US 11076735

A comprehensive analysis of United States Patent 11,076,735 reveals a detailed invention related to a "Surface cleaning apparatus," assigned to Bissell Inc. The patent has been the subject of recent legal proceedings, culminating in a decision by the U.S. Court of Appeals for the Federal Circuit.

Patent Details:

• Title: Surface cleaning apparatus
• Assignee: Bissell Inc.
• Inventors: Jacob Resch, Jacob S. Boles
• Filing Date: September 10, 2020
• Issue Date: August 3, 2021
• Abstract: The patent describes a surface cleaning apparatus that includes a storage tray for a self-cleaning mode and for drying a brushroll. A key feature is that the self-cleaning mode can only be activated when the apparatus is docked on the storage tray. When a "cleanout" or self-cleaning cycle is initiated via a user control, the battery charging is disabled.

Plain-Language Overview of Independent Claims:

U.S. Patent 11,076,735 contains two independent claims, which are the broadest claims in the patent and define the core of the invention.

• Independent Claim 1: This claim describes a complete floor cleaning system. It includes a surface cleaning apparatus with a fluid delivery and recovery system, a rechargeable battery, and a battery charging circuit. A crucial element is a user interface with a "self-cleaning mode input control" that starts an automatic "cleanout cycle." The system also includes a cleaning tray for docking the apparatus for both recharging and self-cleaning. The inventive step outlined in this claim is that the battery charging circuit is intentionally disabled during this automatic cleanout cycle.

• Independent Claim 13: This claim outlines a method for self-cleaning the surface cleaning apparatus when it is docked on its cleaning tray, which is also capable of recharging the device's battery. The method involves:

  1. Starting a self-cleaning mode.
  2. Disabling the battery charging circuit during the cleaning cycle.
  3. Running an automatic "cleanout cycle" to clean at least a part of the dirty fluid recovery path.

In essence, both independent claims focus on the interaction between the cleaning apparatus and its docking station, where the self-cleaning operation and battery charging are mutually exclusive. This prevents both power-intensive operations from occurring simultaneously.

Litigation:

This patent was recently the subject of a legal dispute. In the case of Bissell, Inc. v. International Trade Commission, the U.S. Court of Appeals for the Federal Circuit affirmed a decision by the International Trade Commission (ITC). The ITC had initially found that certain products from Tineco infringed on Bissell's patent. However, Tineco redesigned their products with a firmware update. This update altered the self-cleaning cycle so that the battery charging circuit would activate briefly twice during the cycle, rather than remaining disabled throughout the entire process. The court agreed with the ITC's determination that these redesigned products no longer infringed on the claims of U.S. Patent 11,076,735 because the charging circuit was not "disabled" for the duration of the "unattended automatic cleanout cycle" as specified in the patent's claims.

Litigation History for U.S. Patent 11,076,735

As of today's date, May 12, 2026, U.S. Patent 11,076,735 has been involved in several legal disputes. The following is a list of known litigation involving this patent.

1. U.S. Court of Appeals for the Federal Circuit

• Plaintiff: Bissell Inc.

• Defendant: International Trade Commission

• Intervenor: Tineco Intelligent Technology Co., Ltd.

• Jurisdiction: Court of Appeals for the Federal Circuit

• Case Number: 24-1509

• Filing Date: The record for this specific appeal was established from the preceding ITC investigation.

• Status: Decided. The court affirmed the International Trade Commission's ruling that Tineco's redesigned products, which feature a firmware update allowing for brief battery charging during the self-clean cycle, do not infringe on Bissell's patent.

• Plaintiff: Bissell Inc.

• Defendant: International Trade Commission

• Intervenor: Tineco Intelligent Technology Co., Ltd., et al.

• Jurisdiction: Court of Appeals for the Federal Circuit

• Case Number: 24-1709

• Filing Date: The record for this specific appeal was established from the preceding ITC investigation.

• Status: Active/Pending.

2. U.S. International Trade Commission (ITC)

• Complainant: Bissell Inc.

• Respondents: Tineco Intelligent Technology Co., Ltd. and others.

• Jurisdiction: International Trade Commission

• Investigation Number: 337-TA-1304

• Filing Date: The investigation was instituted based on a complaint filed by Bissell.

• Status: The ITC initially found that Tineco's products infringed the patent but later determined that redesigned products with a firmware modification did not infringe. This decision was the subject of the appeal to the Federal Circuit (Case No. 24-1509).

• Complainant: Bissell Inc.

• Respondents: Multiple parties.

• Jurisdiction: International Trade Commission

• Investigation Number: 337-TA-3601

• Filing Date: Details on the filing date are part of the ITC record.

• Status: The record indicates a case was filed, but further details on the specific timeline and outcome require a deeper search of the ITC's EDIS database.

