PTAB

IPR2021-00545

SharkNinja Operating LLC v. iRobot Corp

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Autonomous Floor-Cleaning Robot
  • Brief Description: The ’511 patent discloses an autonomous floor-cleaning robot featuring a collection of conventional components. Key elements include a wheeled housing, a motor drive for propulsion, an obstacle detector with a control circuit for navigation, a powered primary brush assembly, and a powered side brush assembly to direct debris toward the main cleaning head.

3. Grounds for Unpatentability

Ground 1: Obviousness over Bisset in view of Toyoda or Ye - Claims 1, 8-12, 16, 18, 19, 22-25, 32-34, 37, 55, 56, and 62 are obvious over Bisset in view of Toyoda or Ye.

  • Prior Art Relied Upon: Bisset (WO 00/38026), Toyoda (Japanese Publication # JP2000-353014), and Ye (Chinese Publication # CN 2389761Y).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Bisset, an autonomous vacuum cleaner, disclosed nearly all limitations of the challenged independent claims, including a wheeled housing, motor drive, obstacle sensors, a control circuit, and a powered primary brush. However, Bisset lacked a dedicated side brush. Petitioner argued that Toyoda and Ye both taught self-propelled cleaning robots that explicitly included powered side brushes to improve cleaning efficacy, particularly in corners and along edges where a central primary brush cannot reach.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the teachings of Bisset with Toyoda or Ye to improve the cleaning performance of Bisset's robot. The benefits of side brushes were well-known in the art of floor cleaning for improving reach and overall cleaning ability. Adding side brushes as taught by Toyoda or Ye to the Bisset robot was a predictable solution to a known problem (incomplete edge and corner cleaning).
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination, as it involved applying a known technique (side brushes) to a similar device (an autonomous vacuum) to achieve a predictable result (improved cleaning coverage). The petition cited numerous other prior art examples of side brushes on robotic vacuums to demonstrate this was a conventional design choice.

Ground 2: Obviousness over Bisset, Toyoda/Ye, and Jones - Claims 14 and 36 are obvious over Bisset in view of Toyoda or Ye and Jones.

  • Prior Art Relied Upon: Bisset (WO 00/38026), Toyoda (Japanese Publication # JP2000-353014) or Ye (Chinese Publication # CN 2389761Y), and Jones (a 1998 textbook, Mobile Robots: Inspiration to Implementation).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the combination of Bisset and Toyoda/Ye by adding Jones to teach the limitations of claims 14 and 36, which require a displaceable bumper and a corresponding displacement sensor. Jones, a textbook on mobile robot design, explicitly taught the use of force sensors, including a full-coverage, force-detecting bumper with microswitches for cylindrical robots.
    • Motivation to Combine: Petitioner argued that while Bisset's robot included ultrasonic and infrared obstacle sensors, a POSITA would be motivated to add the force-detecting bumper taught by Jones to provide redundancy and a "fail-safe" mechanism. This would prevent the robot from becoming stuck or colliding with obstacles that the other sensors might miss. Jones taught that redundancy was a common and important principle in robotic design to handle sensor errors.
    • Expectation of Success: A POSITA would expect success in adding a bumper to the Bisset robot. Jones provided clear instructions on how to implement such a bumper and interface its sensors with a microprocessor, making the integration into Bisset's existing control system straightforward.

Ground 3: Obviousness over Bisset, Toyoda/Ye, and Horst - Claims 16 and 17 are obvious over Bisset in view of Toyoda or Ye and Horst.

  • Prior Art Relied Upon: Bisset (WO 00/38026), Toyoda (Japanese Publication # JP2000-353014) or Ye (Chinese Publication # CN 2389761Y), and Horst (Patent 3,732,590).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground further modifies the base combination to address claim 17, which recites laterally extending brush arms from which bristles extend. Petitioner contended that Horst taught a rotary sweeper with a plurality of arms extending radially from a central hub, with bristles arranged on each arm.
    • Motivation to Combine: A POSITA would be motivated to incorporate Horst's teachings to expand the diameter and improve the reach of the side brushes added from Toyoda or Ye. This modification would further enhance the robot's ability to clean into corners. Additionally, Horst taught a design where the bristle arms were easily replaceable, which would motivate a POSITA to improve the serviceability of the Bisset robot's side brushes.
    • Expectation of Success: The combination was presented as the use of a known technique (bristle arms) to improve a similar device (rotary sweeping brushes) in a predictable way (improved reach and easier replacement). A POSITA could readily adapt the size and materials of Horst's arms for use on the modified Bisset robot.

4. Arguments Regarding Discretionary Denial

  • §314(a) (Fintiv Factors): Petitioner argued against discretionary denial under Fintiv, emphasizing that the petition was filed very early in the parallel district court and ITC proceedings, before significant investment had been made in those cases. Petitioner stipulated that if IPR is instituted, it will not pursue the same invalidity grounds in the parallel litigation, eliminating concerns of overlap and inefficiency. Petitioner also asserted the strong merits of the petition weighed heavily in favor of institution.
  • §325(d): Petitioner contended that denial under §325(d) was inappropriate because the key prior art and arguments were not previously considered by the USPTO. While Bisset was listed in an Information Disclosure Statement during prosecution of the ’511 patent, there was no evidence the Examiner substantively reviewed it. The other primary references (Toyoda, Ye, Jones, Horst) and the proposed combinations are entirely new and non-cumulative to the art considered during the original examination.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 8-12, 14, 16-19, 22-25, 32-34, 36-37, 55, 56, and 62 of the ’511 patent as unpatentable under 35 U.S.C. §103.