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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Shenzhen Silver Star Intelligent Technology Co. Ltd.
`
`v.
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`iRobot Corporation
`Patent Owner
`
`U.S. Patent No. 6,809,490
`Filing Date: June 12, 2002
`Issue Date: October 26, 2004
`
`Title: Method and System for Multi-Mode Coverage for an Autonomous Robot
`
`
`DECLARATION OF MINGSHAO ZHANG
`
`Inter Partes Review No. <To Be Assigned>
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`Table of Contents
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`I.  BACKGROUND AND EXPERIENCE ............................................................... 5 
`A.  General Work Experience and Professional Background ............................... 5 
`B.  Education ......................................................................................................... 6 
`C.  Professional Societies, Committee Memberships, and Teaching Experience 6 
`D.  Publications ...................................................................................................... 6 
`E.  Compensation .................................................................................................. 7 
`II.  Person of Ordinary Skill in the Art ....................................................................... 8 
`III. RELEVANT TECHNOLOGY BACKGROUND AND STATE OF THE ART 9 
`A.  Means for moving the robot over a surface ..................................................... 9 
`B.  Bounce mode ................................................................................................... 9 
`C.  Isolated area ................................................................................................... 11 
`D.  Means for manually selecting an operational mode ...................................... 14 
`E.  A control system operatively connected to said obstacle detection sensor and
`said means for moving said control system configured to operate in a
`plurality of operational modes and to select from among the plurality of
`modes in real time in response to signals generated by the obstacle detection
`sensor ............................................................................................................. 15 
`IV.  THE ‘490 Patent ............................................................................................ 15 
`A.  The Specification ........................................................................................... 15 
`B.  The Claims of the ‘490 Patent ....................................................................... 16 
`C.  Contested Claims of the ‘490 Patent ............................................................. 17 
`V.  APPLICATION OF THE PRIOR ART TO THE CLAIMS .............................. 19 
`A.  Overview of the Prior Art .............................................................................. 19 
`i.  Ueno (Ex. 1005) ....................................................................................... 19 
`ii.  Bottomley (Ex. 1006) ............................................................................... 20 
`iii. Kawagoe (Ex. 1007) ................................................................................. 20 
`iv. Öhman (Ex. 1008) .................................................................................... 21 
`v.  Bisset (Ex. 1010) ...................................................................................... 21 
`vi. Erwin (Ex. 1011) ...................................................................................... 22 
`vii.  Bisset-612 (Ex. 1026) .......................................................................... 22 
`B.  Ueno Discloses All the Features of Claims 1, 2-5, 7, 8, and 12 .................... 23 
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`(a) Claim Element 1(a) ............................................................................. 23 
`(b) Claim Element 1(b) ............................................................................. 23 
`(c) Claim Element 1(c) ............................................................................. 24 
`(d) Claim Element 1(d) ............................................................................. 25 
`(e) Claim Element 1(e) ............................................................................. 27 
`(f) Claim Element 1(f) .............................................................................. 29 
`(g) Claim Element 1(g) ............................................................................. 30 
`(h) Claim Element 1(h) ............................................................................. 31 
`(i)  Claim Element 1(i) .............................................................................. 34 
`b.  Dependent Claims 2-5, 7, 8, and 12 ......................................................... 36 
`(a) Claim 2 ................................................................................................ 36 
`(b) Claim 3 ................................................................................................ 37 
`(c) Claim 4 ................................................................................................ 38 
`(d) Claim 5 ................................................................................................ 39 
`(e) Claim 7 ................................................................................................ 40 
`(f) Claim 8 ................................................................................................ 41 
`(g) Claim 12 .............................................................................................. 41 
`c.  Summary of Ueno Invalidity .................................................................... 42 
`C.  The Combination of Ueno and AAAI Article Describes Claims 1, 2-5, 7, 8,
`and 12 ............................................................................................................. 42 
`D.  The Combination of Ueno and Kawagoe Describes Claims 1, 2-5, 7, 8, and
`12 45 
`E.  The Combination of Ueno and Bisset Describes Claim 12 ........................... 48 
`F.  The Combination of Ueno, AAAI Article and Bisset Describes Claim 12 .. 51 
`G.  The Combination of Ueno, Kawagoe and Bisset Describes Claim 12 .......... 51 
`H.  The Combination of Ueno and Erwin Describes Claim 12 ........................... 51 
`I.  The Combination of Ueno, AAAI Article and Erwin Describes Claim 12... 53 
