PUBLIC VERSION
`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`Washington, D.C.
`
`Before the Honorable Thomas B. Pender
`Administrative Law Judge
`
`
`
`
`
`
`Investigation No. 337-TA-1057
`
`In the Matter of
`
`CERTAIN ROBOTIC VACUUM
`CLEANING DEVICES AND
`COMPONENTS THEREOF SUCH AS
`SPARE PARTS
`
`
`
`RESPONDENTS HOOVER INC. AND ROYAL APPLIANCE
`MANUFACTURING CO. D/B/A TTI FLOOR CARE NORTH AMERICA, INC.’S
`RESPONSE TO THE COMPLAINT AND THE NOTICE OF INVESTIGATION
`
`Respondents Hoover Inc. (“Hoover”) and Royal Appliance Manufacturing Co. d/b/a TTi
`
`Floor Care North America, Inc. (“Royal”) (collectively, the “Hoover Respondents”), pursuant to
`
`19 C.F.R. § 210.13, respectfully submit this Response to the Complaint of iRobot Corporation
`
`(“iRobot” or “Complainant”) under Section 337 of the Tariff Act of 1930, as Amended (the
`
`“Complaint”), and the Notice of Investigation (the “Notice of Investigation”).
`
`RESPONSE TO THE COMPLAINT
`
`The Hoover Respondents respond to the Complaint dated April 17, 2017, and entitled
`
`“Verified Complaint of iRobot Corporation Under Section 337 of the Tariff Act of 1930, as
`
`Amended,” in like-numbered paragraphs, as follows. Certain headings are reproduced from the
`
`Complaint for the sake of convenience but are not an admission of the content of the Complaint
`
`or the specific allegations therein. Any allegations not specifically admitted are hereby denied.
`
`I.
`
`
`INTRODUCTION
`
`1.1
`
`The Hoover Respondents admit that iRobot has requested that the United States
`
`International Trade Commission (the “Commission”) institute an investigation under Section 337
`
`
`
`1
`
`IROBOT 2014
`Shenzhen Silver Star v. iRobot
`IPR2018-00897
`
`
`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`Washington, D.C.
`
`Before the Honorable Thomas B. Pender
`Administrative Law Judge
`
`
`
`
`
`
`Investigation No. 337-TA-1057
`
`In the Matter of
`
`CERTAIN ROBOTIC VACUUM
`CLEANING DEVICES AND
`COMPONENTS THEREOF SUCH AS
`SPARE PARTS
`
`
`
`RESPONDENTS HOOVER INC. AND ROYAL APPLIANCE
`MANUFACTURING CO. D/B/A TTI FLOOR CARE NORTH AMERICA, INC.’S
`RESPONSE TO THE COMPLAINT AND THE NOTICE OF INVESTIGATION
`
`Respondents Hoover Inc. (“Hoover”) and Royal Appliance Manufacturing Co. d/b/a TTi
`
`Floor Care North America, Inc. (“Royal”) (collectively, the “Hoover Respondents”), pursuant to
`
`19 C.F.R. § 210.13, respectfully submit this Response to the Complaint of iRobot Corporation
`
`(“iRobot” or “Complainant”) under Section 337 of the Tariff Act of 1930, as Amended (the
`
`“Complaint”), and the Notice of Investigation (the “Notice of Investigation”).
`
`RESPONSE TO THE COMPLAINT
`
`The Hoover Respondents respond to the Complaint dated April 17, 2017, and entitled
`
`“Verified Complaint of iRobot Corporation Under Section 337 of the Tariff Act of 1930, as
`
`Amended,” in like-numbered paragraphs, as follows. Certain headings are reproduced from the
`
`Complaint for the sake of convenience but are not an admission of the content of the Complaint
`
`or the specific allegations therein. Any allegations not specifically admitted are hereby denied.
`
`I.
`
`
`INTRODUCTION
`
`1.1
`
`The Hoover Respondents admit that iRobot has requested that the United States
`
`International Trade Commission (the “Commission”) institute an investigation under Section 337
`
`
`
`1
`
`IROBOT 2014
`Shenzhen Silver Star v. iRobot
`IPR2018-00897
`
`
`
`PUBLIC VERSION
`
`of the Tariff Act of 1930, as amended, 19 U.S.C. § 1337. The Hoover Respondents deny that
`
`they have unlawfully imported, sold for importation, and/or sold after importation in the United
`
`States any robotic vacuum cleaning devices or components thereof that infringe any valid and
`
`enforceable United States patent owned by iRobot.
