PTAB

PGR2026-00012

Xingmai Innovation Technology Suzhou Co Ltd v. Aiper Global Pte Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Controllable Sinking and Floating Swimming Pool Robot
  • Brief Description: The ’196 patent describes a pool-cleaning robot with a buoyancy control system that enables it to operate both underwater and at the surface. The system uses a "sinking and floating control unit" comprising airbags, pumps, and valves to switch between sinking and floating states.

3. Grounds for Unpatentability

Ground 1: Claims 1-7, 9-11, and 13-19 are obvious over Wang in view of Zhao and Owen.

  • Prior Art Relied Upon: Wang (Application # 2025/0146315), Zhao (Patent 11,803,193), and Owen (WO 2007/106730).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wang disclosed the core elements of a pool-cleaning robot with a processor-controlled, air-based buoyancy system (a "mode-switching member"), sensors for detecting waterline proximity and posture (gyroscope), and multi-state operation for bottom, wall, and surface cleaning. To the extent Wang’s wall-finding logic was insufficient, Zhao taught an advanced system using ultrasonic sensors to detect and navigate to the nearest pool wall. The key limitation added during prosecution—stopping the buoyancy control unit "for a predetermined time"—was not taught by Wang or Zhao but was explicitly disclosed by Owen, which taught a timer circuit to automatically shut off a pump inflating a bladder to prevent overinflation.
    • Motivation to Combine: A POSITA would combine Wang and Zhao to integrate Zhao’s superior, sensor-driven wall-finding and navigation logic into Wang’s capable multi-state cleaning robot, creating a more autonomous and efficient device. A POSITA would have been further motivated to incorporate Owen's well-known, timer-controlled shutoff into Wang’s buoyancy system to solve the predictable problem of overinflation once the robot surfaced, thereby increasing reliability and protecting components. Petitioner asserted Owen is analogous art as it addresses the same technical problem of controlling inflation in pneumatic systems.
    • Expectation of Success: The combination involved integrating known elements for their intended purposes (navigation sensors for navigation, motor timers for timed operation), which would yield predictable results.

Ground 2: Claims 1-6, 10, and 14-17 are obvious over Zhang in view of Zhao and Owen.

  • Prior Art Relied Upon: Zhang (Patent 11,946,282), Zhao (Patent 11,803,193), and Owen (WO 2007/106730).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Zhang, like Wang, disclosed a base pool-cleaning robot with a "mode-switching member" for buoyancy control, sensor feedback for navigation, and processor control to manage transitions between submerged and floating states. Zhang also taught processor-driven navigation to locate and climb pool walls based on user tasks. As in Ground 1, Zhao supplied the explicit teaching of using ultrasonic sensors to find the "closest pool wall," and Owen provided the timer-based pump shutoff to meet the "predetermined time" limitation.
    • Motivation to Combine: The motivation was analogous to Ground 1: a POSITA would enhance Zhang’s robot with Zhao’s precise distance-sensing navigation and incorporate Owen’s routine timer-based control to prevent overinflation of the buoyancy cavity. This combination would predictably result in a more robust, autonomous, and reliable cleaning robot.
    • Expectation of Success: Combining these complementary technologies—navigation, buoyancy control, and timed shutoff—was a straightforward engineering task with a high expectation of success.

Ground 3: Claims 1-14 are indefinite under 35 U.S.C. §112(b).

  • Prior Art Relied Upon: Not applicable. This is a §112 ground.

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the terms "main control unit" (claims 1-14) and "distance measure unit" (claim 4) are means-plus-function limitations under §112(f) because they use the generic nonce term "unit" and are defined solely by their function without reciting any definite structure.
    • Key Aspects: The petition asserted that the specification failed to disclose the corresponding structure—such as a specific algorithm or control logic—required to perform the claimed functions (e.g., finding and crawling a wall, stopping after a predetermined time, measuring distance). The specification merely stated that the "main control unit 10 is configured to control each component," which Petitioner argued was a mere recitation of function, not a disclosure of structure. This lack of corresponding structure allegedly rendered the claims indefinite.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 8 and 12 are obvious over the combination of Wang, Zhao, Owen, and Guo (Chinese Patent CN117738506), and that various claims are obvious over Guo in view of Zhao and Owen. These grounds relied on similar combination rationales, with Guo providing teachings of an internal gas-circulation system using an electromagnetic valve.

4. Key Claim Construction Positions

  • Petitioner argued that multiple claim terms should be construed as means-plus-function limitations under §112(f) because they are recited using generic, non-structural nonce terms (e.g., "unit," "subunit") and defined by their function.
  • Key terms identified for §112(f) treatment included: "sinking and floating control unit," "waterline detection unit," "posture detection unit," "main control unit," and "distance measure unit."
  • For each, Petitioner contended the specification lacked disclosure of the corresponding structure or algorithm necessary to perform the recited function, rendering the claims indefinite.

5. Key Technical Contentions (Beyond Claim Construction)

  • A central technical argument was that a pump operating at a constant flow rate (Q) for a given time (t) produces a predictable inflated volume (V ≈ Q × t). Therefore, Petitioner argued that a POSITA would understand that achieving a "gas volume threshold," as taught by Wang, inherently corresponds to running a pump for a "predetermined time."
  • This principle supported the motivation to combine Wang or Zhang with Owen, as Owen’s timer-based shutoff was presented as a direct, well-known, and reliable implementation for achieving such time-based inflation control to prevent over-pressurization.

6. Relief Requested

  • Petitioner requested institution of Post-Grant Review and cancellation of claims 1-19 of the ’196 patent as unpatentable.