In re: Aqua Prods., Inc., No. 15-1177 (Fed. Cir. 2016)
Annotate this CaseAqua’s patent concerns automated swimming pool cleaners. Using motor-driven wheels that enable the cleaner to move in a controlled pattern requires a drive motor and integrated circuitry. Cleaners that use suction or water jets do not require a drive motor, but often move in erratic patterns. The patent discloses an automated pool cleaner that uses “an angled jet drive propulsion system” to move in a controlled pattern. Zodiac sought inter partes review, citing prior art cleaners that use an internal pump to create a filtered water jet. Aqua moved to substitute new claims to require that the jet creates a downward vector force rear of the front wheels; the wheels control the directional movement of the cleaner; the cleaner has four wheels; and the jet shoots filtered water. Aqua argued that the combination of prior art did not render the substitute claims obvious because it does not suggest the vector limitation. The Patent Board denied Aqua’s motion to amend. The Federal Circuit affirmed, rejecting challenges to Board procedures, which require the patentee to demonstrate that amended claims would be patentable over the art of record. The Board rebutted Aqua’s sole argument that the vector limitation made the substitute claims patentable over the combination of prior art.
The court issued a subsequent related opinion or order on August 12, 2016.
The court issued a subsequent related opinion or order on August 12, 2016.
The court issued a subsequent related opinion or order on October 4, 2017.
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