`
`1.2
`
`The Hoover Respondents admit that the Complaint names Bissell Homecare, Inc.,
`
`Hoover Inc., Royal Appliance Manufacturing Co. Inc. d/b/a TTi Floor Care North America, Inc.,
`
`Bobsweep, Inc., Bobsweep USA, The Black & Decker Corporation, Black & Decker (U.S.) Inc.,
`
`Shenzhen Zhi Yi Technology Co., Ltd. d/b/a iLife, Matsutek Enterprises Co., Ltd., Suzhou Real
`
`Power Electric Appliance Co., Ltd., and Shenzhen Silver Start Intelligent Technology Co., Ltd.
`
`as proposed respondents (collectively, “Proposed Respondents”). The Hoover Respondents deny
`
`that they have engaged in any unfair acts in violation of Section 337, including the unlicensed
`
`importation, sale for importation, and/or sale after importation in the United States of any
`
`Accused Products that infringe one or more claims of U.S. Patent Nos. 7,155,308 (the “’308
`
`patent”); 8,474,090 (the “’090 patent”); 8,600,553 (the “’533 patent”); 9,038,233 (the “’233
`
`patent”); and/or 9,486,924 (the “’924 patent”) (collectively, the “Asserted Patents”). To the
`
`extent that this paragraph contains any other factual allegations, the Hoover Respondents lack
`
`sufficient knowledge or information to admit or deny the allegations and therefore deny the
`
`same.
`
`1.3
`
`The Hoover Respondents deny that they directly infringe, contributorily infringe,
`
`and/or induce the infringement of any claim of the Asserted Patents, including the claims
`
`identified in this paragraph. To the extent that this paragraph contains any other factual
`
`allegations, the Hoover Respondents lack sufficient knowledge or information to admit or deny
`
`the allegations and therefore deny the same.
`
`
`
`2
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`
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`PUBLIC VERSION
`
`1.4
`
`The Hoover Respondents admit that documents purporting to be certified copies
`
`of the Asserted Patents are attached to the Complaint as Exhibits 1-6. The Hoover Respondents
`
`further admit that documents purporting to be certified copies of the recorded assignments are
`
`attached to the Complaint as Exhibits 7-12. The Hoover Respondents lack sufficient knowledge
`
`or information to admit or deny the remaining allegations of paragraph 1.4 and therefore deny
`
`the same.
`
`1.5
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 1.5 and therefore deny the same.
`
`1.6
`
`The Hoover Respondents admit that iRobot seeks certain relief under Section
`
`337(d) and (f) and that iRobot seeks the imposition of a bond during any Presidential review
`
`period. The Hoover Respondents deny the existence of the predicates and requirements for
`
`liability under Section 337 and therefore deny that iRobot is entitled to any relief, including the
`
`requested relief, as a result of this Investigation. To the extent that this paragraph contains any
`
`other factual allegations, they are denied.
`
`II.
`
`
`COMPLAINANT
`
`2.1
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 2.1 and therefore deny the same.
`
`2.2
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 2.2 and therefore deny the same.
`
`2.3
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 2.3 and therefore deny the same.
`
`2.4
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 2.4 and therefore deny the same.
`
`
`
`3
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`
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`PUBLIC VERSION
`
`2.5
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 2.5 and therefore deny the same.
`
`2.6
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 2.6 and therefore deny the same.
`
`2.7
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 2.7 and therefore deny the same.
`
`III.
`
`
`PROPOSED RESPONDENTS
`
`A.
`
`3.1
`
`Bissell Homecare, Inc.
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.1 and therefore deny the same.
`
`3.2
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.2 and therefore deny the same.
`
`3.3
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.3 and therefore deny the same.
`
`B.
`
`3.4
`
`3.5
`
`Hoover, Inc.
`
`The Hoover Respondents admit the allegations in paragraph 3.4.
`
`The Hoover Respondents admit that Exhibit 14 is a document purporting to be a
`
`copy of a page from the website https://hoover.com/products/category/robot-vacuums/. The
`
`Hoover Respondents further admit that the Quest ™ line of products includes the Quest 700
`
`(Model BH70700), Quest 800 (Model70800), and Quest 1000 (Model BH71000) robot vacuums
`
`(hereinafter, “Hoover Accused Products”). The Hoover Respondents further admit that they
`
`offer to sell the Hoover Accused Products.
