DCT

2:25-cv-00582

Zodiac Pool Systems LLC v. Wybotics Co Ltd

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00582, E.D. Tex., 09/22/2025
  • Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign company not resident in the United States and therefore may be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s robotic pool cleaners infringe five U.S. patents related to filtration systems, wheel-driven brushing mechanisms, and camera-based navigation and control.
  • Technical Context: The technology at issue pertains to automated robotic pool cleaners, a significant product category in the residential and commercial pool maintenance market.
  • Key Procedural History: The complaint alleges that Defendant was previously subject to an ITC investigation and a parallel district court action regarding two of the patents-in-suit (’031 and ’029). Those actions were reportedly terminated after Defendant made "sworn representations" that it had stopped and would no longer import or sell the accused products. Plaintiff alleges that Defendant has since resumed selling infringing products, forming a basis for its willfulness allegations.

Case Timeline

Date Event
2007-12-21 U.S. Patent No. 8,393,029 Priority Date
2012-07-10 U.S. Patent Nos. 11,880,207, 11,262,766, 11,003,191 Priority Date
2013-03-12 U.S. Patent No. 8,393,031 Issued
2013-03-12 U.S. Patent No. 8,393,029 Issued
2016-02-12 Defendant allegedly learned of '029 Patent via letter
2021-05-11 U.S. Patent No. 11,003,191 Issued
2022-03-01 U.S. Patent No. 11,262,766 Issued
2022-07-29 ITC Investigation and CDCA Action filed against Defendant for '031 and '029 Patents
2023-02-21 ITC Investigation terminated as to Defendant
2023-03-29 CDCA Action voluntarily dismissed without prejudice
2024-01-23 U.S. Patent No. 11,880,207 Issued
2024-06-04 Defendant notified of alleged infringement of ’207, ’766, and ’191 Patents via letter
2024-07-17 Date on or after which Defendant allegedly removed Wybot M2 from website
2025-03-19 Date on or before which Defendant allegedly began offering Wybot C2 Vision for sale
2025-05-12 Date on or before which Defendant allegedly began offering Wybot S2 Solar Vision for sale
2025-06-02 Plaintiff sent another letter to Defendant regarding alleged infringement
2025-09-22 Complaint Filing Date

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

U.S. Patent No. 8,393,031 - "Apparatus For Cleaning A Submerged Surface With Removable Filtration Device"

  • Issued: March 12, 2013 (the "’031 Patent")

The Invention Explained

  • Problem Addressed: The patent describes known robotic pool cleaners as having inconvenient access to their filtering devices, sometimes requiring the user to invert the entire unit, which can be cumbersome and lead to spills ('031 Patent, col. 1:37-53).
  • The Patented Solution: The invention provides a self-contained, removable filtering casing that can be accessed from the top of the cleaner. This casing is formed from two distinct shells: a first shell that acts as a debris collection "pocket" and a second shell that functions as a liquid inlet. The two shells fit together to form a single, integral unit for removal from the cleaner body, and can then be separated from one another for easy emptying and cleaning ('031 Patent, Abstract; col. 2:19-51).
  • Technical Importance: This design improves user convenience by allowing for top-access and easy handling of the filter mechanism, a frequent point of interaction for the end-user.

Key Claims at a Glance

  • The complaint asserts direct infringement of at least Claim 1 (Compl. ¶51).
  • Independent Claim 1 requires, among other elements:
    • A body with an inlet, outlet, and filtration chamber.
    • A filtering device comprising a first shell (with peripheral filtering walls defining a debris recovery space) and a second shell fitted to the first shell.
    • The two shells are configured to fit together to form an "integral filtering casing" that is "removable in one piece" from the filtration chamber.
    • When removed, one of the shells is "movable relative to the other" for emptying debris.
  • The complaint notes that infringement is not limited to Claim 1, reserving the right to assert other claims (Compl. ¶50).

U.S. Patent No. 8,393,029 - "Apparatus For Cleaning A Submerged Surface Including A Brushing Device Driven By Members For Driving The Apparatus On The Submerged Surface"

  • Issued: March 12, 2013 (the "’029 Patent")

The Invention Explained

  • Problem Addressed: The patent background discusses drawbacks of prior art brushing mechanisms. Some use drive members separate from the wheels, which adds weight, complexity, and energy consumption. Others integrate brushing surfaces onto the wheels themselves, which can be ineffective and may project debris away from the cleaner's intake ('029 Patent, col. 1:49-col. 2:19).
  • The Patented Solution: The patented invention uses a drive wheel of the cleaner to also rotate a separate brush. This is achieved through a mechanical linkage where an "internally toothed ring" fixedly joined to the wheel engages a "pinion" connected to the brush assembly. This arrangement causes the brush to rotate in the same direction as the drive wheel, providing powered scrubbing that is synchronized with the cleaner's movement ('029 Patent, Abstract).
  • Technical Importance: This approach provides a mechanically simple and compact solution for powering a brush without requiring a separate motor or relying on less effective integrated wheel-brushes.

