Wybotics Co Ltd v. Zodiac Pool Systems LLC

1. Case Identification

• Case #: IPR2026-00160
• Patent #: 11,880,207
• Filed: November 25, 2025
• Petitioner(s): Wybotics, Co. Ltd.
• Patent Owner(s): Zodiac Pool Systems LLC
• Challenged Claims: 1-8, 11-14, and 19

2. Patent Overview

• Title: Pool Cleaning System and Method to Automatically Clean Surfaces of a Pool Using Images From a Camera
• Brief Description: The ’207 patent discloses a self-propelled, robotic pool cleaner comprising a vehicle body, propulsion mechanisms, a filter, at least one camera, and a controller. The controller is configured to analyze images captured by the camera and generate control signals to direct the cleaner’s movement within the pool.

3. Grounds for Unpatentability

Ground 1: Anticipation by Fu - Claims 1-3, 5-8, 12-14, and 19 are anticipated under 35 U.S.C. § 102 by Fu.

• Prior Art Relied Upon: Fu (CN 101139007B).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Fu, which discloses an "underwater cleaning robot," teaches every element of the challenged claims. Fu describes a self-propelled robot with a body, motor-driven wheels (means for moving), a filter screen within a drainage mechanism (filter), and monitoring cameras. Fu’s control system, comprising a central processor, receives images from the cameras, compares them against a "pool cleanliness image threshold" to determine the level of cleanliness, and generates control signals to plan cleaning movements and adjust wheel speeds. Petitioner contended this process inherently generates signals to move the robot toward dirty areas and away from clean areas, thus meeting the key limitation of generating a signal to cause movement "to, or away from, the first object" (i.e., the imaged region of the pool surface).

Ground 2: Obviousness over Fu in view of Benzler - Claims 1-8, 11-14, and 19 are obvious over Fu in view of Benzler.

• Prior Art Relied Upon: Fu (CN 101139007B) and Benzler (Application # 2010/0299016).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that to the extent Fu is found not to explicitly teach generating control signals to cause movement "to, or away from" a specific object, this limitation is rendered obvious by Benzler. Benzler discloses an activation system for robotic vehicles, including an autonomous lawnmower embodiment where a logic unit detects "mowed/not mowed" sections from image data and calculates driving instructions to preferably move the vehicle toward the "not mowed" sections. Combining Benzler’s image-based classification and targeted motion control with Fu’s robotic pool cleaner would result in the claimed invention.
  • Motivation to Combine: A POSITA would combine Fu and Benzler because both relate to autonomous cleaning robots that use image-based navigation. Applying Benzler's method of directing a robot toward target areas (unmowed lawn) and away from non-target areas (mowed lawn) to Fu’s system would be a known and predictable way to improve cleaning efficiency by prioritizing dirtier pool sections and reducing redundant cleaning.
  • Expectation of Success: A POSITA would have a high expectation of success. The combination would not require new hardware, as Fu already provides the necessary camera, processor, and propulsion systems. Implementing Benzler’s classification-driven movement would involve routine controller configuration within the skill of a POSITA.

Ground 3: Obviousness over Schnittman in view of Benzler - Claims 1-7, 11-14, and 19 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 discloses a generic autonomous floor-cleaning robot with all the core components of claim 1: a body, a drive system with wheels, an internal filter, a forward-facing camera, and a microprocessor. Schnittman’s microprocessor processes camera signals to "recognize debris" and "maneuver the robot 11 toward the debris" or "avoid obstacles." While Schnittman does not describe a pool cleaner, Benzler explicitly teaches a pool-robotic vehicle and the adaptation of such autonomous systems for underwater use.
  • Motivation to Combine: A POSITA would combine Schnittman and Benzler because they address the same problem of using image-based perception to enable autonomous cleaning. A POSITA seeking to build a pool cleaner would look to the broader field of autonomous cleaning robots, where Schnittman’s debris-responsive navigation is a key teaching. Benzler provides the specific context and motivation for applying these general principles to an underwater pool environment, demonstrating the known interchangeability of the technology across domains.
  • Expectation of Success: A POSITA would have a reasonable expectation of success, as the necessary adaptations to make Schnittman's robot water-ready (e.g., moisture-sealing electronics, ensuring traction on submerged surfaces) were straightforward and known techniques at the time, as reinforced by Benzler’s disclosure.

• Additional Grounds: Petitioner asserted an alternative obviousness challenge based on Fu alone, and a challenge to claim 8 as obvious over Schnittman in view of Benzler and in further view of Fu.

4. Key Claim Construction Positions

• "means for moving the vehicle body within the swimming pool": Petitioner identified this term from claim 1 as a means-plus-function term governed by 35 U.S.C. § 112(f).
  • Function: "Moving the vehicle body within the swimming pool."
  • Corresponding Structure: Based on the ’207 patent’s specification, Petitioner identified the corresponding structure as "wheels, rollers, tracks or other surface contacting members powered by a motor and the like" and "vacuum or liquid jets."

5. Key Technical Contentions (Beyond Claim Construction)

• Interpretation of "to, or away from": Petitioner advanced a broad technical interpretation of the claim phrase "movement of the body ... to, or away from, the first object." It argued that once a camera captures an image of an object, any subsequent commanded movement of the robot—forward, backward, or turning—will necessarily alter the distance between the robot and the imaged object. Therefore, Petitioner contended that any control signal causing any movement in response to the image inherently satisfies the "to, or away from" limitation.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-8, 11-14, and 19 of the ’207 patent as unpatentable.