'533 Ipr

UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE PATENT TRIAL AND APPEAL BOARD
Shenzhen Zhiyi Technology Co., Ltd.,

Petitioner
v.
iRobot Corporation,
Patent Owner.
Patent No. 8,600,553 to Svendsen et al.
IPR Case No. IPR2017-02133
PETITION FOR INTER PARTES REVIEW OF CLAIMS 1-2,

4, 8, 11-12, 21-22, AND 25 OF U.S. PATENT NO. 8,600,553
UNDER 35 U.S.C. 311-319 AND 37 C.F.R. 42.100 ET
SEQ.
Patent No. 8,600,553 Petition Requesting Inter Partes Review
TABLE OF CONTENTS
TABLE OF EXHIBITS ...........................................................................................iv

I. MANDATORY NOTICES UNDER 37 C.F.R. 42.8(a)(1) FOR
INTER PARTES REVIEW..............................................................................1
A. Real Party in Interest Under 37 C.F.R. 42.8(b)(1) ............................1
B. Related Matters Under 37 C.F.R. 42.8(b)(2) ....................................1
C. Lead and Backup Counsel Under 37 C.F.R. 42.8(b)(3) and
Service Information under 37 C.F.R. 42.8(b)(4)............................... 2
II. PAYMENT OF FEES UNDER 37 C.F.R. 42.15 ........................................3
III. CERTIFICATION OF WORD COUNT UNDER 37 C.F.R.
42.24(D) ..........................................................................................................3
IV. REQUIREMENTS FOR IPR UNDER 37 C.F.R. 42.104 ...........................3
A. Grounds for Standing Under 37 C.F.R. 42.104(a) ............................3
B. Identification of Challenge Under 37 C.F.R. 42.104(b) and
Relief Requested...................................................................................3
V. OVERVIEW ...................................................................................................5
A. Overview of the 553 Patent.................................................................5
B. Background of the 553 Patent .............................................................7
1. Priority Date ...............................................................................7
2. Prosecution of the 553 Patent ...................................................7
C. The Challenged Claims ......................................................................11
D. Person of Ordinary Skill in the Art (POSITA) ...............................11
E. Claim Construction ............................................................................12
F. Overview of the Prior Art...................................................................12
1. Overview of Suckmaster Article (Ex. 1004-Article) ............... 12
2. Overview of Suckmaster Source Code (Ex. 1005-Code) ........ 14
3. Overview of Jones-490 (Ex. 1009-Jones) ................................20
4. Overview of Park-707 (Ex. 1010-Park) ...................................22
VI. SPECIFIC GROUNDS FOR PETITION .....................................................23
ii
A. Ground 1: Anticipation Based on Suckmaster Article (including

incorporated and published Suckmaster Code) Ground 2:
Obviousness Based on Suckmaster Article and Suckmaster
Code ....................................................................................................23
1. The scope and content of the prior art .....................................23
2. Rationale for Combining Suckmaster Article and
Suckmaster Code......................................................................24
3. Challenged Claims for Grounds 1 and 2 ..................................25
B. Ground 3: Obviousness Based on Suckmaster Article (including
incorporated and published Suckmaster Code) and Jones-490.......... 50
2. Rationale for Combining Suckmaster Article (including
incorporated and published Suckmaster Code) and Jones-
490 ............................................................................................51
3. Challenged Claims for Ground 3 .............................................52
C. Ground 4 - Obviousness Based on Suckmaster Article
(including incorporated and published Suckmaster Code),
Jones-490, and Park-707 ....................................................................65
incorporated and published Suckmaster Code), Jones-
490, and Park-707 ....................................................................65
3. Challenged Claim for Ground 4...............................................66
VII. CONCLUSION.............................................................................................67
CERTIFICATE OF SERVICE ...............................................................................68
iii
TABLE OF EXHIBITS
Exhibit Description
1001 U.S. Patent No. 8,600,553 (553 patent)
1002 File History of U.S. Patent No. 8,600,533
1003 Expert Declaration of Dr. C. Douglass Locke, Ph.D.
Dales Homemade Robots - Suckmaster II Vacuum Robot

1004
(Suckmaster Article)
1005 Suckmaster2.c (Suckmaster Source Code)
1006 Declaration of Dale Heatherington
Archived Version of Suckmaster Article, achived on June 20,

2002, retrieved from
1007
https://web.archive.org/web/20020620103553/http://www.wa4dsy
.net/robot/suckmaster2/index.html
1008 **Intentionally Left Blank**
1009 U.S. Patent No. 6,809,490 to Jones et al. (Jones-490)
1010 U.S. PG Pub. No. 2005/0192707 to Park et al. (Park-707)
1011 Joint Claim Construction Statement, In re Certain Robotic

Vacuum Cleaning Devices And Components Thereof Such As
Spare Parts, Investigation No. 337-TA-1057
iv
Shenzhen Zhiyi Technology Co., Ltd. (Petitioner) hereby seeks inter
partes review of Claims 12, 4, 8, 1112, 2122, and 25 (the Challenged
Claims) of U.S. Patent No. 8,600,553 (Ex. 1001 (the 553 patent)). The
Challenged Claims of the 553 patent do not claim anything new; they claim
previously-known hardware and navigation control strategies as applied to an
autonomous robot, such as a vacuum cleaner. The Challenged Claims in the patent
should therefore be canceled for the reasons described in this Petition.
I. MANDATORY NOTICES UNDER 37 C.F.R. 42.8(a)(1) FOR INTER

PARTES REVIEW
A. Real Party in Interest Under 37 C.F.R. 42.8(b)(1)

The real parties-in-interest in this Petition are: Shenzhen Zhiyi Technology
Co. Ltd. d/b/a iLife.
B. Related Matters Under 37 C.F.R. 42.8(b)(2)

There is a pending proceeding before the U.S. International Trade
Commission that involves the Challenged Claims of the 553 patent: In re Certain
Robotic Vacuum Cleaning Devices And Components Thereof Such As Spare Parts,
Investigation No. 337-TA-1057 (the ITC Investigation).
There is also a federal district court litigation filed by iRobot Corporation
against Petitioner that also involves the Challenged Claims of the 553 patent:
iRobot Corp. v. Shenzhen Zhiyi Technology Co. Ltd. d/b/a iLife, Case No. 1:17-cv-
10652 (D. Mass.) (the District Court Case).
1
C. Lead and Backup Counsel Under 37 C.F.R. 42.8(b)(3) and

Service Information under 37 C.F.R. 42.8(b)(4)
Petitioner designates the following lead and backup counsel:
Lead Patrick J. McCarthy

Counsel: Registration No. 62,762
mccarthyp@gtlaw.com
Greenberg Traurig LLP

2101 L Street, N.W., Suite 1000
Washington, D.C. 20037
Phone: (202) 533-2386

Fax: (202) 331-3101
Backup Cameron M. Nelson
Counsel: Registration No. 55,486
nelsonc@gtlaw.com

77 W. Wacker Dr.
Suite 3100
Chicago, IL 60601
Phone: 312-456-8400
Fax: 312-456-8435
Service on Petitioner may be made by mail or hand delivery to: Greenberg
Traurig, LLP, 2101 L Street N.W., Suite 1000, Washington, D.C. 20037.
Petitioner also consents to electronic service by emailing counsel of record at
mccarthyp@gtlaw.com, nelsonc@gtlaw.com, and
ShenzhenZhiyiITCAll@gtlaw.com.
2
II. PAYMENT OF FEES UNDER 37 C.F.R. 42.15

Petitioner authorizes the U.S. Patent & Trademark Office to charge Deposit
Account No. 50-2638 for the fee set in 37 C.F.R. 42.15(a) for this Petition and
further authorizes any additional fees to be charged to this Deposit Account.
III. CERTIFICATION OF WORD COUNT UNDER 37 C.F.R. 42.24(D)

Petitioner certifies that the word count in this Petition is 11,689 words, as
counted by the word-processing program (Microsoft Word 2010) used to generate
this Petition, where such word count excludes the table of contents, table of
authorities, mandatory notices, certificate of service, appendix of exhibits, and this
certificate of word count. This Petition is in compliance with the 14,000 word
limit set in 37 C.F.R. 42.24(a)(1)(i).
IV. REQUIREMENTS FOR IPR UNDER 37 C.F.R. 42.104
A. Grounds for Standing Under 37 C.F.R. 42.104(a)

Petitioner certifies that the 553 patent is available for inter partes review,
and that Petitioner is not barred or estopped from requesting an inter partes review
on the grounds identified in the Petition.
B. Identification of Challenge Under 37 C.F.R. 42.104(b) and Relief

Requested
Petitioner respectfully requests that the following Challenged Claims of the
553 patent (Ex. 1001) be cancelled based on the following grounds of
unpatentability:
3
Ground of
553 Patent Claim(s) Basis for Rejection
Unpatentability
Anticipation based on Suckmaster

Ground 1 1, 2, 8, 11, 12, 25
Publication and incorporated
published Source Code
Obviousness Based on Suckmaster

Ground 2 1, 2, 8, 11, 12, 25
Publication and incorporated
published Source Code
Obviousness based on Suckmaster

Ground 3 2, 4, 12, 21, 22
Publication, incorporated published
Source Code, and Jones-490
Obviousness based on Suckmaster

