On April 18, 2017, iRobot Corp. of Bedford, Massachusetts (“iRobot”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337.
The complaint alleges that the following entities (collectively, the “Proposed Respondents”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain robotic vacuum cleaning devices and components thereof such as spare parts that infringe one or more claims of U.S. Patent Nos. 6,809,490 (the ’490 patent), 7,155,308 (the ’308 patent), 8,474,090 (the ’090 patent), 8,600,553 (the ’553 patent), 9,038,233 (the ’233 patent), and 9,486,924 (the ’924 patent) (collectively, the “asserted patents”):
- Bissell Homecare, Inc. of Grand Rapids, Michigan
- Hoover Inc. of Glenwillow, Ohio
- Royal Appliance Manufacturing Co. Inc. d/b/a TTI Floor Care North America, Inc. of Glenwillow, Ohio
- Bobsweep, Inc. of Canada
- Bobsweep USA of Henderson, Nevada
- The Black & Decker Corporation of Towson, Maryland
- Black & Decker (U.S.) Inc. of Townson, Maryland
- Shenzhen ZhiYi Technology Co., Ltd. d/b/a iLife of China
- Matsutek Enterprises Co., Ltd. of Taiwan
- Suzhou Real Power Electric Appliance Co., Ltd. of China
- Shenzhen Silver Star Intelligent Technology Co., Ltd. of China
According to the complaint, the asserted patents generally relate to various aspects of robotic vacuum cleaning devices. In particular, the ’490 patent relates to a control system for a mobile robot to effectively cover a given area by operating in a plurality of modes. The ’308 patent relates to a robot obstacle detection system that includes a robot housing that navigates with respect to a surface, and a sensor subsystem. The ’090 patent relates to a floor cleaning robot that includes a housing, wheels, and a motor driving the wheels to move the robot across the floor, a control module disposed within the housing and directing movement of the robot across the floor, a sensor for detecting and communicating obstacle information to the control module so that the control module can cause the robot to react to the obstacle, a removable bin disposed at least partially within the housing and receiving particulates, a first rotating member directing particulates toward the bin, and a second rotating member cooperating with the first rotating member to direct particulates toward the bin. The ’553 patent relates to an autonomous coverage robot that includes a drive system, a bump sensor, and a proximity sensor. The ’233 patent relates to an autonomous floor-cleaning robot that includes a cleaning-head subsystem with a dual-stage brush assembly having counter-rotating, asymmetric brushes. Lastly, the ’924 patent relates to a method of scheduling a robotic device that enables the device to run autonomously based on previously-loaded scheduling information.
In the complaint, iRobot states that the Proposed Respondents import and sell products that infringe the asserted patents. The complaint specifically refers to various robotic vacuum cleaning devices associated with the Proposed Respondents as infringing products.
Regarding domestic industry, iRobot states that its own Roomba robotic vacuum cleaning devices practice at least one claim of each of the asserted patents. iRobot further states that it conducts research, design, development, engineering, and testing of its domestic industry products in the U.S. iRobot specifically refers to relevant facilities in Massachusetts and California where it employs at least 520 employees, many of whom devote substantial time and effort towards activities relating to products that practice the asserted patents.
As to related litigation, iRobot states that on April 17, 2017, it filed complaints against the Proposed Respondents in the U.S. District Court for the District of Massachusetts alleging infringement of the asserted patents. iRobot further states it previously accused Urus Industrial Corp. and Koolatron of infringing, inter alia, the ’490 patent in a litigation in the U.S. District Court for the District of Massachusetts. iRobot also states that it has asserted a foreign counterpart to the ’490 patent in litigations in Germany.
With respect to potential remedy, iRobot requests that the Commission issue a limited exclusion order and cease and desist orders directed at the Proposed Respondents.