`J.  The Combination of Ueno, Kawagoe and Erwin Describes Claim 12 .......... 53 
`K.  The Combination of Ueno and Bottomley Describes Claim 42 .................... 53 
`L.  The Combination of Ueno, AAAI Article and Bottomley Describes Claim 42
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`57 
`M. The Combination of Ueno, Kawagoe and Bottomley Describes Claim 42 .. 57 
`N.  The Combination of Ueno and Öhman Describes Claim 42 ......................... 57 
`O.  The Combination of Ueno, AAAI Article and Öhman Describes Claim 42 60 
`P.  The Combination of Ueno, Kawagoe and Öhman Describes Claim 42 ........ 61 
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`Q.  The Combination of Ueno and Bissett-612 Describes Claim 42 .................. 61 
`R.  The Combination of Bottomley and AAAI Article Describes Claims 1 and
`42 64 
`(a) Claim Element 1(a) ............................................................................. 65 
`(b) Claim Element 1(b) ............................................................................. 65 
`(c) Claim Element 1(c) ............................................................................. 66 
`(d) Claim Element 1(d) ............................................................................. 66 
`(e) Claim Element 1(e) ............................................................................. 67 
`(f) Claim Element 1(f) .............................................................................. 68 
`(g) Claim Element 1(g) ............................................................................. 69 
`(h) Claim Element 1(h) ............................................................................. 69 
`(i)  Claim Element 1(i) .............................................................................. 70 
`VI.  Conclusion ..................................................................................................... 72 
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`I, Mingshao Zhang, declare as follows:
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`1.
`
`I have been asked to provide a declaration regarding certain aspects of
`
`U.S. Patent No. 6,809,490 (“the ‘490 Patent”) addressed below, which I understand
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`is the subject of the present inter partes review proceeding.
`
`I.
`
`BACKGROUND AND EXPERIENCE
`2.
`I am over the age of 18 and am competent to offer this Declaration. I
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`have personal knowledge, or have developed knowledge of these technologies based
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`upon education, training, or experience, of the matters set forth herein.
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`A. General Work Experience and Professional Background
`3.
`I currently act as an assistant professor at Southern Illinois University
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`Edwardsville. I have a very broad and deep understanding of robotics technologies
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`as it relates to design, mechanisms, sensing, control as well as electronics and
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`software systems utilized in mobile robots. I have taught many undergraduate
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`classes including Engineering Problem Solving and Sensors and Actuators. As such
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`I am very well versed with complete system design and with all their components
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`such as motors, drivetrains, power-systems, user-interfaces, wireless communication
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`systems,
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`sensors,
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`controls
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`(hardware
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`and
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`software),
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`electronics
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`and
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`microprocessors, and have an appreciation of the history of development in the field
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`of robotics since its nascent years. All this experience is covered in my curriculum
`
`5
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`vitae (attached as Appendix A), which provides a detailed recitation of my
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`employment history and tenure at various jobs.
`
`
`B.
`4.
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`Education
`I have earned the following degrees:
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`
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`B.Sc. Mechanical Engineering and Automation, University of
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`Science and Technology of China, 2010
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`M.Sc. Mechanical Engineering, Stevens Institute of Technology,
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`Ph.D. Mechanical Engineering, Stevens Institute of Technology,
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`
`
`
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`2012
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`2016.
`
`C.
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`5.
`
`Professional Societies, Committee Memberships, and Teaching
`Experience
`I have remained an active participant or member in organizations
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`throughout my studies and career, and have pursued advancements in my field,
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`including:
`
` American Society for Engineering Education, 2016-Present
`
`D.
`Publications
`6. My curriculum vitae, attached as Appendix A, provides as
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`comprehensive a record of these publications as I have been able to assemble.
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`E. Compensation
`7.
`I am being compensated by the Southern Illinois University at
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`Edwardsville (SIUE), and the petitioner finds me through the SIUE. My
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`compensation does not depend in any way upon the outcome of this proceeding.