`
`3.6
`
`[
`
`
`
`4
`
`
`
`
`
`PUBLIC VERSION
`
` ] The Hoover
`
`Respondents further admit that Royal imports the Hoover Accused Products into the United
`
`States. The Hoover Respondents further admit that Royal sells the Hoover Accused Products in
`
`the United States following importation.
`
`
`
`C.
`
`
`3.7
`
`3.8
`
`Royal Appliance Manufacturing Co. Inc. d/b/a TTi Floor Care North
`America, Inc.
`
`The Hoover Respondents admit the allegations in paragraph 3.7.
`
`[
`
`
`
` ] The Hoover Respondents further admit
`
`that Royal imports the Hoover Accused Products into the United States. The Hoover
`
`Respondents further admit that Royal sells the Hoover Accused Products in the United States
`
`following importation.
`
`3.9
`
`The Hoover Respondents admit that Exhibit 16 is a document purporting to be a
`
`copy of a page from the website https://hoover.com/products/category/robot-vacuums/ that states
`
`“Today, Hoover is part of TTI Floor Care North America, Headquartered in Glenwillow, OH.”
`
`The Hoover Respondents admit that Exhibit 17 is a document purporting to be a copy of a TTi
`
`Floor Care North America website that states “Hoover: We acquired this marquee brand in
`
`2007.” The Hoover Respondents deny that Exhibit 17, which purports to be a copy of the TTi
`
`Floor Care North America website, includes a link to the Hoover sales website. To the extent
`
`that this paragraph contains any other factual allegations, the Hoover Respondents lack sufficient
`
`knowledge or information to admit or deny the allegations and therefore deny the same.
`
`Bobsweep, Inc.
`
`D.
`
`3.10 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.10 and therefore deny the same.
`
`
`
`5
`
`
`
`PUBLIC VERSION
`
`3.11 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.11 and therefore deny the same.
`
`3.12 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.12 and therefore deny the same.
`
`Bobsweep USA
`
`E.
`
`3.13 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.13 and therefore deny the same.
`
`3.14 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.14 and therefore deny the same.
`
`3.15 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.15 and therefore deny the same.
`
`The Black & Decker Corporation
`
`F.
`
`3.16 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.16 and therefore deny the same.
`
`3.17 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.17 and therefore deny the same.
`
`3.18 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.18 and therefore deny the same.
`
`3.19 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.19 and therefore deny the same.
`
`
`
`6
`
`
`
`PUBLIC VERSION
`
`Black & Decker (U.S.) Inc.
`
`G.
`
`3.20 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.20 and therefore deny the same.
`
`3.21 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.21 and therefore deny the same.
`
`3.22 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.22 and therefore deny the same.
`
`Shenzhen ZhiYi Technology Co., Ltd. d/b/a iLife
`
`H.
`
`3.23 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.23 and therefore deny the same.
`
`3.24 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.24 and therefore deny the same.
`
`3.25 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.25 and therefore deny the same.
`
`Matsutek Enterprises Co., Ltd.
`
`I.
`
`3.26 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.26 and therefore deny the same.
`
`3.27 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.27 and therefore deny the same.
`
`3.28 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.28 and therefore deny the same.
`
`Suzhou Real Power Electric Appliance Co., Ltd.
`
`J.
`
`3.29 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`
`
`7
`
`
`
`PUBLIC VERSION
`
`deny the allegations of paragraph 3.29 and therefore deny the same.
`
`3.30 The Hoover Respondents admit that Suzhou Real Power Electric Appliance Co.,
`
`Ltd. (“Real Power”) manufactures certain of the Hoover Accused Products at least in China. To
`
`the extent that this paragraph contains any other factual allegations, the Hoover Respondents lack
`
`sufficient knowledge or information to admit or deny the allegations and therefore deny the
`
`same.
`
`3.31 The Hoover Respondents admit that Exhibits 34 and 35 purport to identify Real
`
`Power as manufacturer of Hoover robot vacuum models BH70700 and BH70800. The Hoover
`
`Respondents further admit that Exhibit 36 purports to identify Real Power as the shipper of
`
`“Vacuum Cleaner Spare Parts – Robots” to Royal. The Hoover Respondents further admit that
`
`Exhibit 37 purports to identify Real Power as the “Manufacturer” of the BH70700 robot vacuum
`
`cleaner. To the extent that this paragraph contains any other factual allegations, the Hoover
`
`Respondents lack sufficient knowledge or information to admit or deny the allegations and
`
`therefore deny the same.
