Wybotics Co Ltd v. Zodiac Pool Systems LLC

1. Case Identification

• Case #: IPR2026-00159
• Patent #: 11,262,766
• Filed: November 25, 2025
• Petitioner(s): Wybotics, Co. Ltd.
• Patent Owner(s): Zodiac Pool Systems LLC
• Challenged Claims: 1-5

2. Patent Overview

• Title: Pool Cleaning System and Method to Automatically Clean Surfaces of a Pool Using Images from a Camera
• Brief Description: The ’766 patent discloses a self-propelled, robotic swimming pool cleaner that uses an onboard camera to capture images of submerged surfaces. A controller analyzes these images to generate control signals that direct the cleaner’s movement within the pool.

3. Grounds for Unpatentability

Ground 1: Anticipation by Fu - Claims 1-4 are anticipated by Fu under 35 U.S.C. §102.

• Prior Art Relied Upon: Fu (CN 101139007 B).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Fu, which describes an "underwater cleaning robot," discloses every limitation of claims 1-4. Fu’s robot includes a vehicle body, a mobility platform with wheels driven by DC motors (means for moving), a drainage mechanism with a filter screen, and monitoring cameras mounted on the housing. Fu’s control system, comprising a central processor within the robot's body, receives images from the cameras and, in an autonomous mode, generates control signals to drive the wheels. Petitioner asserted that Fu’s process of comparing captured images to a "cleanliness image threshold" and then planning cleaning movements constitutes generating a control signal to move the body "to, or away from" a portion of the surface.

Ground 2: Obviousness over Fu and Benzler - Claims 1-4 are obvious over Fu in view of Benzler.

• Prior Art Relied Upon: Fu (CN 101139007 B) and Benzler (Application # 2010/0299016).
• Core Argument for this Ground:
  • Prior Art Mapping: To the extent Fu is found not to explicitly teach generating a control signal to move "to, or away from" a specific portion of the submerged surface, Petitioner argued this limitation is rendered obvious by Benzler. Benzler discloses an activation system for robotic vehicles, including a preferred "pool-robotic vehicle" embodiment. Benzler’s system uses a camera and a logic unit to detect differently conditioned sections of a work area (e.g., mowed vs. unmowed lawn) and calculates driving instructions to move the vehicle toward a target section and away from a non-target section.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Fu and Benzler because both address autonomous, image-guided robotic cleaning. A POSITA would have been motivated to incorporate Benzler's more specific image-based motion control (moving toward dirty areas and away from clean ones) into Fu’s system to improve cleaning efficiency and coverage, a known technique for optimizing robotic cleaners.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because Fu already provided the necessary hardware (camera, processor, wheels). Implementing Benzler’s classification-based movement would have involved a routine controller configuration within the skill of a POSITA.

Ground 3: Obviousness over Schnittman and Benzler - Claims 1, 2, and 4 are obvious over Schnittman in view of Benzler.

• Prior Art Relied Upon: Schnittman (Application # 2012/0169497) and Benzler (Application # 2010/0299016).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Schnittman, which describes an autonomous cleaning robot (e.g., for floors), discloses a vehicle body, a drive assembly with wheels, an internal filter, a camera, and a microprocessor controller. Schnittman’s microprocessor processes signals from the camera to recognize debris and maneuver the robot toward it. While Schnittman discloses a general cleaning robot, Benzler provides the specific context of a pool-cleaning robot and teaches adapting such systems for underwater use. The combination of Schnittman's debris-targeting logic with Benzler's pool-cleaning embodiment renders the claimed invention obvious.
  • Motivation to Combine: A POSITA would combine Schnittman and Benzler because they address the same problem of using an image to guide a cleaning robot. A POSITA would have recognized that Schnittman's state-of-the-art, debris-responsive cleaning logic could be advantageously applied to the pool-cleaning environment explicitly taught by Benzler. Benzler itself reinforces this by describing its image-based framework across multiple environments (land and water), demonstrating the adaptability of such principles.
  • Expectation of Success: Success was predictable. Adapting Schnittman’s system for underwater use, as guided by Benzler, would involve straightforward engineering tasks like waterproofing electronics, which were well within the skill of a POSITA at the time.
• Additional Grounds: Petitioner asserted that claim 3 is obvious over Schnittman and Benzler in further view of Bailey (Patent 8,364,309), which teaches a portable electronic device for remote communication with a cleaning robot. Petitioner also argued that claim 5, which adds a "chemical dispenser," is obvious over the primary combinations (Fu/Benzler or Schnittman/Benzler) in further view of Hui (Application # 2011/0139727), which explicitly teaches adding a chemical dispenser to a pool cleaning vehicle for sanitization.

4. Key Claim Construction Positions

• Petitioner argued 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).
• The corresponding structures identified in the ’766 patent’s specification are "wheels, rollers, tracks or other surface contacting members powered by a motor and the like" and "vacuum or liquid jets." This construction was central to mapping prior art drive mechanisms to this claim limitation.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-5 of the ’766 patent as unpatentable.