Ground 4 22 Publication, incorporated published
Source Code, Jones-490, and Park-
707
4
V. OVERVIEW
A. Overview of the 553 Patent
The 553 patent relates to movement of an autonomous robot. (Ex. 1001 at
Abstract, 1:17.) The 553 patent describes control mechanisms for an autonomous
robot vacuums navigation speed and direction in the presence of obstacles. (Id. at
34-38.) The 553 patent discloses certain hardware elements contributing to the
autonomous movement of the robot, including a drive system 104 receiving
commands from a controller 108 to drive wheels 112 and 114. (Id. at FIGS. 2, 3;
6:28-61.)
The hardware disclosed in the 553 patent further includes sensors, including
infrared proximity sensors 134 that may sense a potential obstacle in front of the
robot and kinetic bump sensors 132 that may be responsive to a collision. (Id.
at Abstract; FIGS. 8B, 10; 8:35-45.)
In operation, the 553 patent explains that the robot autonomously traverses
an area at a full clean speed, but [u]pon sensing a proximity of [an] object
forward of the robot, the robot reduces the cleaning speed to a reduced cleaning
speed while continuing towards the object. (Id. at Abstract (emphasis added).)
The 553 patent states that this slowing down makes collisions less noisy, and less
likely to mar surfaces. (Id. at 9:1-4.) Once a collision is sensed by the kinetic
bump sensor, the robot autonomously turns. (Id. at 7:6-11.) As shown in the
5
highlighted 553 flow chart below, the robot will continue at a reduced speed for a
preset time or distance and then ramp back up to full cleaning speed if no collision
is detected by the kinetic bump sensor. (Id. at FIG. 9B.)
6
The 553 patent bases its direction and speed control scheme on the motion
control behavior of two patents: U.S. Pat. Nos. 6,809,490 and 6,781,338. (Id. at
8:49-53.) U.S. Pat. No. 6,809,490 has the same assignee as the 553 patent and is
cited in this Petition.
B. Background of the 553 Patent
1. Priority Date
The 553 patent issued from an application filed on June 5, 2007, and is a
continuation of the application that matured into U.S. Patent No. 7,441,298. (Ex.
1001, Cover Page.) The 553 patent further claims priority to provisional
application no. 60/741,442, which was filed on December 2, 2005. (Id.) Thus, the
earliest possible priority date for the Challenged Claims is December 2, 2005. For
purposes of this Petition only, Petitioner assumes that the Challenged Claims are
entitled to the benefit of the provisional filing date.
2. Prosecution of the 553 Patent
The 553 patent issued from U.S. application ser. no. 11/758,289 (the 289
application), filed on June 5, 2007. (Ex. 1002 at 172.) At filing, the 289
application included 23 claims, including independent claims 1 and 10.
Independent claim 1, as-filed, is reproduced below:
1. An autonomous coverage robot comprising:
a drive system configured to maneuver the robot according to a

heading setting and a speed setting;
7
a bump sensor responsive to a collision of the robot with an

obstacle in a forward direction; and
a proximity sensor responsive to a potential obstacle forward of the

robot;
wherein the drive system is configured to reduce the speed setting

in response to a signal from the proximity sensor indicating
detection of a potential obstacle, while continuing to advance
the robot according to the heading setting; and
wherein the drive system is configured to alter the heading setting

in response to a signal received from the bump sensor
indicating contact with an obstacle.
(Id. at 37.)
Claim 10 was a method claim that followed claim 1 closely. (Id. at 38.)
On March 11, 2010, the USPTO issued a first Office Action that rejected
claims 1-7 and 10-20 as anticipated by U.S. Patent No. 6,809,490 to Jones et al.
(Jones-490), rejected claims 8-9 and 23 as obvious based on Jones-490 in view
of WO 01/06904, and rejected claims 21-22 as obvious over Jones-490 in view of
U.S. PG Pub. No. 2005/0192707 to Park et al. (Park-707). (Id. at 146154.)
In response, the Applicant did not amend any claims, but did add new claim
24, reproduced below:
24. (New) The robot of claim 1 wherein the drive system is

configured to increase the speed setting if the drive system does not
8
receive a signal from the bump sensor within an elapsed time after the
speed setting is reduced.
(Id. at 193.)
With respect to claim 1, the Applicant argued that Jones[-490] does not
describe slowing down the robot in response to a proximity sensor responsive to a
potential obstacle forward of the robot. (Id. at 194.) As a result, according to the
Applicant, Jones[-490] did not describe ... a drive system configured to reduce
the speed setting in response to a signal from the proximity sensor..., as recited in
claim 1, or upon sensing a proximity of [an] object forward of the robot, the
robot reducing the cleaning speed to a reduced speed while continuing towards the
object until the robot detects contact with the object, as recited in claim 10. (Ex.
1002 at 19495.)
In a second Office Action, dated November 10, 2010, the Examiner
indicated that claim 24 included patentable subject matter (Id. at 250, 7), but
rejected all original claims. Specifically, the Examiner rejected claims 1-7 and 10-
17 as obvious over Jones-490 in view of US 2005/0165508 to Kanda et al.
(Kanda), rejected claims 18-20 as obvious over Jones-490 in view of Kanda and
U.S. Pat. No. 5,502,638 to Takenaka, rejected claims 8-9 and 23 as obvious over
Jones-490 in view of Kanda and WO 01/06904, and rejected claims 21 and 22 as
obvious over Jones-490 in view of Kanda and Park-707. (Id. at 243252.)
9
In response, the Applicant: (1) added new claim 25, which included all
recitations of allowable claim 24, including its base claim; and (2) amended claims
1 and 10 to include the crux of allowable claim 24 (i.e., to increase the speed
setting if the drive system does not receive a signal from the bump sensor). For
example, claim 1 was amended as follows:
1. An autonomous coverage robot comprising:
a drive system configured to maneuver the robot according to a

heading setting and a speed setting;
a bump sensor responsive to a collision of the robot with an

obstacle in a forward direction; and
a proximity sensor responsive to a potential obstacle forward of the

robot;
wherein the drive system is configured to reduce the speed setting

in response to a signal from the proximity sensor indicating
detection of a potential obstacle, while continuing to advance
the robot according to the heading setting; [[and]]
wherein the drive system is configured to increase the speed setting

if the drive system does not receive a subsequent signal
indicating the presence of an obstacle while continuing to
advance according to the heading setting and the reduced speed
setting; and
10
wherein the drive system is configured to alter the heading setting

in response to a signal received from the bump sensor
indicating contact with an obstacle.
(Id. at 279 (underlining in original).)
In other words, to overcome the prior art, the claims were amended to
require that when in the reduced speed operation, the robot increases the speed
setting if the drive system does not receive a signal from the bump sensor. After
the amendment, the Examiner issued a Notice of Allowance. (Id. at 297-98.)
Claim 10 was renumbered as issued claim 11. (Id. at 303.) The Notice of
Allowance did not contain a statement of reasons for allowance.
C. The Challenged Claims

Claims 1, 11, and 25 are the only independent claims of the 553 patent,
each of them is challenged in this Petition. Claims 1-2, 4, 8, 11-12, 21-22, and 25
constitute the Challenged Claims.
D. Person of Ordinary Skill in the Art (POSITA)

A POSITA in the field of the 553 patent at the time of the earliest possible
priority date would have had at least an undergraduate degree in computer science
or electrical engineering, or equivalent experience and, in addition, two years of
experience in the design and implementation of embedded computer devices
managing sensors and controlling motors. (Ex. 1003, Expert Declaration of Dr. C.
Douglass Locke, Ph.D. (hereinafter Ex. 1003-Locke) at 11-17.)
11
E. Claim Construction
Pursuant to 37 C.F.R. 42.100(b), the claims in inter partes review are
given the broadest reasonable construction in light of the specification. For
purposes of this proceeding, Petitioner requests that all terms of the Challenged
Claims be given their plain meaning, except nor-linear (a term in claim 21),
which Petitioner requests be interpreted as non-linear based on a typographical
error. The parties to the ITC investigation have agreed that nor-linear means
non-linear. Attached hereto as Exhibit 1011 is the parties joint claim
construction chart from the ITC investigation. Petitioner is not aware of any
dispute in the ITC investigation or other litigation that meaningfully affects the
analysis in this petition which is provided under the broadest reasonable
interpretation of the claims.
F. Overview of the Prior Art
1. Overview of Suckmaster Article (Ex. 1004-Article)
Dales Homemade Robots Suckmaster II Vacuum Robot (Ex. 1004;
hereinafter Suckmaster Article in text, Ex. 1004-Article in citations) is an
article authored by Dale Heatherington that was available at
http://www.wa4dsy.net/robot/suckmaster2/index.html, a web page that was
available to the public without any password, fee, or other restriction, as early as
February 2002. (Ex. 1006, Declaration of Dale Heatherington (hereinafter Ex.
1006-Heatherington in citations) at pp. 1-3.) This web page was archived by
12
www.archive.org no later than June 20, 2002, demonstrating both that the
Suckmaster Article predates the 553 priority date by more than a year and that the
website was indexed by search engines. (Id. at pp. 1-3; Ex. 1007, Archived
Version of Suckmaster Article, archived on June 20, 2002.) The Suckmaster
Article is prior art to the 553 patent under 35 U.S.C. 102(b).
The Suckmaster Article discloses a vacuum robot designed to compete in
the annual AHRC Robot Rally Vacuum contest, pictured below:
(Ex. 1004-Article at 1.) The robot includes sonar and a sonar CPU, two front
bump switches, two ground speed sensors, and an IR transmitter and two IR
receivers for beacon tracking. (Id. at 2.) The sonar is used to detect the presence
of objects, and the bump switches are used to detect collisions. (Id. at 4.)
13
The Suckmaster Article further discloses a main CPU and speed control
software. (Id. at 2.) Under control of the CPU and speed control software, the
robot is disclosed as slowing down when proximity sensors detect nearby objects
in the robots path. (Id. at 4.) Crucially, unlike what the Examiner found with
respect to the prior art of record during prosecution, the Suckmaster Article also
discloses speeding up when such objects are no longer detected. (Id. at 4.) Also
disclosed is turning the robot when its bump sensor(s) signal a collision. (Id. at 4.)
The Suckmaster Article was not cited during the prosecution of the 553
patent and is not listed in the References Cited section of the 553 patent.
The web page of the Suckmaster Article incorporated the source code for the
described Suckmaster robot and further detailed the processor functionality of the
Suckmaster. A user reading the online posting was directed to an embedded link
that uploaded the source code to the user. (Ex. 1006-Heatherington at pp. 1-3.)
This source code is described next.
2. Overview of Suckmaster Source Code (Ex. 1005-Code)

