PTAB

IPR2020-00863

SharkNinja Operating LLC v. iRobot Corp

Key Events

Petition

Case #: IPR2020-00863
Patent #: 8,418,303
Filed: May 6, 2020
Petitioner(s): SharkNinja Operating LLC, SharkNinja Management LLC, and SharkNinja Sales Company
Patent Owner(s): iRobot Corporation
Challenged Claims: 1-2, 4-12, and 14-15

Title: Cleaning Robot Roller Processing
Brief Description: The ’303 patent relates to a floor cleaner featuring a driven brush assembly with an axial end guard. The invention's stated purpose is to prevent hair, threads, and other filaments from wrapping around the brush ends and entering the bearings, which could otherwise lead to jamming or decreased performance.

Prior Art Relied Upon: Lang (Patent 1,680,741) and Fahlen (Patent 4,238,870).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Lang, a 1928 patent for an upright vacuum cleaner, discloses every element of the base claims. Lang was asserted to teach a floor cleaner with a chassis, a cleaning assembly, a driven brush with bristles, end mounting features (bearing structures), and a removable, cup-shaped "thread guard." Petitioner mapped this thread guard directly to the claimed "axial end guard," arguing it was configured to prevent filaments from wrapping around the bearing housing and was removable for servicing, anticipating the core features of the challenged claims.
- Motivation to Combine (for §103 grounds): The combination with Fahlen was presented to address a potential interpretation of the "compliant portion" limitation that requires a beater element in addition to bristles. Fahlen teaches a brush-beater roller that combines bristles with a compliant beater bar. Petitioner argued a POSITA would combine Fahlen's beater bar with Lang's brush to achieve the known and predictable result of more effective dirt removal from carpet, a common design goal.
- Expectation of Success: Combining a known agitating element (Fahlen's beater bar) with a known bristled brush (Lang's) was a conventional and straightforward modification for a POSITA, with a high expectation of success.

Prior Art Relied Upon: Lang (Patent 1,680,741) and Krier (Patent 3,588,945).
Core Argument for this Ground:
- Prior Art Mapping: This ground specifically addressed the limitation in claim 8 requiring bristles arranged in a "substantially V-shaped groove configuration." Lang was asserted to provide the base floor cleaner with a bristled brush, while Krier was introduced for its explicit teaching of a brush with bristles arranged in a V-shaped or "herringbone" pattern.
- Motivation to Combine: Petitioner argued that Krier provides the express motivation for the combination, as it teaches that a V-shaped bristle pattern more effectively channels debris toward the vacuum's centrally located suction port. A POSITA would have been motivated to substitute Lang's simpler bristle arrangement with Krier's superior V-shaped design to achieve the known benefit of improved cleaning efficiency.
- Expectation of Success: The substitution of one known bristle pattern for another on a conventional brushroll was presented as a simple design choice with predictable and desirable outcomes for improving debris collection.

Prior Art Relied Upon: Brundula (Patent 5,452,490) and Lang (Patent 1,680,741). This ground also included an alternative combination adding Fahlen.
Core Argument for this Ground:
- Prior Art Mapping: This ground provided an alternative unpatentability theory using a more modern primary reference. Brundula was argued to disclose the key brushroll features, including an end assembly with a thread guard, an end cap, and a labyrinth seal that prevents filaments from trapping near the bearing. Petitioner argued these elements meet the limitations for the axial end guard. Lang was relied upon to supply the conventional chassis and cleaning assembly housing that were not detailed in Brundula.
- Motivation to Combine: Brundula explicitly describes its brushroll as being "for floor care appliances" like vacuum cleaners. A POSITA would be motivated to incorporate Brundula's improved brushroll into a conventional vacuum cleaner, such as the one disclosed by Lang, to create a complete and functional product. The alignment of Brundula's V-shaped bristle pattern with an offset suction port, similar to Lang's, provided a specific technical rationale.
- Expectation of Success: Petitioner contended that modifying a standard vacuum cleaner nozzle to accept a different brushroll, even one with a different end mount, was a routine and predictable task for a POSITA, especially given the common industry practice of designing interchangeable brushrolls.

Petitioner requests the institution of an inter partes review and the cancellation of claims 1-2, 4-12, and 14-15 of Patent 8,418,303 as unpatentable.