3. U.S. District Court

• Plaintiff: Bissell Inc.
• Defendant: Tineco Intelligent Technology Co., Ltd.
• Jurisdiction: Delaware District Court
• Case Number: 1:22-cv-00150
• Filing Date: The case was filed in early 2022.
• Status: The proceedings in this district court case were likely stayed pending the outcome of the parallel investigation at the International Trade Commission. The current status would be influenced by the Federal Circuit's recent decision.

As a senior PTAB practitioner analyzing U.S. Patent 11,076,735, the primary finding is that there is no record of any America Invents Act (AIA) trial proceedings having been filed against this patent.

Proceedings overview

There have been zero AIA trial proceedings filed against U.S. Patent 11,076,735. This provides a defendant with a completely open field for a potential validity challenge at the Patent Trial and Appeal Board (PTAB), as no claims have been previously litigated, invalidated, or sustained in this forum.

No PTAB proceedings were found for U.S. Patent 11,076,735.

Strategic summary

• Claim Status: All claims of U.S. Patent 11,076,735 remain as they were granted by the USPTO. No claims have been CANCELED, and none have been officially deemed patentable in the face of a PTAB challenge (SUSTAINED). All claims are currently UNTESTED before the PTAB.

• Estoppel Landscape: For a defendant currently facing an infringement assertion, the path to filing an Inter Partes Review (IPR) is clear. There are no estoppel limitations under 35 U.S.C. § 315(e)(2) from prior PTAB proceedings. A new petitioner is free to raise any invalidity ground based on prior art patents or printed publications that they can find.

• Pattern Signals: The absence of PTAB challenges is significant. It may indicate that previous disputes settled before reaching the PTAB or that potential challengers have not yet identified prior art they believe would succeed in an IPR. The patent owner, Bissell Inc., has shown a willingness to aggressively defend its intellectual property in district court and at the International Trade Commission (ITC), which might deter some from filing PTAB petitions.

Recommended next steps

For a defendant accused of infringing U.S. Patent 11,076,735, the absence of prior PTAB activity presents a clear opportunity.

• Conduct a Prior Art Search: A comprehensive search for prior art that predates the January 8, 2019, priority date should be the immediate first step. The focus should be on art that teaches the core concept of the independent claims: a surface cleaning system with a docking station that performs a self-cleaning or "cleanout" cycle, wherein the battery charging function is disabled during that cycle.

• Consider Filing an IPR: If strong prior art is uncovered, filing an IPR petition is a highly recommended defensive measure. An IPR offers a faster and often less expensive path to invalidating patent claims compared to district court litigation. Furthermore, the standard of proof is a "preponderance of the evidence," which is lower than the "clear and convincing evidence" standard required in a district court.

• Key Takeaway: The lack of PTAB history for this patent means that a well-supported IPR petition would be the first test of its validity in this specialized forum. While the patent has been successfully asserted in other venues against specific products, its resilience against a dedicated prior art challenge at the PTAB remains unknown. This provides a significant strategic opening for any currently accused infringer.

Inventors

• Jacob Resch: Based on the assignment record, an inventor employed by Bissell Inc. at the time of invention.
• Jacob S. Boles: Based on the assignment record, an inventor employed by Bissell Inc. at the time of invention.

There are no unusual patterns noted, such as the inventors departing the company. The assignment to the employer is a standard pre-filing procedure.

Original assignee

The original assignee is Bissell Inc., a privately-owned American vacuum cleaner and floor care product manufacturing corporation headquartered in Walker, Michigan. Bissell is a well-known operating company that has been in business since 1876. It actively manufactures and sells a wide range of surface cleaning products, including multi-surface wet/dry vacuum cleaners that appear to embody the claims of the patent, such as their "CrossWave" product line. The company is currently operating.

Assignment timeline

A search of the USPTO Patent Assignment Search database reveals only one recorded assignment for this patent.

• 2020-09-08 (executed) / recorded 2020-09-10 — Reel 202009/007421
  • Conveyance: Assignment of Assignors Interest
  • Assignor: Jacob Resch; Jacob S. Boles
  • Assignee: Bissell Inc.
  • Correspondent: Michael G. Johnston, Esq., Bissell Inc., 2345 Walker Avenue, N.W., Grand Rapids, MI 49544
  • Context: This is a standard pre-filing assignment of invention rights from the employees (inventors) to their employer.

No post-issuance assignments have been recorded. Bissell Inc. has remained the owner of the patent since its issuance.