suckmaster2.c (Ex. 1005; hereinafter Suckmaster Code in text, Ex.
1005-Code in citations) is source code for the robot described in the Suckmaster
Article and that was linked from the Suckmaster Article web page as early as
February 2002. (Ex. 1006-Heatherington at pp. 1-3.) The Suckmaster Code was
archived by www.archive.org as early as February 16, 2002 and was available to
14
the public without any password, fee, or other restriction. (Id.) The Suckmaster
Code is prior art to the 553 patent under 35 U.S.C. 102(b).
The Suckmaster Code discloses several operational modes, including a
perimeter mode and a random mode. (Ex. 1005-Code at lines 1851-1906
(vacuum_perimeter and vacuum_random called in main program loop), lines 1513-
1526 (vacuum_perimeter function), lines 1545-1660 (vacuum_random function).)
In the perimeter mode, the robot hugs the left wall:
(Ex. 1005-Code at lines 1513-1526; Ex. 1003-Locke at 34.)
In the random mode, the robot detects the proximity of objects and,
depending on the proximity of those objects, proceeds straight ahead at one of
three speeds, FWD5, FWD3, or FWD2:
15
Random mode is random because the robot randomly turns left or right
every twenty seconds in that mode:
16
The Suckmaster Code further includes an avoid_object routine, which
instructs the robot how to behave when the bump switch indicates contact with an
obstacle. Four behaviors are disclosed, discussed in turn below. Each of those
behaviors initiates one or more maneuvers. In the Suckmaster Code, each
maneuver is initiated by a call to the start_maneuver routine, which sets
variables that are used in the maneuver routine that executes the maneuvers. The
start_maneuver routine sets a maneuver timer m_timer (for timing the length of a
maneuver), a yaw limit yaw_limit (an upper limit on how much the robot can turn
in a maneuver), a forward clearance limit ahead_limit (for knowing the distance to
the next sensed object), and other variables:
17
The respective speeds of the two wheels of the robot are commanded
separately in the Suckmaster Code. Several different sets of speed commands
(where a set includes a right wheel speed and a left wheel speed) may exist
simultaneously within the execution of the Suckmaster Code. One speed-related
routine is the arbitrate routine, which decides which of these speeds to apply at any
given time. (Ex. 1005-Code at lines 1670-1704; Ex. 1003-Locke at 38-39.)
There are three bump sensor response behaviors. First, if the robot hits the
obstacle on its left side, an A_WALL_LEFT maneuver is initiated, during which
the right wheel is reversed to change directions. (Ex. 1005-Code at lines 1220-
1224; Ex. 1003-Locke at 40.)
Second, if the robot hits the obstacle on its right side, an A_WALL_RIGHT
behavior is initiated such that the left wheel reverses. (Ex. 1005-Code at lines
1226-1229; Ex. 1003-Locke at 40.)
Third, if the robot is in perimeter mode and the bump sensor detects contact
with an obstacle, an A_BACKAWAY maneuver is initiated. (Ex. 1005-Code at
lines 1453-1460; Ex. 1003-Locke at 40.)
In the A_BACKAWAY maneuver, while in perimeter mode, the robot backs
up for a short time, and then an A_SPIN_RIGHT maneuver is initiated if the
robots right side sonar does not indicate contact with an obstacle on the right side,
18
or an A_SPIN_LEFT maneuver if it does. (Ex. 1005-Code at lines 1128-1142; Ex.
1003-Locke at 40.)
In the A_SPIN_RIGHT maneuver, the robot drives its left wheel forward
and its right wheel in reverse until the right side of the robot contacts an obstacle or
until the timer expires. (Ex. 1005-Code at lines 1176-1193; Ex. 1003-Locke at
40.) Although the A_SPIN_RIGHT maneuver will also stop if a yaw limit is
reached, the A_BACKAWAY maneuver that initiates the A_SPIN_RIGHT
maneuver is itself initiated with a yaw limit of zero, and thus the portion of
A_SPIN_RIGHT highlighted below will not execute when initiated responsive to a
bump switch in perimeter mode:
(Ex. 1005-Code at lines 1176-1193 (emphasis added); Ex. 1003-Locke at 40.)
The A_SPIN_LEFT maneuver mirrors A_SPIN_RIGHT. (Ex. 1005-Code at
lines 1201-1216; Ex. 1003-Locke at 40.)
19
In addition to the above scenarios, A_BACKAWAY is also the default
behavior of the robot. In a default call, the A_BACKAWAY maneuver is initiated
for 900 milliseconds, with a yaw_limit of 5 (which the code notes is 30 degrees)
and an ahead_limit of 12 (which the code notes is 12 inches):
3. Overview of Jones-490 (Ex. 1009-Jones)
U.S. Patent No. 6,809,490 to Jones et. al (Ex. 1009; hereinafter Jones-490
in text and Ex. 1009-Jones in citations) issued on October 26, 2004 from an
application filed on June 12, 2002. Jones-490 claims priority to a provisional
application filed on June 12, 2001. Jones-490 is therefore prior art to the 553
patent under at least 35 U.S.C. 102(a), (b), and (e). The applicant did not dispute
that Jones-490 is prior art during prosecution.
Jones-490, entitled Method and System for Multi-Mode Coverage for an
Autonomous Robot, discloses hardware and control strategies for an autonomous
robot to navigate in the presence of obstacles. (Ex. 1009-Jones at Cover, Abstract.)
20
A preferred embodiment of Jones-490 is a robotic sweeper. (Ex. 1009-Jones
at 5:39-41.)
Jones-490 discloses several operational modes (also referred to as
coverage behaviors) for an autonomous robot, including spot coverage,
wall/obstacle following, and room coverage. (Ex. 1009-Jones at 9:6-13:25.)
Each of these operational modes incorporates one or more behaviors, including
Spiral, Bounce, Straight Line, and Align. (Ex. 1009-Jones at FIGS. 6A-
6C (spiral) 10 (bounce); 9:19-10:21 (spiral), 10:4-8 (straight line), 12:30-52
(align), 12:62-13:22 (bounce).) Each operational mode also includes various
escape behaviors, including turn, edge, wheel drop, and slow. (Ex.
1009-Jones at 13:26-15:24.)
Jones-490 discloses various sensors, including bump sensors, cliff sensors,
and a wall-following sensor. (Ex. 1004-Jones at 5:41-58.) Jones-490 specifically
identifies the cliff sensors and the wall-following sensor as proximity sensors.
(Ex. 1009-Jones at 5:52-55.) Jones-490 further discloses that output of the sensors
triggers transitions within behaviors (e.g., changes in direction or speed) and
transitions between behaviors within an operational mode. (Ex. 1009-Jones at,
e.g., 10:58-11:19 (role of wall-following proximity sensor in wall-following
mode), 12:30-32 (In certain embodiments, when the WALL-FOLLOWING
21
behavior is active and there is a bump, the ALIGN behavior becomes active.),
15:48-52 (role of cliff detector proximity sensor in slow escape behavior).)
The 553 patent specifically references Jones-490 as disclosing [c]ontrol of
the direction and speed of the robot ... by motion control behaviors selected by an
arbiter according to the principles of behavior based robotics for coverage and
confinement. (Ex. 1001 at 8:49-56.)
4. Overview of Park-707 (Ex. 1010-Park)

U.S. Patent App. Pub. No. 2005/0192707 to Park et al. (Ex. 1010;
hereinafter Park-707 in text and Ex. 1010-Park in citations) published on
September 1, 2005 from an application filed on January 6, 2005. Park-707 claims
priority to a Korean patent application filed on February 27, 2004. Park-707 is
therefore prior art to the 553 patent under at least 35 U.S.C. 102(a) and (e).
Park-707, entitled Dust detection method and apparatus for cleaning robot,
discloses various features of a cleaning robot, including a specific cleaning speed
and a specific reduced speed of such a robot.
Park-707 was cited by the Examiner during the prosecution of the 553
patent for teaching, e.g., a cleaning speed of 300 mm/sec. (Ex. 1002 at 250.) The
Applicant did not contest the Examiners assertion.
22
VI. SPECIFIC GROUNDS FOR PETITION
A. Ground 1: Anticipation Based on Suckmaster Article (including

incorporated and published Suckmaster Code)
Ground 2: Obviousness Based on Suckmaster Article and
Suckmaster Code
1. The scope and content of the prior art

The Suckmaster Article and the Suckmaster Code are a single prior art
reference that anticipates the 553 patent (Ground 1). The Suckmaster Code and
Suckmaster Article are a single reference for anticipation purposes for two reasons.
First, the Suckmaster Article and Suckmaster Code are akin to two chapters from
the same book; they were posted on the same website, concern the same subject
matter, and a user would naturally flip from one to the other to understand the
full subject matter of the Suckmaster robot.
Second, the Suckmaster Code is incorporated by reference into the
Suckmaster Article:
If you want to see the schematics and source code click here to
download a zip file.
(Suckmaster Article at 1.) In the quote above, click here was hyperlinked
to the Suckmaster Code. (Id.; Ex. 1006-Heatherington at pp. 1-3.)
A POSITA would understand the Suckmaster Article to incorporate the
Suckmaster Code by reference, as a code-level implementation of the behavior
described in the Suckmaster Article. When one reference is incorporated by
reference into another, the two references are treated as a single reference for
23
anticipation purposes. See Husky Injection Molding v. Athena Automation Ltd.,
838 F. 3d 1236, 1248 (Fed. Cir. 2016) (The incorporation standard relies only on
the reasonably skilled artisan and his or her ability to deduce from language,
however imprecise, what a host document aims to incorporate.); see also
Callaway Golf Co. v. Acushnet Co., 576 F.3d 1331, 1334 (Fed. Cir. 2009).
If, however, the Board determines that the Suckmaster Article and the
Suckmaster Code are not a single reference for anticipation purposes, Petitioner
also presents the Suckmaster Article and the Suckmaster Code as an obviousness
combination (Ground 2).
Because Ground 1 and Ground 2 consist of the same substantive citations
from the Suckmaster Article and the Suckmaster Code, Petitioner presents both
grounds in this Section VI(A). Sub-section VI(A)(2) only applies to Ground 2.
2. Rationale for Combining Suckmaster Article and

