially adapted for infringing use (Compl. ¶¶42, 58, 74, 88, 102).
  • Willful Infringement: Willfulness is alleged for all asserted patents. The basis includes Defendant's alleged awareness of Plaintiff as an "industry leader" and alleged knowledge of Plaintiff's patent portfolio through Plaintiff's patent marking website. The complaint asserts that Defendant "knew or was willfully blind" to the patents-in-suit and will have known of them at least as of the filing of the complaint (Compl. ¶¶40, 43, 56, 59, 72, 75, 86, 89, 100, 103).

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

  • A central issue will be one of algorithmic equivalence: does the Defendant's "sophisticated autonomous path planning algorithm" operate in a way that can be mapped onto the "repulsive forces" and "route pose" limitations of the ’780 and ’539 patents? The case may turn on whether these claim terms can be construed broadly to cover modern path-planning techniques or are limited to the specific force-based model described in the patents' specifications.
  • A second key question will be one of definitional scope across the patent families. For the mapping patents (’325 and ’576), the dispute may center on whether the Accused Products perform "scan matching on extended scan groups" or utilize a "confidence measure" as those terms are understood in the patents. For the optical patent (’436), the analysis will likely focus on whether the accused sensors use a "dynamically configured" threshold based on a "contrast parameter."
  • An evidentiary question will be the strength of the willfulness allegations. The complaint's theory rests on constructive knowledge via industry leadership and a patent marking website. The development of factual evidence showing Defendant's actual pre-suit knowledge of the specific patents-in-suit will be critical to this aspect of the case.