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`8.
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`The analysis that I provide in this Declaration is based on my education
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`and experience in the field of Mobile Robots, as well as the documents I have
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`considered, including the ‘490 Patent (Ex. 1001) which states on its face that it
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`issued from an application filed on June 12, 2002, in turn claiming priority back to
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`an earliest provisional application filed on June 12, 2001. For purposes of this
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`Declaration, I have assumed June 12, 2001 as the effective filing date for the ‘490
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`Patent to be on the conservative side. I have considered the following documents in
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`my analysis below:
`
`Description of Exhibit
`Ex. No.
`U.S. Patent No. 6,809,490 to Joseph L. Jones et al.
`1001
`1002
`Prosecution File History of U.S. Patent No. 6,809,490
`1005
`Translation of JP 11-212642 (“Ueno”)
`1006 WO 00/04430 (“Bottomley”)
`1007
`US 6,574,536 (“Kawagoe”)
`1008 WO 93/03399 (“Öhman”)
`1010 WO 00/38025 (“Bisset”)
`1011
`Translation of DE 19849978 (“Erwin”)
`1014
`JP 11-212642 (“Ueno”)
`1015
`DE 19849978 (“Erwin”)
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`II.
`
`1016
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`1017
`
`1018
`
`1019
`
`1026
`
`“Sensors for Mobile Robots – Theory and Application” by H.R.
`Everett, Wellesley, MA, 1995
`“Where am I? Sensors and Methods for Mobile Robot Positioning”
`by J. Borenstein, H.R. Everett and L. Feng, University of Michigan,
`Ann Arbor, MI, April 1996
`“Mobile Robots – Inspiration to Implementation” by J.L. Jones and
`A. M. Flynn, Wellesley, MA, 1st Edition, 1993
`“Sweep Strategies for a Sensory-Driven, Behavior-Based Vacuum
`Cleaning Agent” by K.L. Doty and R.R. Harrison, AAAI Technical
`Report FS-93-03, AAAI 1993 Fall Symposium Series –
`Instantiating Real-World Agents, Oct. 1993
`US Patent 6,493,612 to Bisset 612
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`PERSON OF ORDINARY SKILL IN THE ART
`9.
`I have been informed that a person of ordinary skill in the art (a
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`“POSITA”) is a hypothetical person who is presumed to have the skill and
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`experience of an ordinary worker in the field and is deemed to have knowledge of
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`the relevant prior art. A POSITA, as of the June 2001 filing date of the application
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`upon which the ‘490 Patent claims priority would have had a bachelor’s degree in
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`computer engineering, electrical engineering, mechanical engineering, computer
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`science, or robotic engineering (or equivalent degree/experience) with at least two
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`years of experience in robotics.
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`10. Although my qualifications and experience exceed those of the
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`hypothetical POSITA defined above, my analysis and opinions regarding the ‘490
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`Patent are based on the perspective of a POSITA as of June 2001.
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`III. RELEVANT TECHNOLOGY BACKGROUND AND STATE OF THE
`ART
`11.
`
` The ‘490 Patent, entitled “Method and System for Multi-Mode
`
`Coverage for an Autonomous Robot,” discloses and claims a control system for a
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`mobile robot that operates in a plurality of operational modes, including an obstacle
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`following mode, a random bounce mode, and a spot coverage mode. Ex. 1001,
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`Abstract and 3:65-4:4. In this section, I provide a brief background of the state of
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`the art pertinent to the claims of the ‘490 Patent as of June 2001.
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`A. Means for moving the robot over a surface
`12. The function is straightforward – moving the robot over a surface. The
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`corresponding structure in the ‘490 patent specification performing that function is
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`straightforward also. The disclosed embodiment includes “two wheels 20, motors
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`21 for driving the wheels independently” Ex. 1001, 5:59-62. The ‘490 specification
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`states that “[t]hese components are well known in the art and are not discussed in
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`detail herein.” Id., 5:63-64. The parties in the related ITC case are in agreement that
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`the structure performing the function of moving the robot over a surface is two
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`wheels and motors 21 for driving the wheels independently. Ex. 1023, 5; Ex. 1025,
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`14-15. Accordingly, this should be considered the corresponding structure for
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`purposes of claim construction.
