SharkNinja Operating LLC v. iRobot Corp

1. Case Identification

• Case #: IPR2020-00735
• Patent #: 10,045,676
• Filed: March 23, 2020
• Petitioner(s): SharkNinja Operating LLC, SharkNinja Management LLC, and SharkNinja Sales Company
• Patent Owner(s): iRobot Corporation
• Challenged Claims: 1-2, 4-10, 12-15, and 16-18

2. Patent Overview

• Title: Robotic Device and Communication Device
• Brief Description: The ’676 patent discloses a method for operating a robotic cleaning device that communicates wirelessly with a mobile device (e.g., laptop, mobile phone). The system allows the robot to transmit status reports (power level, mission status, errors) to the mobile device and receive commands from it.

3. Grounds for Unpatentability

Ground 1: Obviousness over Toshiba and Ruffner - Claims 1, 4-8, 13, 14, and 16-18 are obvious over Toshiba in view of Ruffner.

• Prior Art Relied Upon: Toshiba (Japanese Patent Application # 2002-85305) and Ruffner (Application # 2002/0049521).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Toshiba taught the core features of independent claim 1, including an autonomous robotic cleaner that communicates with a mobile device (a notebook computer or mobile phone) to transmit status information, such as battery charge and cleaning completion reports (“mission status”). However, Petitioner contended Toshiba did not explicitly teach automatically returning to a dock based on a low power level or reporting a brush error. Ruffner was argued to supply these missing elements, as it disclosed a robotic cleaner that automatically docks to recharge when its battery is low and can report operational problems, such as a tangled brush, to the user.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Toshiba and Ruffner to improve the autonomy and user-friendliness of Toshiba’s robot. Adding Ruffner’s automatic low-power docking and error reporting capabilities were described as known techniques to solve known problems, yielding the predictable result of a more robust, “fully unattended” cleaning system.
  • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved applying known functionalities (automatic recharging, error reporting) from one robotic cleaner (Ruffner) to a similar robotic cleaner (Toshiba) by programming its controller, which was well within the skill of the art.

Ground 2: Obviousness over Toshiba, Ruffner, and Abramson - Claims 2, 9, and 10 are obvious over Toshiba in view of Ruffner and Abramson.

• Prior Art Relied Upon: Toshiba, Ruffner, and Abramson (Application # 2003/0120389).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the base combination of Toshiba and Ruffner and added Abramson to address the limitations of claims 2, 9, and 10, which relate to receiving cleaning power settings from the mobile device. Petitioner argued that Abramson taught a robotic vacuum that receives commands from a remote controller, including "strengths of cleaning" and brush speed adjustments based on surface type, which constituted a user-selected cleaning power setting. The robot then initiated cleaning using that setting.
  • Motivation to Combine: A POSITA would be motivated to incorporate Abramson’s teachings to provide greater user control over the cleaning process in the Toshiba/Ruffner system. This would allow a user to customize cleaning power for different floor types or soil levels, a desirable and known feature that minimizes the need for manual intervention.

Ground 3: Obviousness over Toshiba, Ruffner, and Murray - Claim 15 is obvious over Toshiba in view of Ruffner and Murray.

• Prior Art Relied Upon: Toshiba, Ruffner, and Murray (Application # 2002/0152576).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground added Murray to the base combination to teach the specific limitation of claim 15: transmitting an error report indicative of a filter error. While the primary combination taught reporting a brush error, Petitioner asserted that Murray disclosed a vacuum cleaner with sensors to detect problems with consumable parts, specifically including a “plugged filter,” and could transmit error codes to a user’s mobile device (e.g., a PDA or laptop).
  • Motivation to Combine: A POSITA would be motivated to add Murray’s filter error detection to the Toshiba/Ruffner system to improve maintenance and simplify management of the device. Since both filters and brushes are common consumable parts, extending the existing error-reporting framework to include filter status was argued to be an obvious improvement.

Ground 4: Obviousness over Toshiba, Ruffner, and Otsu - Claim 12 is obvious over Toshiba in view of Ruffner and Otsu.

• Prior Art Relied Upon: Toshiba, Ruffner, and Otsu (Japanese Patent Application # 2002-85305).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground added Otsu to the base combination to address claim 12, which required authenticating the communication link before transmitting reports. Petitioner argued that Otsu taught a communication method between a robot and a mobile phone that checked for access rights before allowing communication and operation.
  • Motivation to Combine: A POSITA would incorporate Otsu's authentication method to solve the known problem of ensuring the robot communicates only with an authorized device, particularly in a smart-home environment with multiple connected devices (as shown in Toshiba). This was presented as a simple and predictable application of a known security feature to the base robotic cleaning system.

4. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-2, 4-10, 12-15, and 16-18 of the ’676 patent as unpatentable.