Key Claims at a Glance

  • The complaint asserts direct infringement of at least Claim 1 (Compl. ¶61).
  • Independent Claim 1 requires, among other elements:
    • A body with an inlet and outlet.
    • A pumping device.
    • A wheel "having an internally toothed ring."
    • A brush assembly with a brush and a shaft.
    • A "pinion engaging the internally toothed ring and connected to the shaft" such that rotation of the wheel causes rotation of the pinion and the brush.
  • The complaint reserves the right to assert other claims (Compl. ¶60).

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 (the "’207 Patent")
  • Technology Synopsis: The patent addresses the challenge of ensuring that an automated pool cleaner has satisfactorily cleaned all pool surfaces. The described solution uses at least one camera to capture images of the pool, and a controller analyzes the imagery to determine a "cleanliness characteristic" (e.g., identifying missed spots or insufficiently cleaned areas) and generates control signals to direct the cleaner's movement in response ('207 Patent, Abstract; col. 1:21-28).
  • Asserted Claims: At least independent claim 2 is asserted (Compl. ¶70).
  • Accused Features: The complaint accuses products incorporating Defendant’s "Vision Tech system," such as the Wybot M2, of infringement (Compl. ¶¶43, 71).

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 "’766 Patent")
  • Technology Synopsis: Belonging to the same family as the ’207 Patent, this patent also relates to using visual data for improved cleaning performance. The invention involves a system with a camera to capture imagery and a controller that analyzes the imagery to determine a cleanliness characteristic of the surface, using that determination to generate control signals that direct the cleaner’s movement ('766 Patent, Abstract).
  • Asserted Claims: At least independent claim 4 is asserted (Compl. ¶80).
  • Accused Features: The complaint accuses products incorporating Defendant’s "Vision Tech system," such as the Wybot M2, of infringement (Compl. ¶¶43, 81).

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 "’191 Patent")
  • Technology Synopsis: Also from the same family as the ’207 and ’766 Patents, this invention describes a self-propelled pool cleaner with an onboard camera and controller. The camera captures an image of a portion of the submerged surface, and the controller is configured to generate a control signal, in response to the image, to cause movement of the cleaner to or away from that portion of the surface ('191 Patent, Claim 1).
  • Asserted Claims: At least independent claim 3 is asserted (Compl. ¶90).
  • Accused Features: The complaint accuses products incorporating Defendant’s "Vision Tech system," such as the Wybot M2, of infringement (Compl. ¶¶43, 91).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies a broad range of robotic pool cleaners as the Accused Products, including the Wybot C1, Wybot C1 Pro, Wybot C1 Max, Wybot C2 Vision, Wybot M2, Wybot S2, Wybot S2 Pro, Wybot S2 Solar, Wybot S2 Solar Vision, AquaClean, Winny HJ3172, Bugson, Bugson Plus, and Aquamoto Scrubo Pro (Compl. ¶¶3, 5, 41, 47).
  • Functionality and Market Context: The Accused Products are described as robotic pool cleaners marketed, sold, and imported into the United States (Compl. ¶4). The complaint alleges that certain products, such as the Wybot M2, C2 Vision, and S2 Solar Vision, implement an infringing "Vision Tech system" related to the camera-based patents (Compl. ¶¶43, 45). The complaint alleges Defendant sells these products through its websites and other U.S. distribution channels and has advertised them in U.S. publications and at trade shows (Compl. ¶¶3, 4, 7).

IV. Analysis of Infringement Allegations

The complaint states that exemplary claim charts are attached as exhibits for each of the asserted patents (Compl. ¶¶51, 61, 71, 81, 91). As these exhibits were not provided, this analysis summarizes the narrative infringement theory presented in the complaint.

’031 Patent Infringement Allegations

The complaint alleges that the Accused Products, including the Wybot C1 and Wybotics HJ3172, meet every limitation of at least claim 1 of the ’031 Patent (Compl. ¶51). The infringement theory centers on the structure of the products' filtration systems, which allegedly incorporate a removable filtering device made of two shells that function together as a single casing, consistent with the claim elements.