Timeline diagram

timeline
    title Ownership of US 11076735
    2019 : Priority Date
    2020 : Filed by Bissell Inc
         : Inventors assign to Bissell
    2021 : Issued to Bissell Inc
    2022 : Bissell files suit vs Tineco

NPE / troll-pattern signals

1. Shell-entity transfer: Not present. The patent has remained with the original assignee, Bissell Inc., an active operating company, since issuance.
2. Known asserter in the chain: Not present. The only assignee is Bissell Inc., an operating company.
3. Repeat correspondent across the chain: Not present. There has only been one assignment recorded.
4. Cascading transfers: Not present.
5. Pre-litigation transfer: Not present. The patent was not transferred prior to the litigation filed by Bissell Inc. in 2022.
6. Bankruptcy fire-sale: Not present.
7. Privateering: Not present. Bissell Inc. is asserting the patent directly on its own behalf.
8. Defensive aggregator (anti-NPE): Not present.

Verdict

Operating-company assertion

This patent is owned by its original assignee, Bissell Inc., a major manufacturer of floor-care products. The recorded litigation shows Bissell asserting the patent directly against a market competitor, Tineco, which also sells products in the same category. All evidence indicates that this is a case of a manufacturing company enforcing its intellectual property against a direct competitor, which is characteristic of an operating-company assertion, not NPE activity.

A direct link to the USPTO assignment records for this patent can be found at: https://assignment.uspto.gov/patent/index.html#/patent/search/result?patentNum=11076735

Prior Art Analysis for U.S. Patent 11,076,735

Here is an analysis of the most relevant prior art cited during the prosecution of U.S. Patent 11,076,735. The key inventive concept of the patent, as defined in independent claims 1 and 13, is a surface cleaning system where the apparatus, when docked on a cleaning and charging tray, will disable the battery charging circuit while it performs an automatic self-cleaning "cleanout cycle." For a prior art reference to anticipate a claim under 35 U.S.C. § 102, it must disclose every element of that claim in a single document.

1. U.S. Patent Application Publication No. US 2018/0344070 A1

• Full Citation: US 2018/0344070 A1; Stoll, et al. (Assignee: Kärcher).
• Publication Date: December 6, 2018 (Filed: May 30, 2018).
• Brief Description: This document describes a wet-cleaning device with a base station. The base station is designed to receive the cleaning device for storage and also for performing a cleaning process on the device's cleaning roller. The base station includes a flushing fluid tank and a suction device to draw the dirty water away from the roller. The system contemplates both charging the battery and cleaning the roller within the base station.
• Potential Anticipation of Claims: None. This reference is highly relevant as it discloses a surface cleaner with a docking station that performs a self-cleaning cycle on a brushroll. It explicitly mentions that the base station can be equipped with a charging device for charging the battery of the wet-cleaning device. However, Stoll fails to teach or suggest the critical limitation of the '735 patent: disabling the battery charging circuit during the self-cleaning cycle. Stoll describes the functions of cleaning and charging as capabilities of the base station but does not disclose a mode where one is deactivated for the other to proceed. Therefore, it does not anticipate claims 1 or 13.

2. U.S. Patent No. 10,092,155 B2

• Full Citation: US 10,092,155 B2; Grey, et al. (Assignee: Bissell Inc.).
• Issue Date: October 9, 2018 (Filed: December 1, 2016).
• Brief Description: This patent, also assigned to Bissell, is incorporated by reference in the '735 patent. It describes the foundational structure of a multi-surface wet vacuum cleaner, including details of the fluid delivery system, recovery system, and a hybrid brushroll suitable for both hard and soft surfaces. It provides the general mechanical and operational context for the apparatus described in the '735 patent.
• Potential Anticipation of Claims: None. While this patent describes the type of surface cleaning apparatus in detail, it does not disclose a docking station with a self-cleaning mode, nor does it mention any interaction between a self-cleaning cycle and a battery charging circuit. Its focus is on the cleaning apparatus itself during normal floor-cleaning operation. As it is missing the entire concept of a self-cleaning cycle in a tray where charging is disabled, it cannot anticipate claims 1 or 13.

3. U.S. Patent Application Publication No. US 2017/0055848 A1

• Full Citation: US 2017/0055848 A1; Grey, et al. (Assignee: Bissell Inc.).
• Publication Date: March 2, 2017 (Filed: August 31, 2015).
• Brief Description: An earlier application from the same assignee, this document also describes a multi-surface cleaning apparatus with fluid delivery and recovery systems. It details features like a removable nozzle, brushroll assembly, and tank configurations. This publication provides background and foundational technology for the apparatus later improved upon in the '735 patent.
• Potential Anticipation of Claims: None. Similar to US 10,092,155 B2, this reference describes the core cleaning machine but lacks any disclosure of a self-cleaning mode performed in conjunction with a storage or charging tray. The inventive concept of disabling a battery charging circuit during such a cycle is entirely absent. Therefore, it does not anticipate claims 1 or 13.