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`B.
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`Bounce mode
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`13. The word “bounce” in “bounce mode” raises the question of whether
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`actual, physical contact with obstacles is required when driving in this mode, or
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`whether this mode can include situations where the change in direction occurs due
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`to proximity with obstacles without contact. In my opinion, the latter is correct, and
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`that the term “bounce mode” should be construed to according to its plain and
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`ordinary meaning, and including contact or proximity to the object to trigger the
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`change in direction.
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`14. This interpretation is supported by the plain language of the
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`independent claims. Nothing in the independent claims requires actual, physical
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`contact between the robot and an obstacle. Instead, the claim language uses the term
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`“encountering” to describe the robot’s relation to the obstacle, which clearly does
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`not require contact. Ex. 1009 (dictionary definition of “encounter”).
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`15. Moreover, the other claims plainly contemplate that proximity may be
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`used to trigger the change of direction in this mode. For example, claims 8 and 40
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`recite that the “obstacle detection sensor” can comprise “an IR sensor.” IR sensors
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`are used for detecting proximity. Ex. 1001, 6:35-38. Similarly, claim differentiation
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`compels an interpretation that contact is not required because claims 7 and 41 recite
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`that the “obstacle detection sensor” includes “a tactile sensor.” A tactile sensor
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`detects contact. Id.at 5:52-55 (“bump (tactile) sensors”). Thus, an interpretation
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`requiring “bounce mode” to include sensing of physical contact would violate claim
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`differentiation by requiring the device of the independent claims to include a tactile
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`sensor.
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`16. This interpretation is also supported by the specification. The
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`specification states that “the sensor(s) may be of a variety of types including sonar,
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`tactile, electromagnetic, capacitive, etc.” Ex. 1001, 5:50-52. The specification also
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`says “bump (tactile) sensors” are used in the “preferred embodiment” for cost-
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`reasons. Id., 5:52-55. Clearly, the specification contemplates that the sensors chosen
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`may be of any type, including contact sensors or non-contact sensors. That logically
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`means that detection of actual, physical contact used in the “preferred embodiment”
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`should not be required by the independent claim term “bounce mode.” Other parts
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`of the specification confirm this. Id., 6:35-38 (stating as an alternative to
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`contact/bump sensors that “[n]on-contact sensors, which allow the robot to sense
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`proximity to objects without physically touching the object, such as capacitive
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`sensors or a curtain of IR light, can also be used.”); 6:39-42 (“It is useful to have a
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`sensor or sensors that are not only able to tell if a surface has been contacted (or is
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`nearby), but also the angle relative to the robot at which the contact was made.”)
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`Thus, Petitioner’s construction for “bounce mode” should be adopted.
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`C.
`Isolated area
`17. Claims 1 and 42 recite “a spot-coverage mode whereby the robot
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`operates in an isolated area.” The claims do not say whether (a) the area is isolated
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`physically in the sense that it is a limited area with an identifiable physical boundary,
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`e.g., an area behind a couch or in a corner, or (b) the extent of isolation may be
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`determined by the robot itself, such as an algorithm in its controller.
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`18. Unhelpfully, the specification uses the term “isolated” just once, stating
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`that “[s]pot coverage or, for example, spot cleaning allows the user to clean an
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`isolated dirty area.” Id., 9:11-12. That usage sheds little to no light on the meaning
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`of the term “isolated.” However, the specification teaches that both situations (a)
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`and (b) are possible ways to terminate the spot-coverage mode, and thus determine
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`the area it covers.1 When the area has one or more obstacles around it, the robot can
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`exit the spot-coverage mode and switch to another mode upon reaching the obstacle
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`(situation (a)). Id., Fig. 7 at 240 and 9:34-10:8. See also id., 10:18-21 (“In a
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`preferred embodiment, as detailed in step 220, the robot 10 exits spot cleaning mode
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`upon the first obstacle encountered by a bump sensor 12 or 13.”) and Fig. 14.
