DCT

1:19-cv-12125

iRobot Corp v. SharkNinja Operating LLC

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:19-cv-12125, D. Mass., 10/15/2019
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Massachusetts because Defendants have their principal place of business in the district and have committed the alleged acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s Shark IQ Robot line of robotic vacuum cleaners infringes six U.S. patents related to autonomous navigation, docking, energy management, debris removal, modular design, and remote scheduling.
  • Technical Context: The lawsuit concerns technology central to the consumer robotics market, where autonomous features like self-docking, intelligent mapping, and automated dirt disposal are key competitive differentiators.
  • Key Procedural History: The complaint alleges that Defendant intentionally copied features from Plaintiff's Roomba "i" and "s" series products. It further alleges Defendant had actual knowledge of the patents-in-suit at least as of October 8, 2019, following a notice from Plaintiff. Subsequent to the filing of this complaint, two of the patents-in-suit underwent Inter Partes Review (IPR). In IPR2020-00735, all asserted claims of the ’676 Patent were cancelled. In IPR2020-00863, the asserted independent claim and several asserted dependent claims of the ’303 Patent were cancelled.

Case Timeline

Date Event
2002-05-06 ’294 Patent Priority Date
2004-06-24 ’676 Patent Priority Date
2005-12-02 ’038 Patent Priority Date
2006-05-19 ’048 Patent Priority Date
2006-05-19 ’303 Patent Priority Date
2013-04-16 ’303 Patent Issue Date
2015-02-10 ’038 Patent Issue Date
2015-03-11 ’586 Patent Priority Date
2016-11-15 ’048 Patent Issue Date
2017-01-24 ’294 Patent Issue Date
2018-01-01 Plaintiff's Roomba i7+ Launch (approx. date)
2018-03-20 ’586 Patent Issue Date
2018-08-14 ’676 Patent Issue Date
2019-01-01 Defendant's Shark IQ Robot Launch (approx. date)
2019-10-08 Plaintiff alleges it notified Defendant of infringement
2019-10-15 Complaint Filing Date
2020-03-23 IPR filed against ’676 Patent (IPR2020-00735)
2020-05-06 IPR filed against ’303 Patent (IPR2020-00863)
2022-06-09 IPR Certificate issues cancelling asserted claims of ’303 Patent
2022-07-21 IPR Certificate issues cancelling asserted claims of ’676 Patent

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

U.S. Patent No. 9,921,586 - "Celestial Navigation System for an Autonomous Vehicle"

  • Patent Identification: U.S. Patent No. 9,921,586, "Celestial Navigation System for an Autonomous Vehicle," issued March 20, 2018.

The Invention Explained

  • Problem Addressed: The patent's background describes the limitations of prior art autonomous navigation systems, such as inefficient random movement, the need for physical guide wires, and susceptibility to infrared signal interference from sunlight or other electronics (Compl. ¶ 1; ’586 Patent, col. 1:26-67).
  • The Patented Solution: The invention proposes a navigation system where a transmitter emits signals toward a remote surface, such as a room's ceiling. The autonomous vehicle detects these reflected signals and uses them to determine its relative location within the working area, analogous to a ship using celestial bodies for navigation (’586 Patent, Abstract; col. 2:11-24).
  • Technical Importance: This approach allows a robot to navigate systematically in complex indoor environments without requiring direct line-of-sight to wall-mounted beacons or relying solely on odometry, which is prone to cumulative error (’586 Patent, col. 2:11-24).

Key Claims at a Glance

  • The complaint asserts claims 1, 4, 5, 7-11, 14, and 18, with independent claim 1 being central to the allegations (Compl. ¶ 30).
  • Essential elements of Independent Claim 1:
    • A navigational control system that autonomously controls a motive system to direct a robot about a room while mapping the room with respect to objects as points of reference;
    • Returns the robot to a base charging station before completing a cleaning task in response to detecting a need to recharge;
    • Docks the robot with the base station;
    • Recharges the energy storage unit; and
    • Controls the motive system to direct the robot to continue to clean the room.
  • The complaint reserves the right to assert additional claims (Compl. ¶ 30).

U.S. Patent No. 9,550,294 - "Autonomous Robot Auto-Docking and Energy Management Systems and Methods"

  • Patent Identification: U.S. Patent No. 9,550,294, "Autonomous Robot Auto-Docking and Energy Management Systems and Methods," issued January 24, 2017.

The Invention Explained

  • Problem Addressed: The patent addresses the need for autonomous robots to manage their energy and recharge without human intervention, and for their base stations to be unobtrusive and protected from inadvertent contact with the robot (’294 Patent, col. 1:28-2:26).
  • The Patented Solution: The invention describes a system where a base station emits both a short-range "avoidance" signal to prevent collisions and longer-range "homing" signals to guide the robot for docking. The robot monitors its own energy level and initiates a return to the base station when the energy falls below a certain threshold, enabling it to complete cleaning missions over multiple charge cycles (’294 Patent, Abstract; col. 2:30-41).
  • Technical Importance: This system of intelligent energy management and signal-based docking is fundamental to creating a "set-it-and-forget-it" user experience, a critical factor for the widespread adoption of consumer robotics (’294 Patent, col. 2:20-26).