Suckmaster Code
To the extent the Suckmaster Article and Suckmaster Code are found by the
Board to not be a single reference, it would have been obvious to combine them. It
is clear from the Suckmaster Article and the Suckmaster Code that the Suckmaster
Code was written specifically to run on the robot that is the subject of the
Suckmaster Article. The Suckmaster Article specifically references the
Suckmaster Code as the source code for the robot described in the Suckmaster
Article. (Ex. 1004-Article at 1.) Furthermore, the Suckmaster Code specifically
24
notes that it is the control program for the Suckmaster II vacuum robot, i.e., the
robot described in the Suckmaster Article. (Ex. 1004-Article at 1; Ex. 1005-Code
at lines 1-9.) Accordingly, a POSITA would have a reasonable expectation of
success in combining the Suckmaster Code to control the robot described in the
Suckmaster Article, and would be motivated to make that combination. (Ex. 1003-
Locke at 46-47.)
3. Challenged Claims for Grounds 1 and 2

Claims 1, 2, 8, 11, 12, and 25 are anticipated by Suckmaster (Ground 1). To
the extent that the Suckmaster Article and the Suckmaster Code are not considered
a single reference, claims 1, 2, 8, 11, 12, and 25 would have been obvious to a
POSITA based on the combination of the Suckmaster Article and the Suckmaster
Code (Ground 2).
CLAIM 1-PREAMBLE] An autonomous coverage robot comprising:

The Suckmaster Article and the Suckmaster Code both disclose the
preamble of claim 1, whether or not it is considered limiting.
The Suckmaster Article discloses the Suckmaster II Vacuum Robot:
Suckmaster II Vacuum Robot ... This robot was designed to compete

in the annual AHRC Robot Rally Vacuum contest. The contest goal is
to pick up as much rice as possible in 4 minutes or less from an 8 foot
square simulated room.
(Ex. 1004-Article at 1.)
25
The Suckmaster Code discloses the Suckmaster II vacuum robot control
program:
(Ex. 1005-Code at lines 1-9 (emphasis added); Ex. 1003-Locke at 30-31.)
Thus, both the Suckmaster Article and the Suckmaster Code disclose this
limitation.
[1a] a drive system configured to maneuver the robot according to a heading

setting and a speed setting;
Both the Suckmaster Article and the Suckmaster Code disclose this
limitation.
The Suckmaster Article discloses a Main CPU, a Sonar CPU, two gear
motors, a motor driver chip, and speed control in the form of [s]oftware generated
Pulse Rate Modulaton with BackEMF feedback. (Ex. 1004-Article at 2.) Each of
these components is a part of the drive system of the claim. The Suckmaster
Article further discloses control strategies employed by the drive system, which
include heading settings and speed settings:
To avoid crashing into objects at high speed, six channel sonar is used
to detect the presence of objects and slow down when near. High
26
speed operation is resumed when the front sonars see no objects

closer than 20 inches.
When the robot touches something (bump switch detection) it will turn
in the direction with the greatest free space as indicated by the side
looking sonar. It will continue to turn until the forward sonar sees a
clear path. Sometimes a random additional rotation is added to help
randomize the cleaning pattern.
(Ex. 1004-Article at 4 (emphasis added).)
The Suckmaster Code further describes various control modes for executing
the above described operation, each of which includes a speed setting and a
heading setting. Specifically, the Suckmaster Code describes control modes
including vacuum_perimeter, vacuum_random, avoid_object, maneuver, and
others. (Ex. 1005-Code at lines 1851-1906.)
In vacuum_random, three different speed settings (FWD5, FWD3, or
FWD2) may be used, each of which includes setting both wheels to the same speed
(via the vacuumRandomOutput_L and vacuumRandomOutput_R variables),
thereby setting a heading setting of straight at the selected speed:
27
A preferred embodiment of the 553 patent utilizes a heading setting by
independently driving each of the robots two wheels such that a command may
be issued by controller 108 to engage both wheel assemblies in a forward direction,
resulting in forward motion of robot 100. In another instance, a command may be
issued for a left turn that causes left wheel assembly 112 to be engaged in the
forward direction while right wheel assembly 114 is driven in the rear direction,
resulting in robot 100 making a clockwise turn when viewed from above. (Ex.
1001 at 6:54-61.) The Suckmaster Code discloses exactly this.
For example, as explained immediately above, in vacuum_random, the
wheels can be set to the same speed to drive the robot with a straight headingjust
as in the preferred embodiment of the 553 patent. Likewise, as explained in
Section V(F)(2) above, the Suckmaster Code discloses random left and right turns
(Ex. 1005-Code at lines 1552-1582), as well as bumper-initiated A_SPIN_RIGHT
28
(Ex. 1005-Code at lines 1453-1460) and A_SPIN_LEFT (Ex. 1005-Code at lines
1453-1460) maneuvers that cause the robot do a clockwise or counter-clockwise
turn (i.e., heading change) respectivelyagain consistent with the heading setting
in the preferred embodiment of the 553 patent. (Ex. 1003-Locke at 35-40.)
The Suckmaster Code even includes a yaw value that is used to consistently track
the heading of the autonomous robot with reference to its initial drive angle. (Ex.
1005-Code at lines 666-750.)
limitation.
[1b] a bump sensor responsive to a collision of the robot with an obstacle in a

forward direction; and
The Suckmaster Article discloses this limitation. Specifically, the
Suckmaster Article discloses two front bump switches. (Ex. 1004-Article at 1.)
The bump switches are used to detect the robot touching something in its path, i.e.,
a collision of the robot with an obstacle:
looking sonar. . . . If the sonar fails to detect a small object such as the
leg of the folding chair the bump switch will command the robot to
backup and turn away.
Thus, the Suckmaster Article discloses this limitation.
29
[1c] a proximity sensor responsive to a potential obstacle forward of the