`
`Shenzhen Silver Start Intelligent Technology Co., Ltd.
`
`K.
`
`3.32 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.32 and therefore deny the same.
`
`3.33 The Hoover Respondents admit that Shenzhen Silver Star Intelligent Technology
`
`Co., Ltd. (“Silver Star”) manufactures certain of the Hoover Accused Products at least in China.
`
`To the extent that this paragraph contains any other factual allegations, the Hoover Respondents
`
`lack sufficient knowledge or information to admit or deny the allegations and therefore deny the
`
`same.
`
`
`
`3.34 The Hoover Respondents admit that Exhibits 38 purports to identify Silver Star as
`
`8
`
`
`
`PUBLIC VERSION
`
`manufacturer of Hoover robot vacuum model BH71000. To the extent that this paragraph
`
`contains any other factual allegations, the Hoover Respondents lack sufficient knowledge or
`
`information to admit or deny the allegations and therefore deny the same.
`
`3.35 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.35 and therefore deny the same.
`
`3.36 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.36 and therefore deny the same.
`
`IV.
`
`
`THE TECHNOLOGY AND PRODUCTS AT ISSUE
`
`4.1
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 4.1 and therefore deny the same.
`
`4.2
`
`The Hoover Respondents admit that the Complainant identifies the Hoover
`
`Accused Products as Accused Products. The Hoover Respondents deny that any of its products,
`
`including the Hoover Accused Products, infringe any valid or enforceable claim of any Asserted
`
`Patent. To the extent that this paragraph contains any other factual allegations, the Hoover
`
`Respondents lack sufficient knowledge or information to admit or deny the allegations and
`
`therefore deny the same.
`
`4.3
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 4.3 and therefore deny the same.
`
`4.4
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 4.4 and therefore deny the same.
`
`4.5
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 4.5 and therefore deny the same.
`
`4.6
`
`The Hoover Respondents admit that paragraph 4.6 identifies the Quest 700
`
`
`
`9
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`
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`PUBLIC VERSION
`
`(Model BH70700), Quest 800 (Model BH70800), and Quest 1000 (Model BH71000) as
`
`examples of the Hoover Accused Products. Hoover denies that any of its products, including the
`
`Hoover Accused Products, infringes any valid and enforceable claim of the Asserted Patents. To
`
`the extent that this paragraph contains any other factual allegations, they are denied.
`
`4.7
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 4.7 and therefore deny the same.
`
`4.8
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 4.8 and therefore deny the same.
`
`4.9
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 4.9 and therefore deny the same.
`
`4.10
`
`[
`
`
`
` ] The Hoover Respondents further admit
`
`that Royal imports the Hoover Accused Products into the United States. Hoover further admits
`
`that Royal sells the Hoover Accused Products in the United States following their importation.
`
`To the extent that this paragraph contains any other factual allegations, the Hoover Respondents
`
`lack sufficient knowledge or information to admit or deny the allegations and therefore deny the
`
`same.
`
`V.
`
`
`THE ASSERTED PATENTS
`
`A.
`
`
`5.1
`
`U.S. Patent No. 6,809,490
`
`1.
`
`Identification of the Patent and Ownership by iRobot
`
`The Hoover Respondents admit that Exhibit 1 is a document purporting to be U.S.
`
`Patent No. 6,890,490 (“the ’490 Patent”) entitled “Methods and Systems for Multi-Mode
`
`Coverage for an Autonomous Robot” and purporting to be issued on October 26, 2004. The
`
`
`
`10
`
`
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`PUBLIC VERSION
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.1 and therefore deny the same.
`
`5.2
`
`The Hoover Respondents admit that on its face the ’490 patent has seven
`
`independent claims and 35 dependent claims. The Hoover Respondents lack sufficient
`
`knowledge or information to admit or deny the remaining allegations of paragraph 5.2 and
`
`therefore deny the same.
`
`5.3
`
`The Hoover Respondents admit that Exhibit 7 contains documents purporting to
`
`be assignments of all right, title and interest in U.S. Patent Application Serial No. 10/167,851
`
`recorded at the United States Patent and Trademark Office at Reel/Frame 014249/705 and
`
`014249/711. The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 5.3 and therefore deny the same.