Key Claims at a Glance

  • The complaint asserts claims 1-5, 8, 9, 11, and 12, with independent claim 1 being central to the allegations (Compl. ¶ 41).
  • Essential elements of Independent Claim 1:
    • A navigational control system that autonomously controls a motive system to direct a robot about a room while mapping the room with respect to objects as points of reference;
    • Returns the robot to a base charging station before completing a cleaning task in response to the energy level falling to a predetermined threshold;
    • Docks the robot with the base station;
    • Recharges the energy storage unit; and
    • Controls the motive system to direct the robot to continue to clean the room.
  • The complaint reserves the right to assert additional claims (Compl. ¶ 41).

Multi-Patent Capsule: U.S. Patent No. 9,492,048 - "Removing Debris from Cleaning Robots"

  • Patent Identification: U.S. Patent No. 9,492,048, "Removing Debris from Cleaning Robots," issued November 15, 2016.
  • Technology Synopsis: This patent addresses the problem of manually emptying small debris bins on robotic cleaners. The solution is a maintenance station where the robot docks, and an air mover in the station evacuates debris from the robot's bin into a larger collection bin within the station (’048 Patent, Abstract).
  • Asserted Claims: Claims 12 and 18 are asserted (Compl. ¶ 53).
  • Accused Features: The "self-empty base" available with certain models of the Shark IQ Robot product line is accused of infringement (Compl. ¶ 53).

Multi-Patent Capsule: U.S. Patent No. 8,950,038 - "Modular Robot"

  • Patent Identification: U.S. Patent No. 8,950,038, "Modular Robot," issued February 10, 2015.
  • Technology Synopsis: The patent describes a robot constructed with modular components, such as drive wheel assemblies and cleaning head assemblies. These modules are designed to be separately and independently removable from the robot's chassis as complete units, simplifying service and repair (’038 Patent, Abstract).
  • Asserted Claims: Claims 1, 5, 7, 9-12, and 14 are asserted (Compl. ¶ 65).
  • Accused Features: The complaint alleges infringement by the Shark IQ Robot product family, presumably based on its mechanical construction (Compl. ¶ 65).

Multi-Patent Capsule: U.S. Patent No. 8,418,303 - "Cleaning Robot Roller Processing"

  • Patent Identification: U.S. Patent No. 8,418,303, "Cleaning Robot Roller Processing," issued April 16, 2013.
  • Technology Synopsis: This patent addresses the problem of hair, string, and other filaments becoming tightly wound around a cleaning robot's rollers, which inhibits performance and is difficult to clean. The patented solution involves specific roller designs, such as compliant flaps and axial end guards, that prevent filaments from spooling tightly and aid in their subsequent removal (’303 Patent, Abstract).
  • Asserted Claims: Claims 1, 6-11, 14, and 15 are asserted (Compl. ¶ 77).
  • Accused Features: The cleaning rollers of the Shark IQ Robot product family are accused of infringement (Compl. ¶ 77).

Multi-Patent Capsule: U.S. Patent No. 10,045,676 - "Remote Control Scheduler and Method for Autonomous Robotic Device"

  • Patent Identification: U.S. Patent No. 10,045,676, "Remote Control Scheduler and Method for Autonomous Robotic Device," issued August 14, 2018.
  • Technology Synopsis: The patent describes a system where a communication device, such as a remote control, can load scheduling information into a robotic device. This allows the robot to then carry out defined tasks at desired times autonomously, without further external control or the need for a separate PC (’676 Patent, Abstract).
  • Asserted Claims: Claims 1, 2, 4-8, 10, and 14-18 are asserted (Compl. ¶ 89).
  • Accused Features: The remote control and scheduling functionalities of the Shark IQ Robot product family are accused of infringement (Compl. ¶ 89).

III. The Accused Instrumentality

Product Identification

  • The Shark IQ Robot product line, including the RV1000 Series, RV1000AE Series, and models R101 and R101AE (Compl. ¶ 2).

Functionality and Market Context

  • The complaint describes the accused products as robotic vacuum cleaners that incorporate several advanced autonomous features (Compl. ¶ 13). These allegedly include the ability to create a map of a home for room-specific cleaning, return to a base station to recharge when the battery is low, resume cleaning where it left off after recharging, and autonomously empty its dust bin into a self-empty base station (Compl. ¶ 13). The complaint alleges Defendant markets the Shark IQ Robot as a direct competitor to Plaintiff's Roomba i7+, offering the same technology at a lower price point (Compl. ¶ 15).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint. The complaint makes its infringement allegations by reference to claim chart exhibits (Exhibits G-L), which were not provided with the filed complaint (Compl. ¶¶ 31, 42, 54, 66, 78, 90). The following summary is based on allegations made in the complaint's factual background section.