robot;
The Suckmaster Article and the Suckmaster Code both disclose this
limitation. Specifically, the Suckmaster Article discloses multi-channel sonar
responsive to potential obstacles:
speed operation is resumed when the front sonars see no objects closer
than 20 inches.
In this regard, the Suckmaster Code describes a path_clear function that
tracks the sonar proximity sensor values to determine the distance to objects in the
robots direction of travel. (Ex. 1005-Code at lines 900-912; Ex. 1003-Locke at
77.)
Thus, the Suckmaster Article and Suckmaster Code disclose this limitation.
[1d] wherein the drive system is configured to reduce the speed setting in
response to a signal from the proximity sensor indicating detection of a
potential obstacle, while continuing to advance the robot according to the
heading setting;
limitation.
The Suckmaster Article discloses slowing down the robot when the sonar
detects a nearby object. Notably, the 553 patent describes slowing down such
30
that when a collision does occur, the collision is less noisy, and less likely to mar
surfaces. (Ex. 1001 at 9:2-4). The Suckmaster slows down upon sensing
approached objects for the same reasonto avoid crashing into objects at high
speed:
than 20 inches.
The Suckmaster Code confirms that the speed should be reduced without
altering the heading setting. (Ex. 1003-Locke at 80.) Specifically, in the
vacuum_random routine, the robot slows down if an object is within twenty inches
(by setting vacuumRandomOutput_L and vacuum_RandomOutput_R to FWD3),
and will slow down more if an object is within twelve inches (by setting
vacuumRandomOutput_L and vacuum_RandomOutput_R to FWD2):
31
(Ex. 1005-Code at lines 1545-1591 (emphasis added); see Ex. 1003-Locke at 80.)
Thus, by transitioning from FWD5 speed to FWD3 or FWD2 speed, or from
FWD3 speed to FWD2 speed, the robot reduce[s] the speed setting in response to
a signal from the proximity sensor indicating detection of a potential obstacle, as
claimed. Furthermore, because the two wheels of the robot are set at the same
speed as each other, the robot will continue on its straight heading, and thus the
Suckmaster Code discloses reducing the speed setting while continuing to
advance the robot according to the heading setting, as claimed. (Ex. 1003-Locke
at 80.)
As noted above, the Suckmaster Code discloses this claim limitation within
the random mode. Separately and additionally, the Suckmaster Code discloses
reducing speed while continuing towards an obstacle during an initial period after
cleaning begins, by initiating an A_AHEAD_SLOW routine when an obstacle is
detected within thirteen inches or an A_AHEAD_VERYSLOW routine when an
obstacle is detected within seven inches.:
32
The A_AHEAD_SLOW routine sets the robot speed to FWD3, and the
A_AHEAD_VERYSLOW routine sets the robot speed to FWD2:
(Ex. 1005-Code at lines 1233-1243 (emphasis added).) Thus, during an initial
period, if the robot is traveling at its normal cleaning speed (FWD5) and an
approached object is sensed within thirteen inches, A_AHEAD_SLOW will reduce
the speed setting to (FWD3) and any sensed object within seven inches will further
reduce the speed to (FWD2) via A_AHEAD_VERYSLOW. (Ex. 1003-Locke at
81.) In both routines, the heading setting remains unchanged. (Ex. 1003-Locke at
81.)
limitation.
[1e] wherein the drive system is configured to increase the speed setting if the
drive system does not receive a subsequent signal indicating the presence of an
obstacle while continuing to advance according to the heading setting and the
reduced speed setting; and
limitation. First, the Suckmaster Article states that the robot will slow down when
33
an object is near (as described above) and resume high speed operation (without a
heading change) if no object is sensed within twenty inches:
speed operation is resumed when the front sonars see no objects
closer than 20 inches.
As noted above with respect to claim limitation [1d], the Suckmaster Code
discloses that the robot slows down if an object is within twenty inches, and will
slow down more if an object is within twelve inches. If, on a subsequent iteration
of the vacuum_random routine, the robot does not sense an obstacle within twenty
inches (for example, if the sensed object is picked up or moves), the Suckmaster
Code teaches setting the reduced speed (either FWD3 or FWD2 depending on the
proximity of the sensed object) back to the normal cleaning speed, FWD5 (i.e.,
full speed ahead):
(Ex. 1005-Code at lines 1552-1559; Ex. 1003-Locke at 84.) This transition from
FWD2 or FWD3 speed to FWD5 speed is increas[ing] the speed setting if the
34
drive system does not receive a subsequent signal indicating the presence of an
obstacle while continuing to advance according to the heading setting and the
reduced speed setting, as claimed. Similarly, a transition from FWD2 speed to
FWD3 speed (because an obstacle was previously within twelve inches, but is now
between twelve and twenty inches) satisfies this claim limitation.
Furthermore, as noted above, the Suckmaster Code discloses initiating an
A_AHEAD_VERYSLOW routine when an obstacle is detected within seven
inches, or an A_AHEAD_SLOW routine when an obstacle is detected within
thirteen inches, during an initial period of cleaning. Both of these routines are
initiated for 100 milliseconds:
After the expiration of the 100 milliseconds, if an obstacle is not detected, the
robot will return its previous cleaning speed. (Ex. 1003-Locke at 85.) This
return to a previous cleaning speed (i.e., from A_AHEAD_SLOW or
A_AHEAD_VERYSLOW to FWD5 in random mode, or from
A_AHEAD_VERYSLOW to FWD3 in random mode) meets this claim limitation.
35
limitation.
[1f] wherein the drive system is configured to alter the heading setting in
response to a signal received from the bump sensor indicating contact with an
obstacle.
limitation.
First, the Suckmaster Article discloses that the robot turns responsive to
bump switch detection of an obstacle:
clear path.
The Suckmaster Code also discloses altering the heading setting in response
to a signal received from the bump sensor. Specifically, the Suckmaster Code
includes an avoid_object routine, which instructs the robot, e.g., how to respond
when the bump switch indicates contact with an obstacle. Indeed, as explained
above in Section V(F)(2), there are three different maneuvers which are performed,
depending on the type of bump sensor contact that is sensed: A_WALL_RIGHT,
A_WALL_LEFT, and A_BACKAWAY (including the A_SPIN_RIGHT, and
A_SPIN_LEFT maneuvers). (Ex. 1005-Code at lines 1128-1230, 1453-1460; Ex.
36
1003-Locke at 40-41.) All three initiate a heading change in response to the
bump sensor contacting an object. Any of these evasive maneuvers can be
initiated when the bump sensor collides with an object in the reduced speed travel
of the vacuum_random, A_AHEAD_SLOW or A_AHEAD_VERYSLOW
routines, as their operations are described with respect to claim element [1e]. (Ex.
1003-Locke at 88.)
Accordingly, the Suckmaster Article and the Suckmaster Code disclose, in
combination, each and every element of claim 1, and claim 1 is therefore
anticipated by Suckmaster. To the extent that the Suckmaster Article and
Suckmaster Code are considered separate references, a person of skill in the art
would have found the complete subject matter of claim 1 obvious based on the
combination of the Suckmaster Article and the Suckmaster Code. (Ex. 1003-
Locke at 46-47.)
[CLAIM 2] The robot of claim 1 wherein the drive system is configured to

alter the heading setting in response to the signals received from the bump
sensor and the proximity sensor to follow a perimeter of the obstacle.
The Suckmaster Code discloses that the limitation of claim 2 occurs in
random mode. Specifically, the Suckmaster Code discloses when the robot
touches an obstacle with its bump sensor (e.g., while in random mode), an
A_WALL_LEFT or A_WALL_RIGHT maneuver is initiated, depending on
37
whether the obstacle was hit on the right or left side of the robot as determined by
data from the sonar proximity sensor:
In the A_WALL_LEFT and A_WALL_RIGHT maneuvers, the robot
reverses the wheel away from the wall (i.e., the right wheel in A_WALL_LEFT,
and the left wheel in A_WALL_RIGHT) until the path is clear ahead of the robot,
thereby aligning the robots path with the wall:
(Ex. 1005-Code at lines 1220-1231; Ex. 1003-Locke at 40.) As a result,
the Suckmaster Code discloses that, during navigation within the vacuum_random
38
routine, a bump collision with a wall on one robot side results in an
A_WALL_LEFT or A_WALL_RIGHT routine whereby the robot aligns its path
with the wall before proceeding along the walls perimeter. (Ex. 1003-Locke at
92.)
combination, each and every element of claim 2, and Suckmaster anticipates claim
2.
Thus, to the extent that the Suckmaster Article and Suckmaster Code are
considered separate references, or the Suckmaster Code and Suckmaster Article are
considered not to disclose transitioning from random cleaning to perimeter
cleaning, a person of skill in the art would have found the complete subject matter
of Claim 2 obvious based on the combination of the Suckmaster Article and the
Suckmaster Code. (Ex. 1003-Locke at 46-47.) A POSITA would have found
the complete subject matter of Claim 2 obvious based on the combination of the
Suckmaster Article and the Suckmaster Code. (Ex. 1003-Locke at 46-47, 89-
92.)

maneuver the robot at a torque setting, wherein the drive system is configured
to alter the torque setting in response to a signal received from the bump
sensor indicating contact with an obstacle.
The Suckmaster Article and the Suckmaster Code both inherently disclose
the limitations of claim 8. Specifically, both the Suckmaster Article and the
39
Suckmaster Code inherently disclose that the drive system is configured to
maneuver the robot at a torque setting. By setting a forward speed, (high speed
or reduced speed in the Suckmaster Article; FWD5, FWD3, or FWD2 in the
Suckmaster Code), both the Suckmaster Article and the Suckmaster Code disclose
maneuvering the robot at a torque setting, because torque of an electric motor is
directional. (Ex. 1003-Locke at 94.) In addition, both the Suckmaster Article
and the Suckmaster Code disclose altering that torque setting when the robot
reverses and turns in response to contact with the wall, as discussed above with
respect to claim element [1f] and claim 2. By reversing the robot, the torque
setting on both wheels of the robot is altered (from forward torque to
backward torque); by turning the robot, the torque on one or both of the wheels
of the robot is similarly altered. (Ex. 1003-Locke at 94.) Because this torque
adjustment is in response to contact with the wall (or an object), as discussed above
with respect to claim element [1f] and claim 2, it is in response to a signal received
from the bump sensorthe bump sensor is what is described as alerting the robot
that it has made contact with an object.
40
Locke at 46-47, 93-94.)
[CLAIM 11-PREAMBLE] A method of navigating an autonomous coverage

robot with respect to an object on a floor, the method comprising the robot:
Both the Suckmaster Article and the Suckmaster Code disclose the preamble
of claim 11, whether or not it is limiting.
The Suckmaster Article discloses control strategies employed by an
autonomous robot to navigate around a simulated room. See analysis of claim
element [1a], above.
The Suckmaster Code discloses various control modes for navigating an
autonomous robot with respect to an object. Specifically, the Suckmaster Code
includes a main routine that calls control routines including vacuum_perimeter,
vacuum_random, avoid_object, maneuver, and others. (Ex. 1005-Code at lines
1851-1906.) See analysis of claim element [1a], above.
limitation.
[11a] autonomously traversing the floor in a cleaning mode at a cleaning

speed;
limitation.
41
The Suckmaster Article discloses control strategies employed by the robot,
which include a high speed setting, which is the cleaning speed of the claim:
than 20 inches.
(Ex. 1004-Article at 4.) See analysis of claim element [1a], above.
The Suckmaster Code discloses various control modes, each of which
includes one or more speed settings. Specifically, the Suckmaster Code includes
control modes including vacuum_perimeter, vacuum_random, avoid_object,
maneuver, and others. In vacuum_random, three different speeds (FWD5, FWD3,
or FWD2) may be used; both FWD5 and FWD3 are the cleaning speed of the
claim. See analysis of claim element [1a], above.
limitation.
[11b] upon sensing a proximity of the object forward of the robot, reducing
the cleaning speed to a reduced speed while continuing towards the object;
limitation.
The Suckmaster Article discloses slowing down the robot when the sonar
detects a nearby object. See analysis of claim element [1d], above.
42
The Suckmaster Code discloses reducing speed when an obstacle is detected
by the sonar while continuing towards the object. Specifically, in the
vacuum_random routine, or in an initial startup period, the robot slows down from
FWD5 to FWD3 or FWD2, or from FWD3 to FWD2, when an obstacle is detected.
See analysis of claim element [1d], above.
limitation.
[11c] in response to not sensing the presence of the object while advancing at
the reduced speed, increasing the speed setting; and
limitation. See analysis of claim element [1e], above.
[11d] in response to sensing contact with the object, turning with respect to
the object and cleaning next to the object.
limitation.
The Suckmaster Article discloses that the robot turns responsive to bump
switch detection of an object:
clear path.
43
The Suckmaster Code also discloses turning with respect to an object and
cleaning next to the object in response to sensing contact with an object. First, the
Suckmaster Code discloses turning with respect to an object in response to sensing
contact with that object with a bump sensor. See analysis of claim element [1f],
above. Second, the Suckmaster Code discloses cleaning next to an object after
sensing contact with the object. See analysis of claim 2, above.
Locke at 95-104.)
[CLAIM 12] The method of claim 11 wherein the robot follows a perimeter of
the object while cleaning next to the object.
Both the Suckmaster Article and the Suckmaster Code disclose the
limitations of claim 12. See analysis of claim 2, above.
44
Locke at 105-106.)
[CLAIM 25 Comparison with CLAIM 1]

