PTAB

IPR2026-00158

Wybotics Co Ltd v. Zodiac Pool Systems LLC

Log In
Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Pool Cleaning System and Method to Automatically Clean Surfaces of a Pool Using Images from a Camera
  • Brief Description: The ’191 patent discloses a self-propelled, robotic swimming pool cleaner. The system uses at least one camera to capture images of submerged pool surfaces and a controller that processes these images to generate control signals, causing the cleaner to move within the pool to perform cleaning tasks.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-3 by Fu

  • Prior Art Relied Upon: Fu (CN 101139007 B).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fu anticipates every limitation of claims 1-3. Fu discloses an "underwater cleaning robot" designed for cleaning swimming pool floors and walls. This robot comprises a vehicle body ("robot housing body"), means for moving ("cleaning driving wheels" powered by DC motors), a filter ("water flow filter screen" within a drainage mechanism), at least one camera ("monitoring cameras"), and a controller ("central processor"). The controller is positioned within the body, receives images from the cameras, processes them to determine the pool's "level of cleanliness," and generates control signals to autonomously plan paths and move the robot "to, or away from" a pictured region based on the cleanliness determination. Petitioner asserted that since Fu anticipates the narrower claim 1, it also anticipates the broader independent claims 2 and 3.

Ground 2: Obviousness of Claims 1-3 over Fu in View of Benzler

  • Prior Art Relied Upon: Fu (CN 101139007 B), Benzler (Application # 2010/0299016).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that if Fu is found not to explicitly teach generating a control signal to move "to, or away from" a specific portion of the submerged surface, this limitation is rendered obvious by Benzler. Benzler discloses an activation system for robotic vehicles, including a "particularly preferred" embodiment of a pool-robotic vehicle. Benzler’s system uses a camera and a logic unit to detect "differently conditioned sections" of a work area (e.g., cleaned vs. uncleaned) and calculates driving instructions to move the robot toward or away from such sections to improve efficiency.
    • Motivation to Combine: A POSITA would combine Fu and Benzler as both address autonomous, image-guided robotic cleaners. A POSITA would have been motivated to incorporate Benzler’s classification-driven motion control into Fu’s system to improve cleaning efficiency and coverage performance. This represents a known technique for prioritizing dirty areas and reducing redundant cleaning.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination would not require new hardware or unconventional algorithms. It would involve applying Benzler's known control logic to Fu's existing hardware (camera, processor, wheels), which constitutes a routine controller configuration.

Ground 3: Obviousness of Claims 1-3 over Schnittman in View of Benzler

  • Prior Art Relied Upon: Schnittman (Application # 2012/0169497), Benzler (Application # 2010/0299016).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted Schnittman discloses a self-propelled autonomous cleaning robot with all the core claimed components, including a body, a drive system, a filter, a camera, and a microprocessor controller. Schnittman’s controller processes camera images to recognize debris and generates control signals to "maneuver the robot 11 toward the debris" or "to avoid obstacles." While Schnittman teaches a general-purpose cleaning robot, Benzler teaches applying this exact type of image-based navigation to a "pool-robotic vehicle" that drives on the bottom of a pool.
    • Motivation to Combine: A POSITA designing a pool cleaner would have looked to both general autonomous cleaning art like Schnittman and specific pool-related art like Benzler. Both references address the same problem of using visual data to enable a robot to make cleaning and navigation decisions. Benzler’s explicit disclosure of an underwater embodiment provides clear motivation and guidance for adapting Schnittman’s analogous system to the pool-cleaning context.
    • Expectation of Success: A POSITA would have had a high expectation of success. The necessary adaptations to make Schnittman’s system water-ready (e.g., waterproofing housings, moisture-sealing electronics, ensuring traction on submerged surfaces) were straightforward and well within the ordinary skill in the art at the time of the invention.
  • Additional Grounds: Petitioner asserted in the alternative that claims 1-3 are obvious over Fu alone (Ground 1b), arguing that even if not anticipating, Fu’s disclosure of comparing an image to a cleanliness threshold would have made it obvious to use that information to guide the robot’s movement toward dirtier areas.

4. Key Claim Construction Positions

  • Petitioner argued that the term “means for moving the vehicle body within the swimming pool,” recited in all challenged claims, is a means-plus-function term under 35 U.S.C. §112(f).
  • Petitioner identified the claimed function as "moving the vehicle body within the swimming pool" and the corresponding structures from the ’191 patent’s specification as “wheels, rollers, tracks or other surface contacting members powered by a motor and the like” and “vacuum or liquid jets.”

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3 of the ’191 patent as unpatentable.