PTAB

IPR2026-00201

Beatbot Technology USA Co Ltd v. Zodiac Pool Systems LLC

Key Events

Petition

Title: Camera-Based Control of Pool Equipment
Brief Description: The ’207 patent discloses a pool system that uses camera-based image analysis to detect conditions within a swimming pool and generate control signals for pool equipment. The system primarily focuses on using a camera to identify debris or cleanliness levels and controlling an autonomous cleaning vehicle in response.

Prior Art Relied Upon: Cui (Chinese Patent Application Publication No. CN1540119A).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Cui, an autonomous underwater pool cleaner, discloses all limitations of the challenged claims. Cui teaches a self-propelled cleaning vehicle with a body, track-type crawling mechanisms powered by motors ("means for moving"), a filter bag, a camera, and a computer controller. The controller receives images from the camera, compares them to pre-stored images of a clean pool bottom to detect debris levels (a "characteristic"), and generates control signals to adjust the cleaner's crawling speed in response. Petitioner asserted this control signal causes movement "to" the detected debris, satisfying that element of claim 1.
- Motivation to Combine (for §103 grounds): Not applicable as this ground relies on a single reference. Petitioner contended Cui alone renders the claims obvious.
- Expectation of Success (for §103 grounds): Not applicable.

Prior Art Relied Upon: Cui (Chinese Patent Application Publication No. CN1540119A) and Fu-007 (Chinese Patent Application Publication No. CN101139007A).
Core Argument for this Ground:
- Prior Art Mapping: This ground asserted that to the extent Cui does not teach every limitation of claims 8 and 16, Fu-007 supplies the missing elements. Specifically, Fu-007 teaches an underwater cleaning robot that uses a "cleanliness image threshold" to determine cleaning levels and operate drive wheels accordingly, directly teaching the threshold-based control recited in claim 8. Fu-007 also explicitly discloses a wireless communication capability via a buoyant antenna to communicate with a remote control keyboard, teaching the wireless communication of a control response required by claim 16.
- Motivation to Combine (for §103 grounds): A POSITA would combine these references because both relate to autonomous underwater pool cleaners and sought to improve cleaning operations. Petitioner argued that incorporating Fu-007’s threshold-based control and wireless communication into Cui’s system were known design alternatives that would advance Cui’s stated goals of "intelligent adaptive technology" and "high reliability."
- Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success as both systems employ similar camera-based controls, and the integration would involve predictable software and hardware modifications.

Prior Art Relied Upon: Knoll (German Patent Application Publication No. DE102007053310A1).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Knoll, which discloses an autonomous robotic pool cleaning vehicle, anticipates or renders obvious the challenged claims. Knoll teaches a robotic vehicle with a body, drive means (wheels), a suction/filter device, a camera, and a control unit. The control unit processes image data from the camera to determine the vehicle’s distance from pool boundary surfaces or obstacles. Based on this image-derived distance data, the control unit generates control signals to steer the vehicle, causing it to move "away from" or "toward" the boundary or to "drive around" an obstacle.
- Motivation to Combine (for §103 grounds): Not applicable as this ground relies on a single reference.
- Expectation of Success (for §103 grounds): Not applicable.
Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Cui and Hsu (Application # 2013/0024025); Knoll and Fu-007; Knoll, Fu-007, and Hsu; and a challenge over Laitta (Application # 2008/0048870). These grounds relied on similar theories of combining known features like remote graphical displays (Hsu), threshold-based control (Fu-007), and camera-based monitoring (Laitta).

Petitioner argued that the limitation "means for moving the vehicle body" in claim 1 is a means-plus-function limitation under pre-AIA 35 U.S.C. §112, ¶6.
Petitioner asserted the claimed function is "moving the vehicle body within the swimming pool," and the corresponding structures disclosed in the ’207 patent’s specification are "wheels, rollers, tracks, other surface contacting members powered by a motor, a vacuum, or a liquid jet." This construction was central to mapping prior art drive mechanisms (like Cui's tracks or Knoll's wheels) to the claim.

Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 5-8, 10, 12-17, and 19 of the ’207 patent as unpatentable under 35 U.S.C. §103.