Many of the limitations of claim 25 have equivalent limitations in claim 1,
and thus are satisfied by the disclosures of the Suckmaster Article and the
Suckmaster Code that are discussed with respect to claim 1 infra. A comparison of
claim 25 to its claim 1 equivalent is illustrated in the table below.
Claim 25 Claim 1 Equivalent
25. An autonomous coverage robot 1. An autonomous coverage robot
comprising: comprising:
[25a] a drive system configured to [1a] a drive system configured to
maneuver the robot according to a maneuver the robot according to a
heading setting and a speed setting; heading setting and a speed setting;
[25b] a bump sensor responsive to a [1b] a bump sensor responsive to a
collision of the robot with an obstacle in collision of the robot with an obstacle in
a forward direction; and a forward direction; and
[25c] a proximity sensor responsive to a [1c] a proximity sensor responsive to a
potential obstacle forward of the robot; potential obstacle forward of the robot;
[25d] wherein the drive system is [1d] wherein the drive system is
45
configured to reduce the speed setting in configured to reduce the speed setting in
response to a signal from the proximity response to a signal from the proximity
sensor indicating detection of a potential sensor indicating detection of a potential
obstacle, while continuing to advance obstacle, while continuing to advance
the robot according to the heading the robot according to the heading
setting; setting;
[25e] wherein the drive system is [1e] wherein the drive system is
configured to increase the speed setting configured to increase the speed setting
if the drive system does not receive [a if the drive system does not receive [a
signal from the bump sensor within an subsequent signal indicating the
elapsed time after the speed setting is presence of an obstacle while
reduced]; and continuing to advance according to the
heading setting and the reduced speed
setting]; and
[25f] wherein the drive system is [1f] wherein the drive system is
configured to alter the heading setting in configured to alter the heading setting in
response to a signal received from the response to a signal received from the
bump sensor indicating contact with an bump sensor indicating contact with an
obstacle. obstacle.
46
As shown in the table above, the only difference between claim 25 and claim
1 is the bold and italicized text in element [25e] above.
[25e] wherein the drive system is configured to increase the speed setting if the
drive system does not receive a signal from the bump sensor within an elapsed
time after the speed setting is reduced
The Suckmaster Code discloses this limitation. As noted above with respect
to claim elements [1d] and [11c], the Suckmaster Code discloses initiating an
A_AHEAD_VERYSLOW maneuver when an obstacle is detected within seven
inches, or an A_AHEAD_SLOW maneuver when an obstacle is detected within
thirteen inches. Both of these maneuvers are initiated for 100 milliseconds
because, in the start_maneuver routine, the second input variable (with a value of
10 in the A_AHEAD_SLOW and A_AHEAD_VERYSLOW calls, highlighted
below) sets the length of time for executing the maneuver, where the length of time
is ten milliseconds x the value given. (Ex. 1005-Code at lines 1314-1329
(m_timer = t; // 10ms per tick maneuver limit timer (1.255 = 10ms to 2.55 sec.
).) As a result, the A_AHEAD_SLOW and A_AHEAD_VERYSLOW
maneuvers are initiated for 100 milliseconds. Furthermore, the
A_AHEAD_SLOW and A_AHEAD_VERYSLOW calls include a maneuver
priority of P_SONAR, as shown below:
47
(Ex. 1005-Code at lines 1366-1377 (emphasis added); Ex. 1003-Locke at 32,
35.)
While the robot is executing an A_AHEAD_VERYSLOW maneuver or an
A_AHEAD_SLOW maneuver, the robot may contact an obstacle, triggering the
bump switch. As noted above, this triggers an A_WALL_RIGHT,
A_WALL_LEFT, A_SPIN_RIGHT, A_SPIN_LEFT, and/or A_BACKAWAY
maneuver. Each of these maneuvers is initiated with a maneuver priority of
P_BUMP:
48
P_BUMP is a higher priority sensor than P_SONAR. (Ex. 1005-Code at
lines 194-195; Ex. 1003-Locke at 119.) As a result, when the bump sensor
indicates a bump, the responsive maneuver will override the A_AHEAD_SLOW
or A_AHEAD_VERYSLOW behavior. (Ex. 1003-Code at lines 1322-1323
(cancel_maneuver routine); Ex. 1003-Locke at 119.)
Accordingly, the Suckmaster Code discloses that a signal from the bump
switch within the 100 millisecond execution time of the A_AHEAD_VERYSLOW
or A_AHEAD_SLOW routine prevents the robot from returning to its normal
cleaning speed, because the maneuver responsive to the bump switch detection
instead executes for its instructed period of time.
If, on the other hand, the bump switch (or other maneuver-causing input) is
not activated within the 100 millisecond execution time of the
A_AHEAD_VERYSLOW or A_AHEAD_SLOW routine, then the maneuver
cleaning speed will be set to a null value at the end of the maneuver routine, as
indicated by the highlighted portion below:
49
(Ex. 1005-Code at 1292-1298 (emphasis added).) As a result, the arbitrate routine
will set the robot wheel speed to the speed commanded by the mode of the robot
(e.g., random mode), i.e., the normal cleaning speed (FWD5). Thus, the
Suckmaster Code discloses that the drive system of the robot is configured to
increase the speed setting if the drive system does not receive a signal from the
bump sensor within an elapsed time after the speed setting is reduced.
Locke at 107-121.)
B. Ground 3: Obviousness Based on Suckmaster Article (including

incorporated and published Suckmaster Code) and Jones-490

For Ground 3, the prior art consists of the Suckmaster Article (Ex. 1004), the
Suckmaster Code (Ex. 1005), and Jones-490 (Ex. 1009). Each reference is prior
art, as explained above in V.E. The content of each reference is discussed below.
50

incorporated and published Suckmaster Code) and Jones-
490
Both Suckmaster (including the Suckmaster Code) and Jones-490 disclose
cleaning robots designed to autonomously navigate a space to clean the floor of
that space. (Ex. 1003-Locke at 48-49.) The robots of Suckmaster and Jones-
490 both include two drive wheels and a variety of sensors (including forward-
looking proximity sensors and bump sensors) for navigation. (Ex. 1003-Locke at
48-57.) Furthermore, both Suckmaster and Jones-490 disclose a variety of
cleaning modes intended to collectively maximize the cleaning efficiency of the
robot. (Ex. 1003-Locke at 48-57.) Because of this high degree of similarity, a
person of skill in the art would find it obvious to try the hardware and/or
autonomous navigation strategies of Jones-490 with Suckmaster in an attempt to
improve cleaning performanceas stated by Jones-490, to provide maximum
coverage at an effective coverage rate. (Ex. 1009-Jones at 5:29-30; see Ex. 1003-
Locke at 48-57.) Furthermore, due to the similarities of the Suckmaster and
Jones-490 robots, a POSITA would have a reasonable expectation of success in
implementing the hardware and/or autonomous navigation strategies of Jones-490
in Suckmaster. (Ex. 1003-Locke at 48-57.)
As explained, the Suckmaster disclosures include an autonomous coverage
robot with bump sensors and sonar proximity sensors, as well as an infrared (IR)
51
transmitter for tracking a beacon. (Ex. 1003-Locke at 48.) Jones-490 discloses
similar mechanical, electrical and control mechanisms for an autonomous coverage
robot. (Ex. 1003-Locke at 49.) Those elements include, like the Suckmaster,
bump and IR proximity sensors. (Ex. 1003-Locke at 50.) Structurally then, the
two disclosed robots are similar. The control mechanism of Jones-490, which is a
simple software design able to be implemented on either robots processor,
includes various coverage algorithms and behaviors, including wall following.
(Ex. 1003-Locke at 49-51.)
A POSITA could have easily and with predicable results implemented the
control strategies of Jones-490 into the Suckmaster disclosure. (Ex. 1003-Locke at
51-52.) Jones-490 teaches that its control strategies maximize efficiencies in
cleaning, so a POSITA would have even been motivated to make such a change.
(Ex. 1003-Locke at 49.) Likewise, especially in view of the fact that Suckmaster
already discloses using IR transmitters, a POSITA could have easily and with
predictable results implemented Jones-490s IR proximity sensors for
Suckmasters sonar sensors. (Ex. 1003-Locke at 53-54.)
3. Challenged Claims for Ground 3

A person of skill in the art would have found claims 2, 4, 21, and 22 obvious
based on Suckmaster in view of Jones-490. The combination of Suckmaster and
Jones-490 discloses each and every element of claims 4, 21, and 22, as discussed
52
below, and a POSITA would have found the complete subject matter of claims 4,
21, and 22 obvious based on the combined disclosures of Suckmaster and Jones-
490.

