PTAB

IPR2020-00907

Bissell Homecare Inc v. Koninklijke Philips NV

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Cleaning Device with Rotating Brushes
  • Brief Description: The ’032 patent discloses a cleaning device, such as a vacuum cleaner, for removing particles from a surface. The device features at least one wetted, rotatable brush that expels fluid droplets as a mist into a defined "coalescing space," where they fuse with air-laden dirt particles drawn in through an inlet. These heavier, coalesced particles are then conveyed by an air stream to a cleansing unit for separation.

3. Grounds for Unpatentability

Ground 1: Anticipation over Philips - Claims 1-3, 5-8, and 15 are anticipated by Philips.

  • Prior Art Relied Upon: Philips (WO 2010/041184).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Philips, a PCT application, disclosed a wet cleaning device that is structurally and functionally identical to the ’032 patent’s two-brush embodiment. Philips taught a device with two counter-rotating brushes with flexible bristles that are wetted by a fluid. These brushes rotate at high speed, picking up dirt and water from a surface and propelling them upwards into an inlet that leads to a debris collecting chamber. Petitioner contended this upward projection of fluid from the wetted brushes inherently creates the claimed "mist" in the space above the brushes, which serves as the "coalescing space." Philips further disclosed that this process can be supported by a vacuum, satisfying the "air stream" and "vacuum source" limitations of independent claims 1 and 15, respectively. The debris collecting chamber in Philips was argued to be the claimed "cleansing unit."

Ground 2: Anticipation or Obviousness over Floeter - Claims 1 and 5-7 are anticipated by Floeter or, alternatively, are obvious over Floeter in view of Mueller, Kasper, or Hirose.

  • Prior Art Relied Upon: Floeter (Patent 1,694,937), Mueller (Patent 5,779,744), Kasper (Patent 8,117,713), and Hirose (Japanese Patent Publication No. 2005-27807).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Floeter’s floor scrubbing machine anticipated the challenged claims. Floeter’s device used two high-speed, counter-rotating brushes that sweep dirt and water from the floor and "project the dirt and water vertically upward with considerable force in the form of a substantially flat jet." Petitioner argued this jet of "water and spray" is propelled into the area above the brushes, which constitutes the claimed "coalescing space." Dirt particles enter through an inlet below the brushes and are propelled into this space to intermingle with the spray. Floeter’s lid and trough system, which deflects and collects the coalesced particles, was identified as the "cleansing unit."
    • Motivation to Combine (for §103 grounds): In the alternative, if Floeter was found not to disclose a vacuum source or an adequate cleansing unit, Petitioner argued a person of ordinary skill in the art (POSITA) would have been motivated to combine Floeter with these features from the secondary references. Mueller, Kasper, and Hirose all taught wet cleaning devices with vacuum sources and air-liquid separators. A POSITA would combine these known elements with Floeter’s brush system to achieve the predictable result of improved dirt and water pickup, a primary goal in the field of floor care.
    • Expectation of Success: Because the combination involved using known components for their established functions—adding a vacuum for suction and a separator for separation—a POSITA would have had a high expectation of success.

Ground 3: Anticipation or Obviousness over Hirose - Claims 1, 5, 9, and 15 are anticipated by Hirose or, alternatively, are obvious over Hirose in view of Beskow or Ishiguro.

  • Prior Art Relied Upon: Hirose (Japanese Patent Publication No. 2005-27807), Beskow (Application # 2008/0148512), and Ishiguro (JP 2005-125035).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Hirose’s electric vacuum cleaner disclosed all elements of the independent claims. Hirose taught a suction head with a rotating wiper having flexible rubber lips. This wiper is wetted by atomized water from a discharge port and, as it rotates, throws up grime and water into a "coalescing space" within the suction head. An inlet suctions air-laden dust from the floor into this same space, where the dust and fluid droplets fuse. The coalesced particles are then conveyed by the vacuum’s airflow to a separation tank, which functions as the claimed "cleansing unit." Petitioner contended that Hirose's flexible "rubber lips" met the broad claim term "flexible brush elements."
    • Motivation to Combine (for §103 grounds): Alternatively, if the "rubber lips" of Hirose were not considered "brush elements," Petitioner argued it would have been obvious to substitute them with a conventional bristle brush as taught by Beskow or Ishiguro. The art showed that different types of agitators (bristle brushes, wipers, etc.) were well-known, interchangeable options in floor cleaners. A POSITA would be motivated to make this substitution to improve cleaning efficacy on different surfaces, a common design consideration.
    • Expectation of Success: Substituting one known type of cleaning agitator for another in Hirose's device was a simple, predictable modification that a POSITA would expect to function successfully.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges for dependent claims 2-3 and 6-14. These grounds were based on the primary combinations of Floeter or Hirose, with additional secondary references cited to teach specific, well-known design parameters such as brush rotational speeds (Worwag), brush diameters (Grey), bristle material (Yuki), and the use of a rotatable centrifugal separator (Kasper II).

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3 and 5-15 of Patent 9,186,032 as unpatentable.