PTAB

IPR2020-00734

SharkNinja Operating LLC v. iRobot Corp

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Petition

1. Case Identification

2. Patent Overview

  • Title: Navigation Control System for Robotic Cleaning Device
  • Brief Description: The ’586 patent discloses a navigation system for an autonomous robotic cleaning device. The system allows a user to select specific rooms for cleaning and to specify a schedule, and the device then autonomously cleans the selected rooms according to the schedule.

3. Grounds for Unpatentability

Ground 1: Obviousness over Toshiba in view of Ruffner-556 - Claims 1-9, 11, 12, and 14 are obvious over Toshiba in view of Ruffner-556.

  • Prior Art Relied Upon: Toshiba (Japanese Patent Application Publication No. 2002-85305) and Ruffner-556 (Application # 2002/0156556).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Toshiba taught the core elements of independent claim 1, including an autonomous robotic cleaner with a drive, cleaning apparatus, and a processor. Toshiba disclosed a robot that communicates wirelessly with a home server, allowing a user to select one or more rooms for cleaning via a graphical interface. To the extent Toshiba did not explicitly disclose receiving a detailed user-selected schedule, Petitioner asserted that Ruffner-556 supplied this teaching. Ruffner-556 disclosed a mobile robotic appliance that could be programmed remotely via a webpage to clean specific areas according to a user-defined schedule, including start time and frequency (e.g., daily, weekly). Petitioner also argued that while Toshiba’s control sections imply a processor, Ruffner-556 explicitly disclosed a "processor 66" for its controller, making the use of a processor in the combination explicit.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the teachings of Ruffner-556 with Toshiba to improve Toshiba’s robot cleaner. Adding robust scheduling functionality would be a desirable and predictable improvement, allowing the robot to clean at convenient times (e.g., at night or when residents are away) without manual initiation, thereby increasing the device's autonomy and utility.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining these references. Both relate to software-controlled robotic cleaners that receive user inputs. Implementing the scheduling software logic from Ruffner-556 into the Toshiba system, which already had a user interface for room selection and wireless communication, would be a straightforward software modification.

Ground 2: Obviousness over Toshiba/Ruffner-556 and Goncalves - Claim 10 is obvious over the combination of Toshiba, Ruffner-556, and Goncalves.

  • Prior Art Relied Upon: Toshiba, Ruffner-556, and Goncalves (Application # 2004/0167667).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Toshiba/Ruffner-556 combination to address the limitations of dependent claim 10, which required an "upward-angled camera" for navigating based on "visible points on wall surfaces." While Toshiba disclosed a "visual sensor," Petitioner introduced Goncalves to explicitly teach the upward-angled orientation. Goncalves disclosed a mobile robot with a visual sensor that can be a "generally upward-pointing camera" to recognize landmarks, including objects mounted on a wall, for navigation.
    • Motivation to Combine: A POSITA would be motivated to incorporate Goncalves's upward-pointing camera into the base robot of Toshiba/Ruffner-556 to improve navigational accuracy. Using higher-positioned, fixed landmarks on walls is more reliable for navigation than relying on floor-level objects or furniture that may be moved. This modification would make the robot's mapping and localization more robust.

Ground 3: Obviousness over Toshiba/Ruffner-556 and Köchel - Claims 13, 17, and 19 are obvious over the combination of Toshiba, Ruffner-556, and Köchel.

  • Prior Art Relied Upon: Toshiba, Ruffner-556, and Köchel (German Patent Publication No. DE10113105).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground targeted claims related to "area rug cleaning" and adjusting cleaning behavior based on "a signal indicative of a floor type." Petitioner used Köchel to supply these features. Köchel disclosed a vacuum cleaner with ultrasonic transducers capable of detecting different floor types, such as "soft carpet, carpet, and hard floor." Based on the detected floor type, Köchel’s processor adjusted cleaning behavior, for example, by deactivating a motorized brush on a hard surface to prevent damage.
    • Motivation to Combine: A POSITA would combine Köchel's floor detection system with the Toshiba/Ruffner-556 robot to enhance its cleaning effectiveness and versatility. Automatically adjusting cleaning modes for different surfaces is a known method to optimize performance (e.g., aggressive brushing on carpet, gentle suction on hardwood) and prevent damage to either the floor or the robot, representing a common-sense improvement.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on the primary Toshiba/Ruffner-556 combination in view of other references: Taylor for mapping and avoiding entrapment areas (claim 15); Minolta for using a dirt sensor to create a map of soiled areas (claim 16); and Song for displaying cleaning progress on a remote floor plan (claim 18).

4. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-19 of Patent 9,921,586 as unpatentable under 35 U.S.C. §103.