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`Likewise, when the robot is in an open area free of obstacles, the specification states
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`that the spiraling action of this spot-coverage mode continues outwardly for a
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`prescribed distance and then ends (situation (b)). Ex. 1001, 9:17 (“defined radius”);
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`Fig. 7 at 240 and 9:57-10:8 (“In other embodiments, the robot tracks its total distance
`
`
`1 It would make no sense to read “isolated” as meaning an area that is entirely
`bounded or enclosed from the rest of the room being cleaned, because then the
`robot could not even enter such a completely “isolated area.” Thus, the general
`context of the specification is more informative.
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`travelled in spiral mode.If the maximum spiral is reached without a bump, the robot
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`gives control to a different behavior..”). Thus, the broadest reasonable interpretation
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`of an “isolated area” in the context of the “spot coverage mode” should be an area
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`with its perimeter determined either at least in part by a physical boundary/obstacle,
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`or by the cleaning robot itself. That is, the broadest reasonable interpretation of the
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`claim language includes within its scope a robot configured to react to a physical
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`boundary/obstacle of the “isolated area,” a robot that has a pre-programmed size
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`limit for the “isolated area,” or a robot that has the ability to react to either one (i.e.,
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`whichever event occurs first). The specification teaches that the spot coverage mode
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`can be terminated by either the robot deciding it has covered sufficient distance (and
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`thus area) in this mode or striking a boundary or an obstacle, and thus either event
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`can define the extent of the area’s isolation.
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`19. Moreover, the specification describes a “preferred embodiment” where
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`the “a standard spiral” mode is used in which “the device should continue until any
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`bump sensor event.” Id., 16:42-43. In that embodiment, the bump sensor event
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`triggers switching to wall following mode, as shown in Fig. 14. Id., 16:43-45. Thus,
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`the specification contemplates that the “spot coverage mode” exemplified by this
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`spiraling can be configured to run until hitting a physical object, and not necessarily
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`be limited by a set distance in the robot controller. Further, it should be noted that
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`claim 1, for example, recites a control system that selects “from among the plurality
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`of operational modes in real time in response to signals generated by the obstacle
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`detection sensor.” Accordingly, such claim language indicates that the robot
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`continues in a “spot coverage mode” until the robot detects an obstacle, at which
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`time, the control system is configured to select another mode.
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`20. Hence, the proper construction should include robots that use either or
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`both options for determining the size of its “spot coverage mode’s” “isolated area.”
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`D. Means for manually selecting an operational mode
`21. The function is straightforward – manually selecting an operational
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`mode. The corresponding structure in the ‘490 patent specification performing that
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`function is straightforward also. The disclosed embodiment includes “a remote
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`control” to change or influence operational modes or “a switch mounted on the shell
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`itself” to set the operational mode. Ex. 1001, 17:5-10. The parties in the related
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`ITC case are in agreement that the structure for manually selecting an operational
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`mode in the ‘490 Patent is an input element such as a selector switch, push button,
`
`or remote control by which the user can select a particular operational mode. Ex.
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`1023, 5. Ex. 1025, 14. Accordingly, this should be considered the corresponding
`
`structure for purposes of claim construction.
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`14
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`E. A control system operatively connected to said obstacle detection
`sensor and said means for moving said control system configured
`to operate in a plurality of operational modes and to select from
`among the plurality of modes in real time in response to signals
`generated by the obstacle detection sensor
`If, however, the “control system” is interpreted as a mean plus function
`
`22.
`
`clause, the corresponding structure performing the functions of being operatively
`
`connected, operating in a plurality of operating modes, and selecting from among a
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`plurality of modes is a processor/microcontroller 22 in Fig. 3 of the ‘490 Patent and
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`the associated behavior algorithms in the specification for the three claimed modes.
`
`See id., noting corresponding structure for a “control system.” Specifically, the
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`specification of the ‘490 Patent describes that the processor/microcontroller 22 is
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`connected
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`to
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`sensors
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`and wheels
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`(and motors),
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`and
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`that
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`the
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`processor/microcontroller 22 operates in one or more operational modes and selects
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`an operational mode for the robot’s operation. Ex. 1001, 7:34-57 and 8:48-56.
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`Accordingly, the processor/microcontroller 22 and the behavior algorithms used
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`therein for the claimed modes should be considered the corresponding structure for
`
`purposes of claim construction.