`
`5.4
`
`The Hoover Respondents admit that Appendices A and G, respectively, purport to
`
`contain: A) a certified copy and three additional copies of the prosecution history of the ’490
`
`Patent; and B) four copies of examiner-cited references mentioned in that prosecution history.
`
`The Hoover Respondents lack sufficient knowledge or information to admit or deny the
`
`allegations of paragraph 5.4 and therefore deny the same.
`
`2.
`
`Non-Technical Description of the Patented Invention
`
`To the extent that paragraph 5.5 states legal conclusions regarding the alleged
`
`5.5
`
`scope of the ’490 patent, no response is required. To the extent that a response is required, the
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.5 and therefore deny the same.
`
`3.
`
`Foreign Counterparts to the ’490 Patent
`
`The Hoover Respondents admit that paragraph 5.6 contains a table of foreign
`
`5.6
`
`
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`11
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`
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`PUBLIC VERSION
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`patents and/or patent applications that are allegedly “counterparts” to the ’490 patent. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.6 and therefore deny the same.
`
`4.
`
`Licenses
`
`The Hoover Respondents admit that Confidential Exhibit 40 is a document
`
`
`
`5.7
`
`purporting to be a list of licensed entities. The Hoover Respondents lack sufficient knowledge or
`
`information to admit or deny the remaining allegations of paragraph 5.7 and therefore deny the
`
`same.
`
`B.
`
`
`5.8
`
`U.S. Patent No. 7,155,308
`
`1.
`
`Identification of the Patent and Ownership by iRobot
`
`The Hoover Respondents admit that Exhibit 2 is a document purporting to be U.S.
`
`Patent No. 7,155,308 (“the ’308 Patent”) entitled “Robot Obstacle Detection System” and
`
`purporting to be issued on December 26, 2006. The Hoover Respondents lack sufficient
`
`knowledge or information to admit or deny the allegations of paragraph 5.8 and therefore deny
`
`the same.
`
`5.9
`
`The Hoover Respondents admit that on its face the ’308 patent has two
`
`independent claims and 32 dependent claims. The Hoover Respondents lack sufficient
`
`knowledge or information to admit or deny the remaining allegations of paragraph 5.9 and
`
`therefore deny the same.
`
`5.10 The Hoover Respondents admit that Exhibit 8 contains documents purporting to
`
`be assignments of all right, title and interest in U.S. Patent Application Serial No. 10/453,202
`
`recorded at the United States Patent and Trademark Office at Reel/Frame 014150/455. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`
`
`12
`
`
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`PUBLIC VERSION
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`paragraph 5.10 and therefore deny the same.
`
`5.11 The Hoover Respondents admit that Appendices B and H, respectively, purport to
`
`contain: C) a certified copy and three additional copies of the prosecution history of the ’308
`
`Patent; and D) four copies of examiner-cited references mentioned in that prosecution history.
`
`The Hoover Respondents lack sufficient knowledge or information to admit or deny the
`
`allegations of paragraph 5.11 and therefore deny the same.
`
`2.
`
`Non-Technical Description of the Patented Invention
`
`5.12 To the extent that paragraph 5.12 states legal conclusions regarding the alleged
`
`scope of the ’308 patent, no response is required. To the extent that a response is required, the
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.12 and therefore deny the same.
`
`3.
`
`Foreign Counterparts to the ’308 Patent
`
`5.13 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 5.13 and therefore deny the same.
`
`4.
`
`Licenses
`
`5.14 The Hoover Respondents admit that Confidential Exhibit 40 is a document
`
`
`
`purporting to be a list of licensed entities. The Hoover Respondents lack sufficient knowledge or
`
`information to admit or deny the remaining allegations of paragraph 5.14 and therefore deny the
`
`same.
`
`U.S. Patent No. 8,474,090
`
`C.
`
`
`1.
`
`Identification of the Patent and Ownership by iRobot
`
`5.15 The Hoover Respondents admit that Exhibit 3 is a document purporting to be U.S.
`
`Patent No. 8,474,090 (“the ’090 Patent”) entitled “Autonomous Floor-Cleaning Robot” and
`
`purporting to be issued on July 2, 2013. The Hoover Respondents lack sufficient knowledge or
`13
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`
`
`
`
`PUBLIC VERSION
`
`information to admit or deny the allegations of paragraph 5.15 and therefore deny the same.
