Beatbot Technology USA Co Ltd v. Zodiac Pool Systems LLC

1. Case Identification

• Case #: IPR2026-00200
• Patent #: 11,262,766
• Filed: January 26, 2026
• Petitioner(s): Beatbot Technology (USA) Co. Ltd.
• Patent Owner(s): Zodiac Pool Systems LLC
• Challenged Claims: 1-5

2. Patent Overview

• Title: Autonomous Pool Cleaning System
• Brief Description: The ’766 patent describes a system for autonomously cleaning a swimming pool using a self-propelled vehicle. The system includes one or more cameras that capture images of the pool, and a controller that analyzes the images to generate control signals for operating the cleaning vehicle.

3. Grounds for Unpatentability

Ground 1: Claims 1-5 are obvious over Durvasula in view of Fu-007

• Prior Art Relied Upon: Durvasula (Application # 2014/0015959) and Fu-007 (Chinese Publication No. CN101139007A).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Durvasula, which is a publication of the patent owner’s own earlier application, taught nearly all elements of the claimed self-propelled, camera-guided pool cleaner. However, Durvasula explicitly disclosed that its controller is located externally, either at a dry station or as a remote server, connected to the submerged vehicle via a physical tether or wireless link. To remedy this deficiency, Petitioner asserted that Fu-007 disclosed an underwater cleaning robot with a fully integrated, onboard control system housed within a sealed, waterproof main shell. The combination of Durvasula's cleaning system with Fu-007's onboard controller renders the claims obvious.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the teachings of Durvasula and Fu-007 to improve the autonomy and safety of the pool cleaner. Durvasula’s reliance on an external controller and tether constrains the robot's range and requires human intervention to manage cable entanglement. Fu-007’s onboard architecture, a well-known design alternative, solves these problems. Furthermore, replacing Durvasula's tethered power configuration with Fu-007’s onboard, sealed, battery-powered system would eliminate the potential for electrical leakage, enhancing overall safety.
  • Expectation of Success: A POSITA would have an expectation of success because positioning a controller within the vehicle body was a known design choice for autonomous pool robots. Fu-007’s controller already performed analogous image-based navigation, so integrating it to execute Durvasula’s control logic (e.g., steering toward missed spots) would yield predictable results.

Ground 2: Claims 1-4 are obvious over Cui in view of Fu-007; Claim 5 is obvious over Cui, Fu-007, and Porat

• Prior Art Relied Upon: Cui (Chinese Publication No. CN1540119A), Fu-007 (Chinese Publication No. CN101139007A), and Porat (Application # 2006/0053572).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that Cui disclosed a camera-based pool cleaner that detects debris by comparing captured images to pre-stored images of a clean pool. Like Durvasula, however, Cui’s controller was an external industrial computer connected to the cleaner via a cable assembly. Petitioner again relied on Fu-007 to teach the missing element: an onboard, self-contained controller. For claim 5, which adds a "chemical dispenser," Petitioner introduced Porat, which taught an automated robotic pool cleaner with an integrated, onboard electrochemical chlorine generator.
  • Motivation to Combine: The motivation to combine Cui and Fu-007 was identical to that for Ground 1: to improve autonomy and safety by replacing a tethered, external controller with a known onboard alternative. A POSITA would be further motivated to incorporate Porat’s chemical dispenser into the Cui/Fu-007 combination to enhance cleaning effectiveness. This would create a single, more convenient device capable of performing both mechanical debris removal and chemical sanitization in one pass.
  • Expectation of Success: A POSITA would expect success in combining Cui and Fu-007 for the same reasons as in Ground 1. Adding Porat’s chemical dispenser would also be a predictable modification, as incorporating such dispensers into robotic cleaners was a known technique for improving pool maintenance.

Ground 3: Claims 1, 2, and 4 are obvious over Knoll

• Prior Art Relied Upon: Knoll (German Publication No. DE102007053310A1).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that Knoll, by itself, taught or suggested all limitations of claims 1, 2, and 4. Knoll disclosed an autonomous robotic pool cleaner with a drive means, a camera, and a control unit. Crucially, Knoll explicitly stated its control unit is preferably "located inside the robotic vehicle in a waterproof housing," satisfying the key "on or in the body" limitation. Knoll’s system used its camera to observe a boundary surface (e.g., a pool wall) and its control unit generated signals to maintain a defined distance from that surface as it traveled.
  • Motivation to Combine (N/A for single reference): Knoll’s control logic of maintaining a set distance inherently required moving the vehicle toward the boundary when too far and away from it when too close. Petitioner asserted this directly taught the claimed function of generating a control signal to cause movement "to, or away from, the first portion of the submerged surface."

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations based on Renaud (Application # 2014/0263087), but relied on similar arguments regarding the combination of known elements like onboard controllers and chemical dispensers.

4. Key Claim Construction Positions

• "means for moving the vehicle body" (Claims 1-5): Petitioner argued this is a means-plus-function term under 35 U.S.C. §112(f). The claimed function is "moving the vehicle body within the swimming pool." The corresponding structures disclosed in the ’766 patent were identified as wheels, rollers, tracks, or other surface-contacting members powered by a motor, as well as a vacuum or liquid jet propulsion system.

5. Key Technical Contentions (Beyond Claim Construction)

• Priority Date Challenge: A central contention of the petition was that the ’766 patent is not entitled to its claimed priority date of July 10, 2012, from the ’918 application. Petitioner argued the ’918 application failed the written description and enablement requirements for key limitations because it consistently and exclusively described a controller located outside the pool and remote from the vehicle body (e.g., in a "dry station"). It allegedly provided no disclosure for the claimed "controller positioned on or in the body." This argument, if successful, would establish an earlier effective date for several prior art references.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-5 of Patent 11,262,766 as unpatentable.