SharkNinja Operating LLC v. iRobot Corp

1. Case Identification

• Case #: IPR2020-01639
• Patent #: 10,296,007
• Filed: September 24, 2020
• Petitioner(s): SharkNinja Operating LLC, SharkNinja Management LLC, and SharkNinja Sales Company
• Patent Owner(s): iRobot Corporation
• Challenged Claims: 1-22

2. Patent Overview

• Title: Control System for a Cleaning Robot
• Brief Description: The ’007 patent discloses an autonomous cleaning robot and methods for its maneuvering. The robot is equipped with sensors to detect a border between different floor surfaces (e.g., carpet and hard floor) and a controller that alters the robot’s movement based on sensor output to avoid, follow, or conditionally cross the detected border.

3. Grounds for Unpatentability

Ground 1: Obviousness over Köchel - Claims 1-7, 10-18, 20, and 22 are obvious over Köchel.

• Prior Art Relied Upon: Köchel (German Patent Publication No. DE10113105).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Köchel, an "autonomous floor care machine," discloses all limitations of the challenged claims. Köchel teaches a robot with a drive system, a controller ("evaluation electronics"), and ultrasonic sensors to recognize different floor conditions like "hard floor" or "carpet floor." The sensors detect a "transition edge" between surfaces by comparing the amplitudes of reflected ultrasonic signals. Upon detecting this edge, Köchel’s controller alters the robot's travel direction to either travel along the edge or change direction to stay within a boundary, thereby keeping at least a portion of the robot from crossing the edge. This core teaching allegedly maps to the limitations of independent claims 1 and 13.
  • Prior Art Mapping (Dependent Claims): Petitioner further contended that Köchel teaches limitations of various dependent claims. For claim 4, Köchel discloses multiple ultrasonic sensors at the periphery of the robot that work in parallel to detect an edge. For claims 5 and 6, Köchel’s sensors detect floor elevation ("no floor" or "downward leading steps") and reflectivity (based on the "amplitudes of the reflected and received signal"), respectively. For claim 10, Köchel’s ability to detect a "drop" or lack of floor and execute a "course correction" teaches redirecting the robot away from a cliff edge. For claim 12, Köchel explicitly describes "travel along the transitional edge," teaching the robot to follow a detected border.

Ground 2: Obviousness over Köchel and Windorfer - Claims 8, 9, 19, and 21 are obvious over Köchel in view of Windorfer.

• Prior Art Relied Upon: Köchel (German Patent Publication No. DE10113105) and Windorfer (Application # 2014/0075689).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that the combination of Köchel and Windorfer renders the remaining dependent claims obvious. This ground primarily addresses claim limitations not explicitly found in Köchel alone: the use of an infrared sensor and crossing a border after a predetermined cleaning period.
    • For claims 8 and 19 (requiring an infrared signal emitter), Petitioner argued that while Köchel teaches ultrasonic sensors, Windorfer discloses an autonomous cleaning appliance that explicitly uses "ultrasound and/or infrared sensors" for detecting surface characteristics like the border of a carpet.
    • For claims 9 and 21 (requiring the robot to cross an edge after a predetermined cleaning period or triggering event), Petitioner argued that Windorfer teaches this exact functionality. Windorfer discloses that its robot may travel on a carpet for a "specific time period" or "until the particular cleaning has concluded" before driving across the carpet’s edge to continue cleaning the larger area.
  • Motivation to Combine:
    • A POSITA would combine Köchel with Windorfer's sensor teaching as a simple substitution of one known sensor type (ultrasound) for another (infrared) to achieve the same predictable result of surface detection. Windorfer itself suggests their interchangeability, and the ’007 patent acknowledges that various conventional sensors could be used.
    • A POSITA would combine Köchel’s edge-following robot with Windorfer's timed-cleaning feature to create a more efficient and thorough cleaning method. This would allow the robot to completely clean one surface type (e.g., a carpet) before crossing the border to clean an adjacent one, a logical and predictable improvement.
  • Expectation of Success: A POSITA would have a reasonable expectation of success in making these combinations. Both infrared sensing and timed-based cleaning controls were well-known techniques in the field of robotic cleaners, as evidenced by Windorfer, and integrating these predictable solutions into Köchel's system would have been straightforward.

4. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-22 of the ’007 patent as unpatentable.