’029 Patent Infringement Allegations

The complaint alleges that the Accused Products, including the Wybotics HJ3172, meet every limitation of at least claim 1 of the ’029 Patent (Compl. ¶61). The core of this allegation is that the accused cleaners utilize a mechanism where a brushing device is driven by the rotation of the cleaner’s wheels via an internally toothed ring and pinion engagement, as recited in the claim.

  • Identified Points of Contention:
    • Scope Questions: For the ’031 Patent, a potential point of contention is the definition of "integral filtering casing" and whether the accused products' two-part filter systems meet this limitation. For the ’029 Patent, the dispute may focus on whether the accused mechanism constitutes a "pinion engaging the internally toothed ring" as construed by the court.
    • Technical Questions: A key factual question, particularly in light of the prior ITC proceeding, is whether the filtration and brushing mechanisms in the "newly introduced infringing products" (Compl. ¶47) are structurally and functionally equivalent to the designs of the products previously at issue. For the camera patents (’207, ’766, ’191), the central technical question will be what functions the accused "Vision Tech system" actually performs and whether its method of processing image data to control movement meets the specific limitations of the asserted claims, such as determining a "cleanliness characteristic."

V. Key Claim Terms for Construction

  • The Term: "integral filtering casing" (’031 Patent, Claim 1)

  • Context and Importance: The structure of the claimed invention hinges on the two shells forming a single, "integral" unit for removal. The scope of this term will be critical in determining whether a filter whose parts are merely placed together, rather than securely interlocked, infringes. Practitioners may focus on this term because the specific nature of the connection between the two "shells" could be a primary non-infringement argument.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification states the shells "can be fitted together so as to form an integral filtering casing" ('031 Patent, col. 2:38-40), which may support an interpretation where any method of fitting the parts together to create a single removable unit suffices.
    • Evidence for a Narrower Interpretation: The patent's preferred embodiment discloses a specific mechanical connection involving pins, apertures, and a catch mechanism ('031 Patent, col. 6:21-48; Fig. 7). This could support a narrower construction requiring a specific type of interlocking engagement for the casing to be considered "integral."

  • The Term: "pinion engaging the internally toothed ring" (’029 Patent, Claim 1)

  • Context and Importance: This term defines the core of the power transfer mechanism from the wheel to the brush. The infringement analysis for the ’029 patent will turn on whether the accused products' drive mechanism meets this specific mechanical limitation.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The plain language of the claim does not specify the type of teeth, the material, or the precise nature of the contact, suggesting any gear-like engagement that transfers rotational motion could fall within its scope.
    • Evidence for a Narrower Interpretation: The abstract and detailed description refer to a "brush pinion engaged with a toothed ring on the wheel" ('029 Patent, Abstract; col. 3:23-26). A party might argue that "engaging" should be limited to the direct gear-tooth-to-gear-tooth contact depicted in the patent's figures, potentially excluding alternative power transfer methods.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all five patents. Inducement is based on allegations that Defendant provides instructions, user manuals, and website information that encourage and explain how to use the Accused Products in an infringing manner (Compl. ¶¶52, 62, 72, 82, 92). Contributory infringement is based on allegations that the products are specifically made for an infringing use and have no substantial non-infringing uses (Compl. ¶¶53, 63, 73, 83, 93).
  • Willful Infringement: Willfulness is alleged for all five patents. For the ’031 and ’029 Patents, knowledge is alleged from at least the July 29, 2022 filing of the prior ITC and district court actions, with willfulness predicated on Defendant allegedly resuming infringement after representing it would cease its activities (Compl. ¶57). For the ’029 Patent specifically, knowledge is also alleged from as early as a letter dated February 12, 2016 (Compl. ¶62). For the ’207, ’766, and ’191 Patents, knowledge is alleged from a notice letter dated June 4, 2024, with willfulness based on continued infringement after that date (Compl. ¶¶77, 87, 97).

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

  • A central issue will be one of procedural history and intent: What is the legal effect of Defendant’s prior representations to the ITC that it would cease infringing the ’031 and ’029 Patents? The court will need to determine if this history primarily supports Plaintiff’s claim for willful infringement or if it gives rise to other legal or equitable arguments.
  • A key factual question will be one of technical identity: Are the Defendant's "newly introduced" products "non-materially different" from the products subject to the prior ITC action, as the complaint alleges? This will require a granular comparison of the accused product designs against the limitations of the ’031 and ’029 patents.
  • A core evidentiary question for the newer camera patents will be one of functional operation: What is the precise method of operation of the accused "Vision Tech system," and does the evidence show that it performs the specific functions required by the asserted claims, such as determining a "cleanliness characteristic" from image data and generating a control signal based on that specific determination?