`
`5.16 The Hoover Respondents admit that on its face the ’090 patent has three
`
`independent claims and 17 dependent claims. The Hoover Respondents lack sufficient
`
`knowledge or information to admit or deny the remaining allegations of paragraph 5.16 and
`
`therefore deny the same.
`
`5.17 The Hoover Respondents admit that Exhibit 9 contains documents purporting to
`
`be assignments of all right, title and interest in U.S. Patent Application Serial No. 12/201,554
`
`recorded at the United States Patent and Trademark Office at Reel/Frame 0286625/471. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.17 and therefore deny the same.
`
`5.18 The Hoover Respondents admit that Appendices C and I, respectively, purport to
`
`contain: E) a certified copy and three additional copies of the prosecution history of the ’090
`
`Patent; and F) four copies of examiner-cited references mentioned in that prosecution history.
`
`The Hoover Respondents lack sufficient knowledge or information to admit or deny the
`
`allegations of paragraph 5.18 and therefore deny the same.
`
`2.
`
`Non-Technical Description of the Patented Invention
`
`5.19 To the extent that paragraph 5.19 states legal conclusions regarding the alleged
`
`scope of the ’090 patent, no response is required. To the extent that a response is required, the
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.19 and therefore deny the same.
`
`3.
`
`Foreign Counterparts to the ’090 Patent
`
`5.20 The Hoover Respondents admit that paragraph 5.20 contains a table of foreign
`
`
`
`patents and/or patent applications that are allegedly “counterparts” to the [sic] ’553 patent. The
`
`
`
`14
`
`
`
`PUBLIC VERSION
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the remaining
`
`allegations of paragraph 5.20 and therefore deny the same.
`
`4.
`
`Licenses
`
`5.21 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`
`
`deny the allegations of paragraph 5.21 and therefore deny the same.
`
`U.S. Patent No. 8,600,553
`
`D.
`
`
`1.
`
`Identification of the Patent and Ownership by iRobot
`
`5.22 The Hoover Respondents admit that Exhibit 4 is a document purporting to be U.S.
`
`Patent No. 8,600,553 (“the ’553 Patent”) entitled “Coverage Robot Mobility” and purporting to
`
`be issued on December 3, 2013. The Hoover Respondents lack sufficient knowledge or
`
`information to admit or deny the allegations of paragraph 5.22 and therefore deny the same.
`
`5.23 The Hoover Respondents admit that on its face the ’553 patent has three
`
`independent claims and 22 dependent claims. The Hoover Respondents lack sufficient
`
`knowledge or information to admit or deny the remaining allegations of paragraph 5.23 and
`
`therefore deny the same.
`
`5.24 The Hoover Respondents admit that Exhibit 10 contains documents purporting to
`
`be assignments of all right, title and interest in U.S. Patent Application Serial No. 11/758,289
`
`recorded at the United States Patent and Trademark Office at Reel/Frame 020893/176. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.24 and therefore deny the same.
`
`5.25 The Hoover Respondents admit that Appendices D and J, respectively, purport to
`
`contain: G) a certified copy and three additional copies of the prosecution history of the ’553
`
`Patent; and H) four copies of examiner-cited references mentioned in that prosecution history.
`
`
`
`15
`
`
`
`PUBLIC VERSION
`
`The Hoover Respondents lack sufficient knowledge or information to admit or deny the
`
`allegations of paragraph 5.25 and therefore deny the same.
`
`2.
`
`Non-Technical Description of the Patented Invention
`
`5.26 To the extent that paragraph 5.26 states legal conclusions regarding the alleged
`
`scope of the ’553 patent, no response is required. To the extent that a response is required, the
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.26 and therefore deny the same.
`
`3.
`
`Foreign Counterparts to the ’553 Patent
`
`5.27 The Hoover Respondents admit that paragraph 5.27 contains a table of foreign
`
`patents and/or patent applications that are allegedly “counterparts” to the ’553 patent. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.27 and therefore deny the same.
`
`4.
`
`Licenses
`
`5.28 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`
`
`deny the allegations of paragraph 5.28 and therefore deny the same.
`
`U.S. Patent No. 9,038,233
`
`E.
`
`
`1.
`
`Identification of the Patent and Ownership by iRobot
`
`5.29 The Hoover Respondents admit that Exhibit 5 is a document purporting to be U.S.
