iRobot Corporation v. SharkNinja Operating LLC et al. (19-cv-12125).

Judge Burroughs denied iRobot’s motion for a preliminary injunction barring sales of accused Shark IQ Robot vacuum cleaners alleged to infringe two iRobot patents (while the complaint identified a total of six patents, iRobot did not assert the other four patents-in-suit in its motion for a preliminary injunction). The two patents covered robotic vacuums that could travel to their base stations to recharge and, once charged, resume cleaning where they left off as well as robotic cleaners that could self-empty into the base station. SharkNinja asserted that it knew of the two patents and that they designed the Shark IQ Robot to avoid infringement of these claims – by placing the service opening (through which self-emptying occurs) in a location different from that required by the claims. This argument required construction of the phrase “bottom portion,” which the specification and prosecution history suggested would be limited to only the bottom surface, as SharkNinja suggested. Judge Burroughs found that this at least raised a substantial question as to whether the IQ Robot infringed the ‘048 patent. Similarly, SharkNinja’s products do not detect a weak battery and then seek to recharge – instead, they simply run on a 60-minute timer and recharge at the end of the 60-minute cycle, regardless of charge state. iRobot pointed to language in the specification that indicated that a timer could be used to predetermine a time period before recharging “without determining which energy level subsequence” the robot is operating in. Judge Burroughs looked to the plain meaning of the claim phrase “detect a need to recharge” and determined that it required the robot to take an action in order to determine whether there is a need to charge itself, which the Shark IQ Robots do not do. Accordingly, iRobot’s request for a preliminary injunction was denied.

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