Beatbot Technology USA Co Ltd

1. Case Identification

• Case #: IPR2026-00202
• Patent #: 11,003,191
• Filed: January 26, 2026
• Petitioner(s): Beatbot Technology (USA) Co. Ltd.
• Patent Owner(s): Zodiac Pool Systems LLC
• Challenged Claims: 1-3

2. Patent Overview

• Title: Camera-Based Pool Cleaning System
• Brief Description: The ’191 patent relates to a self-propelled pool cleaner or system that uses camera-based image analysis to detect pool conditions. A controller analyzes the captured images and generates control signals to cause movement of the cleaner to or away from a submerged surface.

3. Grounds for Unpatentability

Ground 1: Claims 1-2 are obvious over Durvasula in view of Fu-007

• Prior Art Relied Upon: Durvasula (Application # 2014/0015959) and Fu-007 (Chinese Publication # CN101139007A).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Durvasula, a publication of the patent owner’s own application, discloses all elements of the claims except for a controller "positioned on or in the body" of the cleaner. Durvasula explicitly teaches an external controller located outside the pool. Fu-007, which discloses an underwater cleaning robot, remedies this deficiency by teaching a central processing unit (controller) housed within a sealed, waterproof enclosure inside the robot’s main shell.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Durvasula’s system with Fu-007’s onboard controller to improve the system’s autonomy and safety. Replacing Durvasula’s external, tethered controller with Fu-007’s onboard, battery-powered architecture would eliminate range limitations and cable entanglements. It would also remove the safety risks associated with running an electrical power and data cable into the pool, which creates a potential pathway for electrical leakage.
  • Expectation of Success: A POSITA would have a reasonable expectation of success because positioning a controller on the vehicle body was a well-known design choice for autonomous pool robots. Fu-007’s controller was already configured for similar image-based cleaning tasks, making its integration into Durvasula’s system predictable.

Ground 2: Claims 1-2 are obvious over Cui in view of Fu-007

• Prior Art Relied Upon: Cui (Chinese Publication # CN1540119A) and Fu-007 (Chinese Publication # CN101139007A).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that Cui discloses a self-propelled pool cleaner with a camera, filter, and track-based propulsion, meeting most claim limitations. However, like Durvasula, Cui’s industrial control computer is located externally and connected via a tether. The argument relies on the same teachings from Fu-007 to disclose an onboard controller positioned within the vehicle body.
  • Motivation to Combine: The motivation is analogous to Ground 1. A POSITA would substitute Cui’s external computer with Fu-007’s onboard controller to enhance autonomy by removing the physical tether. This modification would also improve safety by eliminating the external cable, which poses an electrical risk in a pool environment. The use of either an external or an onboard controller represented two known design options in the field.
  • Expectation of Success: Success would be expected because Fu-007’s onboard controller is already configured to execute image-based cleaning tasks similar to Cui’s, such as analyzing images and generating drive signals. A POSITA would reasonably expect that Fu-007’s controller could implement Cui’s specific control logic (e.g., adjusting crawling speed based on debris levels) to yield predictable results.

Ground 3: Claims 1-3 are obvious over Knoll

• Prior Art Relied Upon: Knoll (German Publication # DE102007053310A1).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that Knoll, standing alone, renders all challenged claims obvious. Knoll discloses an autonomous robotic pool cleaner with all the key features: a vehicle body, drive means (wheels), a suction/filter device, and an onboard camera. Critically, Knoll teaches a "control unit is preferably located inside the robotic vehicle in a waterproof housing," directly teaching the onboard controller limitation. The controller uses image data from the camera to calculate a trajectory and control the drive means to move the vehicle "away from or toward" a boundary surface to maintain a defined distance.
  • Motivation to Combine (N/A): This ground relies on a single reference.
  • Expectation of Success (N/A): This ground relies on a single reference.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including claims over Durvasula alone, Cui alone, and Renaud (Application # 2014/0263087) alone, which also allegedly disclose all claimed features.

4. Key Claim Construction Positions

• The petition argued that the term “means for moving the vehicle body” is a means-plus-function limitation under §112(f).
• The corresponding structure disclosed in the ’191 patent’s specification for performing the function of "moving the vehicle body" was identified as wheels, rollers, tracks, or other surface-contacting members powered by a motor, as well as a vacuum or liquid jet.

5. Key Technical Contentions (Beyond Claim Construction)

• A central contention of the petition was that the ’191 patent is not entitled to its claimed priority date of July 10, 2012, from the ’918 application.
• Petitioner argued that the ’918 application fails to provide written description support for key limitations added in later applications, specifically: (1) "a controller...positioned on or in the body" and (2) a control signal causing movement "away from...the submerged surface."
• The petition asserted that the ’918 application consistently and exclusively discloses a controller located outside the pool and remote from the vehicle, and only describes control signals that steer the vehicle to or towards areas needing cleaning.
• This argument, if successful, would establish a later priority date for the challenged claims, making references like Durvasula (the publication of the ’918 application itself), Cui, Knoll, and Renaud valid prior art under the AIA.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-3 of Patent 11,003,191 as unpatentable under 35 U.S.C. §103.