alter the heading setting in response to the signals received from the bump
sensor and the proximity sensor to follow a perimeter of the obstacle.
As noted above in Section VI(A)(3)(claim 2), the Suckmaster Article and the
Suckmaster Code disclose A_WALL_LEFT and A_WALL_RIGHT maneuvers
that alter the heading setting in response to signals received from the bump sensor
and the proximity sensor to follow a perimeter of the obstacle while in random
mode.
The Suckmaster Article and the Suckmaster Code also disclose a perimeter
mode. The Suckmaster Article discloses that the robot, with its side against the
wall, will follow a perimeter of the room:
The Suckmaster II is started with its left side against the wall of the
simulated room. It moves forward until it touches the far wall and
executes at 90 degree right turn and moves until it touches the next
wall and executes another 90 degree right turn. It then runs until it
touches the speaker box and executes a 90 degree right turn.
(Ex. 1004-Article at 4.)
53
The Suckmaster Code discloses a perimeter mode in which the robot hugs
the left wall by setting the right wheel speed to a faster speed (FWD5) than the left
wheel (FWD4): to follow the wall, i.e., the perimeter of the obstacle, as claimed:
(Ex. 1005-Code at lines 1513-1521; Ex. 1003-Locke at 39, 91.)
The Suckmaster Code also discloses that, when the robot touches an obstacle
with its bump sensor while in perimeter mode, an A_BACKAWAY maneuver is
initiated:
(Ex. 1005-Code at lines 1453-1455; Ex. 1003-Locke at 91.) Within the
A_BACKAWAY maneuver, an A_SPIN_LEFT or A_SPIN_RIGHT maneuver is
eventually initiated to align the robot with the wall; which maneuver is initiated
depends on a reading from the sonar:
54
(Ex. 1005-Code at lines 1144-1150; Ex. 1003-Locke at 34, 40.) As a result, in
perimeter mode, the Suckmaster code discloses altering the heading setting in
response to the signals received from the bump sensor and the proximity sensor to
follow a perimeter of the obstacle, as claimed.
Jones-490 also discloses a perimeter-follow mode. Specifically, Jones-490
describes a wall following mode using wall following sensors:
In a preferred embodiment, in the wall-following mode, the robot uses

the wall-following sensor 16 to position itself a set distance from the
wall. The robot then proceeds to travel along the perimeter of the wall.
As shown in FIGS. 8A & 8B, in a preferred embodiment, the robot 10
is not able to distinguish between a wall 100 and another solid
obstacle 101.
(Ex. 1009-Jones at 10:43-49.)
Jones-490 further describes using wall sensors to follow a wall until a bump
is detected by a bump sensor, at which point the robot changes its heading using an
align behavior to navigate around bump obstacle before resuming wall-following
behavior:
In certain embodiments, when the WALL-FOLLOWING behavior is

active and there is a bump, the ALIGN behavior becomes active. The
ALIGN behavior turns the robot counter-clockwise to align the robot
with the wall. ... When the ALIGN behavior has completed turning, it
cedes control to the WALL-FOLLOWING behavior.
55
(Id. at 12:30-52.)
FIGS. 8A, 8B, 8C, and 8D further show that the robot of Jones-490 is
configured to follow a wall and navigate the perimeter of a room, or, in the same
manner, to navigate the perimeter of an obstacle within a room:
As shown above, Jones-490 describes a robot that uses proximity and bump
sensors to alter the heading of a robot in order to follow the perimeter of an
obstacle, such as a wall. (Ex. 1003-Locke at 42-43, 124-125.)
In addition, Jones-490 explicitly discloses transitioning to wall-following
mode from another operational mode when encountering a wall:
In a preferred embodiment, the device immediately enters wall

following mode after the triggering event.
In a preferred embodiment, the device then switches between wall

following mode (movement lines 51) and random bounce modes
56
(movement lines 48) based on bump sensor events or the completion

of the wall following algorithm.
(Ex. 1009-Jones at 16:43-50.)
Although the Suckmaster Code does not explicitly disclose that the
Suckmaster robot transitions into the perimeter mode from the random mode,
Jones-490 does teach transitioning to wall following mode from another operation
mode upon encountering a wall, as noted above. A POSITA would recognize that
the Suckmaster Code is specifically designed for a situation in which, as described
by the Suckmaster Article, the robot is placed against the wall to begin cleaning,
and thus may begin in perimeter mode. A POSITA would recognize that the
navigation strategies disclosed in the Suckmaster Code could be invoked in any
order as needed for a given situation, including but not limited to transitioning
from random mode to perimeter mode in response to the bump sensor detecting an
obstacle, as taught by Jones-490. In addition, because both Suckmaster and Jones-
490 disclose the use of wall-following behavior for the same reason (i.e., cleaning
along a wall), a POSITA would have found it obvious to apply the specific wall
following behavior parameters taught in Jones-490 to Suckmaster. (Ex. 1003-
Locke at 48-57.)
Therefore, a POSITA would have found claim 2 obvious based on the
combination of Suckmaster and Jones-490. (Ex. 1003-Locke at 123-125.)
57
[CLAIM 4] The robot of claim 1 wherein the proximity sensor comprises at

least one infrared emitter and receive pair.
Suckmaster discloses the robot of claim 1. Jones-490 discloses the
additional limitations of claim 4. Specifically, Jones-490 describes a preferred
embodiment in which the proximity sensors are infrared sensors comprising an
infrared emitter and receiver pair:
A preferred embodiment also contains a wall-following or wall-

detecting sensor 16 mounted on the dominant side of the robot 10. In a
preferred embodiment, the wall following sensor is an IR sensor
composed of an emitter and detector pair collimated so that a finite
volume of intersection occurs at the expected position of the wall.
This focus point is approximately three inches ahead of the drive
wheel in the direction of robot forward motion. The radial range of
wall detection is about 0.75 inches.
(Ex. 1004-Jones at 7:11-19.)
Jones-490 therefore describes a proximity sensor comprising an infrared emitter
and receiver.
As described above, Suckmaster uses sonar sensors to navigate around a
room and to sense objects in its path and to its sides. Jones-490, as explained
above, uses similar proximity sensors but instead of using sonar, Jones-490 teaches
using IR proximity sensors, just as in the claim. A POSITA would have
understood that the sensors described by Jones-490 were a simple design choice
58
and it would have been easy to substitute infrared sensors (Jones-490) for sonar
sensors (Suckmaster). (Ex. 1003-Locke at 128.)
Thus, Jones-490 discloses the specific recitations of claim 4, and Suckmaster
in view of Jones-490 renders claim 4 obvious to a POSITA. (Ex. 1003-Locke at
127-128.)
[CLAIM 12] The method of claim 11 wherein the robot follows a perimeter of
the object while cleaning next to the object.
The Suckmaster Article, Suckmaster Code, and Jones-490 disclose the
limitations of claim 12. See analysis of claim 2, above. Accordingly, a person of
skill in the art would have found the complete subject matter of claim 12 obvious
based on the combination of Suckmaster and Jones-490. (Ex. 1003-Locke at
129-130.)
[CLAIM 13] The method of claim 11 wherein the robot maintains a

substantially constant following distance from the object while cleaning next
to the object in response to the contact with the object.
Although Petitioner does not challenge claim 13 in this Petition, claim 13 is
discussed because Petitioner does challenge claims 21 and 22, which depend from
claim 13.
As explained above with respect to claim 2, the Suckmaster Article and
Suckmaster Code disclose an A_WALL_LEFT or A_WALL_RIGHT routine in
which the robot transitions from a collision with a wall to aligning itself and
following the wall. (Ex. 1005-Code at lines 1220-1230.) This alone discloses
59
claim 13. However, if the Board finds that tracking the wall at no distance does
not satisfy this claim, Suckmaster combined with Jones-490 certainly does.
Specifically, Jones-490 discloses that the robot positions itself a set distance
from a wall or other obstacle and then follows the perimeter:
In a preferred embodiment, in the wall-following mode, the robot

uses the wall-following sensor 16 to position itself a set distance from
the wall. The robot then proceeds to travel along the perimeter of the
wall. As shown in FIGS. 8A & 8B, in a preferred embodiment, the
robot 10 is not able to distinguish between a wall 100 and another
solid obstacle 101. (Ex. 1004-Jones at 10:43-49 (emphasis added).)
Jones-490 illustrates this process in FIGS. 8A-8D, in which the robot
follows a path 46/47 that is substantially a constant distance from the wall 100 or
obstacle 101:
60
As shown above, one of Jones-490s control strategies is to follow a wall at
a controlled distance using its side-looking IR proximity sensors. Thus, Jones-490
discloses the limitations of claim 13 and it in combination with Suckmaster render
claim 13 obvious.
61
[CLAIM 21] The method of claim 13 wherein the robot decreases the cleaning
speed to a reduced speed at a nor-linear rate.
The Suckmaster Code discloses the limitation of claim 21. Specifically, the
Suckmaster Code discloses, in random mode, that the cleaning speed of the robot is
reduced from full speed (i.e., FWD5) to a reduced speed (FWD3) when an obstacle
is detected in front of the robot, and is further reduced to a further reduced speed
(FWD2) when an obstacle is detected closer to the robot. Thus, the Suckmaster
Code teaches that the speed is reduced from FWD5 to FWD2, with an intermediate
speed of FWD3. If, during this reduction, the speed of the robot is maintained at
FWD3 for any period of time, then the change from FWD5 to FWD2 is non-linear,
regardless of whether the change from FWD5 to FWD3 is linear or non-linear, and
regardless of whether the change from FWD3 to FWD2 is linear or non-linear.
(Ex. 1003-Locke at 135.) At reasonable values of FWD5, FWD3, and FWD2,
the robots speed would indeed be FWD3 for some period of time while the robot
advances towards an obstacle (i.e., where detection of the same obstacle triggers
both the transition from FWD5 to FWD3, and from FWD3 to FWD2. (Ex. 1003-
Locke at 135.) Accordingly, the Suckmaster Code discloses that the robot
decreases the cleaning speed at a non-linear rate when the Suckmaster robot
reduces its speed from FWD5 to FWD2, with an intermediate speed of FWD3.
In addition, a POSITA would have found it obvious to implement a non-
linear speed decrease with a reasonable expectation of success. A POSITA would
62
appreciate that non-linear speed reduction is a typical speed reduction
implementation in a wheeled vehicle powered by an electric motor, and would be
motivated to implement non-linear speed reduction as a standard means of
controlling the speed of the Suckmaster robot, which is a wheeled robot powered
by an electric motor. (Ex. 1003-Locke at 135-136.)
[CLAIM 22] The method of claim 13 wherein the cleaning speed of the robot
is about 300 mm/sec.
The Suckmaster Code discloses that the robot cleans at a max speed of
FWD5. (Ex. 1005-Code at lines 126-129; Ex. 1003-Locke at 72.) The
Suckmaster Code does not explicitly disclose what actual speed FWD5
corresponds to and, in any event, the actual speed of FWD5 would vary based on
the wheel size and motor type of the robot executing the Suckmaster Code. A
POSITA would have appreciated that the actual speed of FWD5 was a routine
design choice and a setting that resulted in 300 mm/sec would have been obvious.
(Ex. 1003-Locke at 138.)
In any event, Jones-490 explicitly discloses a cleaning speed of 300 mm/sec.
Specifically, Jones-490 discloses that 77% of its normal speed is 0.235 m/s, which
is 235 mm/s. (Ex. 1004-Jones at 15:50.) Thus, the normal speed (or 100/77 of 235
mm/s) disclosed by Jones-490 is 305.2 mm/s. A POSITA would consider this to
be about 300 mm/s, as required by the claim, as it differs by less than 2%. (Ex.
1003-Locke at 139-140.)
63
Thus, Jones-490 discloses the limitation of claim 22, and Suckmaster in
view of Jones-490 renders claim 22 obvious. (Ex. 1003-Locke at 141.)
The Examiner of the application that gave rise to the 553 patent stated
during prosecution that Jones-490 does not disclose that the cleaning speed of the
robot is about 300 mm/sec. (Ex. 1002 at 250.) The Examiner may not have
appreciated the mathematical inherency confirming that Jones-490 discloses a
cleaning speed of 305.2 mm/s. Indeed, this less than 2% difference speed was
never referenced during prosecution. As explained, a person of skill in the art
would consider 305.2 mm/s to be about 300 m/s.
Even if the Board disagrees that 305.2 mm/s is about 300 m/s, this would
have been an obvious design choice. A person of skill in the art would have
known that any number of cleaning speeds between the 77% reduced speed and
normal speed of 305.2 mm/s would have been readily available and equally
effective. (Ex. 1003-Locke at 140.) Accordingly, even if the Board finds that
Jones-490 does not explicitly disclose this limitation, it would have been obvious
in view of the knowledge of one of skill in the art reading Jones-490.
Nonetheless, if the Board is inclined to defer to the Examiners judgment on
this issue, this Petition includes an alternate ground of unpatentability of claim 22.
See Ground 4 below.
64
C. Ground 4 - Obviousness Based on Suckmaster Article (including