`
`Patent No. 9,038,233 (“the ’233 Patent”) entitled “Autonomous Floor-Cleaning Robot” and
`
`purporting to be issued on May 26, 2015. The Hoover Respondents lack sufficient knowledge or
`
`information to admit or deny the allegations of paragraph 5.29 and therefore deny the same.
`
`5.30 The Hoover Respondents admit that on its face the ’233 patent has two
`
`independent claims and 19 dependent claims. The Hoover Respondents lack sufficient
`
`knowledge or information to admit or deny the remaining allegations of paragraph 5.30 and
`16
`
`
`
`
`
`PUBLIC VERSION
`
`therefore deny the same.
`
`5.31 The Hoover Respondents admit that Exhibit 11 contains documents purporting to
`
`be assignments of all right, title and interest in U.S. Patent Application Serial No. 13/714,546
`
`recorded at the United States Patent and Trademark Office at Reel/Frame 030046/817. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.31 and therefore deny the same.
`
`5.32 The Hoover Respondents admit that Appendices E and K, respectively, purport to
`
`contain: I) a certified copy and three additional copies of the prosecution history of the ’233
`
`Patent; and J) four copies of examiner-cited references mentioned in that prosecution history.
`
`The Hoover Respondents lack sufficient knowledge or information to admit or deny the
`
`allegations of paragraph 5.32 and therefore deny the same.
`
`2.
`
`Non-Technical Description of the Patented Invention
`
`5.33 To the extent that paragraph 5.33 states legal conclusions regarding the alleged
`
`scope of the ’233 patent, no response is required. To the extent that a response is required, the
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.33 and therefore deny the same.
`
`3.
`
`Foreign Counterparts to the ’233 Patent
`
`5.34 The Hoover Respondents admit that paragraph 5.34 contains a table of foreign
`
`patents and/or patent applications that are allegedly “counterparts” to the ’233 patent. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.34 and therefore deny the same.
`
`4.
`
`Licenses
`
`5.35 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`
`
`deny the allegations of paragraph 5.35 and therefore deny the same.
`
`
`
`17
`
`
`
`PUBLIC VERSION
`
`U.S. Patent No. 9,486,924
`
`F.
`
`
`1.
`
`Identification of the Patent and Ownership by iRobot
`
`5.36 The Hoover Respondents admit that Exhibit 6 is a document purporting to be U.S.
`
`Patent No. 9,486,924 (“the ’924 Patent”) entitled “Remote Control Scheduler and Method for
`
`Autonomous Robotic Device” and purporting to be issued on November 8, 2015. The Hoover
`
`Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.36 and therefore deny the same.
`
`5.37 The Hoover Respondents admit that on its face the ’924 patent has two
`
`independent claims and 17 dependent claims. The Hoover Respondents lack sufficient
`
`knowledge or information to admit or deny the remaining allegations of paragraph 5.37 and
`
`therefore deny the same.
`
`5.38 The Hoover Respondents admit that Exhibit 12 contains documents purporting to
`
`be assignments of all right, title and interest in U.S. Patent Application Serial No. 14/670,572
`
`recorded at the United States Patent and Trademark Office at Reel/Frame 035655/501. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.38 and therefore deny the same.
`
`5.39 The Hoover Respondents admit that Appendices F and L, respectively, purport to
`
`contain: K) a certified copy and three additional copies of the prosecution history of the ’924
`
`Patent; and L) four copies of examiner-cited references mentioned in that prosecution history.
`
`The Hoover Respondents lack sufficient knowledge or information to admit or deny the
`
`allegations of paragraph 5.39 and therefore deny the same.
`
`2.
`
`Non-Technical Description of the Patented Invention
`
`5.40 To the extent that paragraph 5.40 states legal conclusions regarding the alleged
`
`scope of the ’924 patent, no response is required. To the extent that a response is required, the
`18
`
`
`
`
`
`PUBLIC VERSION
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.40 and therefore deny the same.
`
`3.
`
`Foreign Counterparts to the ’924 Patent
`
`5.41 The Hoover Respondents admit that paragraph 5.34 contains a table of foreign
`
`patents and/or patent applications that are allegedly “counterparts” to the ’924 patent. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the remaining
`
`allegations of paragraph 5.41 and therefore deny the same.
`
`4.
`
`Licenses
`
`5.42 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`
`
`deny the allegations of paragraph 5.42 and therefore deny the same.
`
`VI.
`
`
`SPECIFIC INSTANCES OF UN
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