’9,921,586 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
control the motive system to direct the robot about a room, while mapping the room with respect to objects as points of reference The Shark IQ Robot can allegedly "create a map of a user's home so the user can schedule when and what rooms the robot cleans." ¶13 col. 2:11-14
return the robot to the base charging station before completing a cleaning task in the room, in response to detecting a need to recharge the energy storage unit The Shark IQ Robot can allegedly "return to its base to recharge if it runs low on battery power while cleaning." ¶13 col. 2:11-14
dock the robot to the base charging station upon return The complaint alleges the product returns to its base to recharge. ¶13 col. 2:11-14
recharge the energy storage unit with the robot docked The complaint alleges the product returns to its base to recharge. ¶13 col. 2:11-14
and then to control the motive system to direct the robot to continue to clean the room The Shark IQ Robot can allegedly "resume where it left off once it is recharged." ¶13 col. 2:11-14

’9,550,294 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
control the motive system to direct the robot about a room, while mapping the room with respect to objects as points of reference The Shark IQ Robot can allegedly "create a map of a user's home so the user can schedule when and what rooms the robot cleans." ¶13 col. 2:30-41
return the robot to the base charging station before completing a cleaning task in the room, in response to a quantity of energy remaining in the energy storage unit falling to a predetermined threshold The Shark IQ Robot can allegedly "return to its base to recharge if it runs low on battery power while cleaning." ¶13 col. 2:30-41
dock the robot to the base charging station upon return The complaint alleges the product returns to its base to recharge. ¶13 col. 2:30-41
recharge the energy storage unit with the robot docked The complaint alleges the product returns to its base to recharge. ¶13 col. 2:30-41
and then to control the motive system to direct the robot to continue to clean the room The Shark IQ Robot can allegedly "resume where it left off once it is recharged." ¶13 col. 2:30-41

Identified Points of Contention

  • Scope Questions: A central question for both the ’586 and ’294 patents will be the construction of the phrase "mapping the room with respect to objects as points of reference." The dispute may turn on whether the accused product's mapping technology, which enables room selection for cleaning, performs mapping in the specific manner required by the claims.
  • Technical Questions: The infringement analysis for the ’294 Patent raises the evidentiary question of how the accused product technically determines its energy level has fallen to a "predetermined threshold." Similarly for the ’586 Patent, the analysis will require evidence of the mechanism that constitutes "detecting a need to recharge." A potential point of dispute could be whether these two claim limitations, though similarly worded, describe distinct technical requirements.

V. Key Claim Terms for Construction

  • The Term: "mapping the room with respect to objects as points of reference" (Claim 1 of both ’586 and ’294 Patents)
  • Context and Importance: This term is critical because it defines the specific type of navigational capability at the heart of the "recharge and resume" feature. The outcome of the infringement analysis for both lead patents may depend on whether the accused product's method of creating a user-selectable map of rooms is construed to fall within the scope of this limitation. Practitioners may focus on this term because the complaint ties infringement to the accused product's ability to create a map that allows users to schedule cleaning by room (Compl. ¶ 13).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specifications of the ’586 and ’294 patents discuss various navigation systems but do not appear to provide a specific, limiting definition of this phrase, which may support an argument for construing it to cover any system that creates a spatial representation of a room relative to detected objects for navigation.
    • Evidence for a Narrower Interpretation: A defendant may point to specific embodiments or figures in the patents that illustrate a particular method of object detection or map creation, arguing that the claim term should be limited to those disclosed examples. The absence of an explicit definition may lead parties to argue for a construction limited to the context provided by the specification as a whole.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides customers with materials such as demonstrations, training guides, videos, websites, and manuals that "depict and describe the infringing features of the Shark IQ Robot" and encourage end-users to use the products in an infringing manner (Compl. ¶¶ 36-37, 48-49).
  • Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged pre-suit and post-suit knowledge of the patents (Compl. ¶¶ 33, 36, 44, 47). The basis for pre-suit knowledge includes allegations that Defendant "emulated and copied features" of Plaintiff's products and knew that Plaintiff had patents covering its robotic vacuum lines (Compl. ¶¶ 34-35). The basis for post-suit knowledge is an alleged notice of infringement sent by Plaintiff to Defendant on October 8, 2019 (Compl. ¶ 33).

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

  • A core evidentiary question will be one of technical operation: Does the accused product's system for mapping, detecting low battery, and resuming cleaning missions operate in a manner that meets the specific, multi-step sequence of limitations recited in the asserted independent claims of the ’586 and ’294 patents, and what is the plaintiff's evidence for each element?
  • A central legal issue will be willfulness: The case will likely turn on the evidence presented regarding Defendant's state of mind, specifically whether Plaintiff can prove that Defendant intentionally copied patented features and continued to sell the accused products despite knowing of the patents-in-suit, thereby justifying enhanced damages.
  • A key procedural issue will be the impact of post-filing events: The cancellation of all asserted claims of the ’676 Patent and the asserted independent claim of the ’303 Patent in subsequent IPR proceedings presents a fundamental challenge to the viability of those infringement counts, and the court will need to address the effect of these administrative findings on the ongoing litigation.