incorporated and published Suckmaster Code), Jones-490, and
Park-707

For Ground 4, the prior art consists of the Suckmaster Article (Ex. 1004), the
Suckmaster Code (Ex. 1005), Jones-490 (Ex. 1009), and Park-707 (Ex. 1010).
Each reference is prior art, as explained above in Section V(E). The content of
each reference is discussed below.

incorporated and published Suckmaster Code), Jones-490,
and Park-707
The rationale for combining Suckmaster with Jones-490 is set forth in
Section VI(B)(2) above.
A person of skill in the art would also be motivated to combine Suckmaster
and Jones-490 with Park-707 because Suckmaster, Jones-490, and Park-707 all
disclose hardware and navigation strategies for autonomous robotic vacuum
cleaners. Accordingly, a person of skill in the art would have a reasonable
expectation of success when combining the teachings of Park-707 with Suckmaster
and Jones-490. (Ex. 1003-Locke at 58-63.) A POSITA would therefore have
found it obvious to try the navigation strategies taught by Park-707, including at
least the cleaning speed taught by Park-707, with Suckmaster and Jones-490 to
improve the cleaning ability of the robot. (Ex. 1003-Locke at 58-63.)
65
3. Challenged Claim for Ground 4

A person of skill in the art would have found claim 22 obvious based on
Suckmaster in view of Jones-490 and Park-707. The combination of Suckmaster,
Jones-490, and Park-707 discloses each and every element of claim 22, as
discussed below, and a POSITA would have found the complete subject matter of
claim 22 obvious based on the combined disclosures of Suckmaster, Jones-490,
and Park-707.
[CLAIM 22] The method of claim 13 wherein the cleaning speed of the robot
is about 300 mm/sec.
Suckmaster in view of Jones-490 discloses the method of claim 13. (See
Section VI(B)(2), above.)
Jones-490 discloses that the cleaning speed of the robot is 305.2 mm/s. (See
Section VI(B)(2), Claim 22, above.)
Park-707 discloses that the cleaning speed of a cleaning robot is exactly 300
mm/second. (Ex. 1010-Park at [0037].) A person of skill in the art would have
found it obvious to apply the cleaning speed disclosed in Park-707 to the
combination of Suckmaster and Jones-490 as a routine design choice. (Ex. 1003-
Locke at 58-63, 144-145.)
Thus, a person of skill in the art would have found claim 22 obvious based
on Suckmaster in combination with Jones-490 and Park-707. (Ex. 1003-Locke at
143-145.)
66
VII. CONCLUSION
For the foregoing reasons, Petitioner respectfully requests that the inter
partes review of the 553 patent be instituted as the Petition establishes a
reasonable likelihood of prevailing with respect to the Challenged Claims.
Petitioner further respectfully requests that claims 1-2, 4, 8, 11-12, 21-22, and 25
be cancelled as unpatentable.
Respectfully submitted,
GREENBERG TRAURIG, LLP
Date: September 21, 2017 By: /s/ Patrick J. McCarthy

Patrick J. McCarthy
Registration No. 62,762
mccarthyp@gtlaw.com
Phone: (202) 533-2386
Fax: (202) 331-3101
Counsel for Petitioner
67
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the Petition together
with all exhibits identified in the above Table of Exhibits and Petitioners Power of
Attorney, have been served on the Patent Owner via Priority Mail Express or by
means at least as fast and reliable as Priority Mail Express on the below date, at the
following addresses:
Ruffin B. Cordell
Ralph A. Phillips
Stephen A. Marshall
FISH & RICHARDSON P.C.
901 15th Street, N.W., Suite 700
Washington, DC 20005
Respectfully submitted,
GREENBERG TRAURIG, LLP
Date: September 21, 2017 By: /s/ Patrick J. McCarthy

Patrick J. McCarthy
Registration No. 62,762
mccarthyp@gtlaw.com
Phone: (202) 533-2386
Fax: (202) 331-3101
Counsel for Petitioner
68

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UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE PATENT TRIAL AND APPEAL BOARD

Shenzhen Zhiyi Technology Co., Ltd.,

Patent No. 8,600,553 to Svendsen et al.

IPR Case No. IPR2017-02133

PETITION FOR INTER PARTES REVIEW OF CLAIMS 1-2,

TABLE OF EXHIBITS ...........................................................................................iv

A. Ground 1: Anticipation Based on Suckmaster Article (including

1002 File History of U.S. Patent No. 8,600,533

1003 Expert Declaration of Dr. C. Douglass Locke, Ph.D.

Dales Homemade Robots - Suckmaster II Vacuum Robot

1005 Suckmaster2.c (Suckmaster Source Code)

1006 Declaration of Dale Heatherington

Archived Version of Suckmaster Article, achived on June 20,

1008 **Intentionally Left Blank**

1009 U.S. Patent No. 6,809,490 to Jones et al. (Jones-490)

1010 U.S. PG Pub. No. 2005/0192707 to Park et al. (Park-707)

1011 Joint Claim Construction Statement, In re Certain Robotic

Shenzhen Zhiyi Technology Co., Ltd. (Petitioner) hereby seeks inter

partes review of Claims 12, 4, 8, 1112, 2122, and 25 (the Challenged

previously-known hardware and navigation control strategies as applied to an

should therefore be canceled for the reasons described in this Petition.

I. MANDATORY NOTICES UNDER 37 C.F.R. 42.8(a)(1) FOR INTER

A. Real Party in Interest Under 37 C.F.R. 42.8(b)(1)

Co. Ltd. d/b/a iLife.

B. Related Matters Under 37 C.F.R. 42.8(b)(2)

Investigation No. 337-TA-1057 (the ITC Investigation).

There is also a federal district court litigation filed by iRobot Corporation

10652 (D. Mass.) (the District Court Case).

C. Lead and Backup Counsel Under 37 C.F.R. 42.8(b)(3) and

Lead Patrick J. McCarthy

Greenberg Traurig LLP

Phone: (202) 533-2386

Greenberg Traurig LLP

Service on Petitioner may be made by mail or hand delivery to: Greenberg

Petitioner also consents to electronic service by emailing counsel of record at

mccarthyp@gtlaw.com, nelsonc@gtlaw.com, and

II. PAYMENT OF FEES UNDER 37 C.F.R. 42.15

further authorizes any additional fees to be charged to this Deposit Account.

III. CERTIFICATION OF WORD COUNT UNDER 37 C.F.R. 42.24(D)

counted by the word-processing program (Microsoft Word 2010) used to generate

authorities, mandatory notices, certificate of service, appendix of exhibits, and this

limit set in 37 C.F.R. 42.24(a)(1)(i).

IV. REQUIREMENTS FOR IPR UNDER 37 C.F.R. 42.104

A. Grounds for Standing Under 37 C.F.R. 42.104(a)

on the grounds identified in the Petition.

B. Identification of Challenge Under 37 C.F.R. 42.104(b) and Relief

553 patent (Ex. 1001) be cancelled based on the following grounds of

Anticipation based on Suckmaster

Obviousness Based on Suckmaster

Obviousness based on Suckmaster

Obviousness based on Suckmaster

A. Overview of the 553 Patent

The 553 patent relates to movement of an autonomous robot. (Ex. 1001 at

autonomous movement of the robot, including a drive system 104 receiving

at Abstract; FIGS. 8B, 10; 8:35-45.)

is detected by the kinetic bump sensor. (Id. at FIG. 9B.)

cited in this Petition.

B. Background of the 553 Patent

entitled to the benefit of the provisional filing date.

2. Prosecution of the 553 Patent

application included 23 claims, including independent claims 1 and 10.

Independent claim 1, as-filed, is reproduced below:

1008 Intentionally Left Blank