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`IV. THE ‘490 PATENT
`A. The Specification
`23. The ‘490 Patent describes a control system for a robot to operate in a
`
`plurality of operational modes, such as an obstacle following mode, a random
`
`bounce mode, and a spot coverage mode. (Ex. 1001, Abstract.) Specifically, the
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`‘490 Patent describes (i) the spot coverage mode as a mode that allows a user to
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`clean an isolated dirty area and that is switched to another mode when an obstacle is
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`encountered by an obstacle sensor, (ii) the obstacle following mode as a mode that
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`allows a user to clean edges of a room by traveling along a perimeter of a wall with
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`the help of an obstacle sensor, and (iii) the random bounce mode as a mode that
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`allows the robot to continue its forward movement until it senses an obstacle and
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`that allows the robot to change the direction of travel when the obstacle has been
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`detected (Ex. 1001, 9:11-12, 10:18-21, 10:27-29, 10:43-46, 12:54-61, and Fig. 11).
`
`Further, the ‘490 Patent describes the structure of the robot that includes bump
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`sensors 12 and 13, reflective IR proximity sensors for the cliff sensors 14, a wall-
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`following sensor 16, wheels 20, motors 21, a microcontroller 22, a rechargeable
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`battery 23, cleaning heads 30, and a side brush 32. (Ex. 1001, 5:41-6:2).
`
`B.
`The Claims of the ‘490 Patent
`24. This Declaration addresses Claims 1, 2-5, 7, 8, 12 and 42 of the ‘490
`
`Patent. Claims 1 and 42 read:
`
`1. A mobile robot comprising:
`(a) means for moving the robot over a surface;
`(b) an obstacle detection sensor;
`(c) and a control system operatively connected to said obstacle detection sensor
`and said means for moving;
`(d) said control system configured to operate the robot in a plurality of operational
`modes and to select from among the plurality of modes in real time in response to
`signals generated by the obstacle detection sensor, said plurality of operational
`modes comprising: a spot-coverage mode whereby the robot operates in an
`isolated area, an obstacle following mode whereby said robot travels adjacent to
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` I
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`an obstacle, and a bounce mode whereby the robot travels substantially in a
`direction away from an obstacle after encountering the obstacle, and wherein,
`when in the obstacle following mode, the robot travels adjacent to an obstacle for
`a distance at least twice the work width of the robot. (Ex. 1001, 17:19-36 (Claim
`1).)
`
`42. A mobile robot comprising:
`(a) means for moving the robot over a surface;
`(b) an obstacle detection sensor;
`(c) a cliff sensor; and
`(d) a control system operatively connected to said obstacle detection sensor, said
`cliff sensor, and said means for moving;
`(e) said control system configured to operate the robot in a plurality of operational
`modes, said plurality of operational modes comprising: a spot-coverage mode
`whereby the robot operates in an isolated area, an obstacle following mode
`whereby said robot travels adjacent to an obstacle for a distance at least twice the
`work width of the robot, and a bounce mode whereby the robot travels
`substantially in a direction away from an obstacle after encountering the obstacle.
`(Ex. 1001, 20:48-64 (Claim 42).)
`
` will address the dependent Claims 2-5, 7, 8, and 12 in the ‘490 Patent in my detailed
`
`analysis in Part V. “Application of the Prior Art” later. Because those claims are
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`short, I reproduced them at the beginning of each section where they are discussed.
`
`C. Contested Claims of the ‘490 Patent
`25. For easier reference to elements of independent Claims 1 and 42 from
`
`the ‘490 Patent, I reproduce their text here, including labels for each clause to make
`
`it easier to refer to each such element in my analysis and discussion of claims and
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`individual claim elements (where applicable):
`
`1(a). A mobile robot comprising
`1(b). means for moving the robot over a surface;
`1(c). an obstacle detection sensor;
`
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`1(d) and a control system operatively connected to said obstacle detection sensor
`and said means for moving;
`1(e). said control system configured to operate the robot in a plurality of
`operational modes and to select from among the plurality of modes in real time in
`response to signals generated by the obstacle detection sensor,
`1(f). said plurality of operational modes comprising: a spot-coverage mode
`whereby the robot operates in an isolated area,
`1(g). an obstacle following mode whereby said robot travels adjacent to an
`obstacle,
`1(h). and a bounce mode whereby the robot travels substantially in a direction
`away from an obstacle after encountering the obstacle,
`1(i). wherein, when in the obstacle following mode, the robot travels adjacent to an
`obstacle for a distance at least twice the work width of the robot.
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`42(a). A mobile robot comprising:
`42(b). means for moving the robot over a surface;
`42(c). an obstacle detection sensor;
`42(d). a cliff sensor; and
`42(e). a control system operatively connected to said obstacle detection sensor,
`said cliff sensor, and said means for moving;
`42(f). said control system configured to operate the robot in a plurality of
`operational modes,
`42(g). said plurality of operational modes comprising: a spot-coverage mode
`whereby the robot operates in an isolated area,
`42(h). an obstacle following mode whereby said robot travels adjacent to an
`obstacle for a distance at least twice the work width of the robot,
`42(i). and a bounce mode whereby the robot travels substantially in a direction
`away from an obstacle after encountering the obstacle.
`
`
`26. Note that using this nomenclature, the Preamble to claim 1 is identified
`
`as claim Element 1(a), or simply 1(a). Thus, the first following limitation after the
`
`Preamble is claim Element 1(b) or 1(b), the next is claim Element 1(c) or 1(c), and
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`so forth. I will use this nomenclature throughout this Declaration to ensure precise
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`and unambiguous references to the numerous elements of claim 1 (and claim 42).
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`18
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`V. APPLICATION OF THE PRIOR ART TO THE CLAIMS
`A. Overview of the Prior Art
`i. Ueno (Ex. 1005)
`JP 11-212642, “Method and Device for Controlling Self-Propelled
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`27.
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`Robot,” has a publication date of August 6, 1999. Ichiro Ueno and Kato Hironobu
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`are the named inventors. This Patent Application will henceforth be identified as
`
`“Ueno.”
`
`28. Ueno describes a method and device for controlling a self-propelled
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`robot that can travel exhaustively over a given area in as short a time as possible.
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`(Ex. 1005, ¶ [0001].) Specifically, Ueno describes that the operations of the wheels,
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`motors, and brakes of the robot are determined based on information received from
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`multiple sensors (for example, infrared sensors, ultrasonic sensors, or any optical
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`sensors) that sense obstacles around the robot. (Ex. 1005, ¶¶ [0007], [0016], [0017],
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`[0020], and Figs. 2 and 3.) Further, Ueno describes three travel modes of the robot:
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`spiral, random, and border-following. (Ex. 1005, ¶¶ [0014] and [0035].)
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`Specifically, (a) in the spiral travel mode, the robot travels in a spiral direction until
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`an obstacle is detected by a sensor (Ex. 1005, ¶¶[0005], [0027], [0028] and Fig. 6),
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`(b) in the border-following, the robot travels along a boundary (such as a wall) when
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`a sensor detects a boundary (Ex. 1005, ¶¶[0023], [0025], and Fig. 4), and (c) in the
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`random travel mode, the robot turns and travels away from a boundary when a wall
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`surface is detected (Ex. 1005, ¶¶[0005], [0029], [0030], [0033], and Figs. 5 and 6).
`19
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`Further, Ueno describes that the repetition of the “spiral travel – random travel –
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`border-following - random travel combination” produces superior results in terms of
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`coverage area and the time that it takes to cover that area. (Ex. 1005, ¶¶ [0014] and
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`[0035].) As I shall show in the analysis and discussion that follow, Ueno includes
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`all the features required by Claims 1, 2-5, 7, 8, and 12.
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`
`
`ii. Bottomley (Ex. 1006)
`29. Bottomley, entitled “Robotic System,” describes a self-propelled robot
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`for movement over a surface to be treated. Ex. 1006, Abstract. Specifically,
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`Bottomley describes navigation sensors that provide signals for enabling the robot
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`to navigate over the surface and a control system that receives the signals from the
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`sensors so as to control the motors of the robot. Ex. 1006, Abstract.
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`
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`iii. Kawagoe (Ex. 1007)
`30. Kawagoe, entitled “Moving Apparatus for Efficiently Moving on Floor
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`with Obstacle,” describes a moving robot that moves in a backward path when an
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`obstacle is encountered