4. U.S. Patent Application Publication No. US 2018/0177372 A1

• Full Citation: US 2018/0177372 A1; Han, et al. (Assignee: [LG Electronics Inc.](/litigations/by-plaintiff/LG%20Electronics%20Inc.)).
• Publication Date: June 28, 2018 (Filed: December 22, 2017).
• Brief Description: This publication discloses a cleaning robot and a charging station. The charging station includes a cleaning unit for automatically cleaning the robot's brushes after it docks. The robot docks, connects to charging terminals, and then a cleaning process involving water supply and suction can be initiated to clean the robot's components.
• Potential Anticipation of Claims: None. This reference teaches a device that combines docking for charging and a self-cleaning function. However, it does not disclose the specific limitation of disabling the charging function while the cleaning takes place. In fact, it suggests these operations can be concurrent. Without the express teaching of disabling the battery charging circuit during the cleanout cycle, it does not anticipate the key element of claims 1 and 13.

5. U.S. Patent Application Publication No. US 2018/0255938 A1

• Full Citation: US 2018/0255938 A1; Oh, et al. (Assignee: LG Electronics Inc.).
• Publication Date: September 13, 2018 (Filed: March 9, 2018).
• Brief Description: This document describes a hand-held cleaner with a docking station or "cradle." The cradle is capable of charging the cleaner's battery and also has a function for cleaning the filter of the handheld cleaner using a suction motor within the cradle itself.
• Potential Anticipation of Claims: None. While this reference discloses a docking station that performs both charging and a type of self-maintenance (filter cleaning), it does not teach disabling the charging process during the cleaning cycle. The core novelty of the '735 patent—the specific control logic of disabling the charging circuit while the self-clean cycle runs—is not present. Therefore, this reference does not anticipate claims 1 or 13.

Summary of Prior Art Analysis

The prior art cited against U.S. Patent 11,076,735 establishes that the concepts of wet/dry surface cleaners, docking stations, battery charging, and even self-cleaning cycles within a docking station were known in the art before the '735 patent's priority date. However, none of the examined references disclose the specific, central limitation of claims 1 and 13: the functional step of disabling the battery charging circuit during the automatic self-cleaning cycle. It is this specific control method, which prevents two high-power-draw events from occurring simultaneously, that appears to be the novel and non-obvious contribution recognized by the USPTO during examination. The litigation outcome against Tineco's redesigned products further reinforces that this "disabling" limitation is the critical point of novelty for the patent.

Obviousness Analysis of U.S. Patent 11,076,735 under 35 U.S.C. § 103

This analysis evaluates whether the invention claimed in U.S. Patent 11,076,735 would have been obvious to a Person Having Ordinary Skill in the Art (PHOSITA) at the time the invention was made. A PHOSITA in this context would be an engineer or product designer with experience in floor care appliances, particularly in the design of battery-powered devices, electrical power management systems, and embedded controls.

The core inventive concept, as defined by independent claims 1 and 13, is a surface cleaning system with a docking station that performs an automated self-cleaning cycle, during which the battery charging function is disabled. The analysis below combines prior art references to argue that this concept would have been an obvious design choice.

Primary Obviousness Combination: US 2018/0344070 (Stoll) in view of General Engineering Principles of Power Management

1. Base Reference: US 2018/0344070 A1 (Stoll)

• What Stoll Discloses: Stoll is the most relevant prior art as it teaches a system that includes nearly all the elements of the '735 patent's independent claims. Specifically, Stoll describes:

  • A wet-cleaning device (a surface cleaning apparatus).
  • A base station (a cleaning tray) for receiving the device.
  • A system for performing a self-cleaning process on the device's cleaning roller (a brushroll) when docked.
  • The capability for the base station to charge the battery of the wet-cleaning device.

• What Stoll Fails to Disclose: Stoll does not explicitly teach or suggest disabling the battery charging circuit during the self-cleaning cycle. It presents these as two functions the base station can perform, but is silent on their interaction or temporal relationship.

2. Motivation to Modify Stoll

A PHOSITA would have been motivated to modify the system disclosed by Stoll for clear and predictable reasons related to fundamental power and thermal management. The self-cleaning cycle, as described in both Stoll and the '735 patent, involves energizing at least a pump and a motor to flush and suction the brushroll assembly. These are power-intensive operations. Simultaneously charging a modern rechargeable battery, such as a lithium-ion battery, is also a significant power draw.

A PHOSITA would recognize several predictable problems with running both high-power systems concurrently:

• Power Supply Limitation and Cost: A power adapter for the docking station would need to be sized to handle the combined peak load of the cleaning cycle motors/pumps and the battery charging circuit. This would require a larger, more expensive, and less common power adapter. A more efficient and cost-effective design would be to use a smaller power adapter capable of handling each function individually but not simultaneously.
• Thermal Management: Both running motors and charging batteries generate significant heat. Operating both systems at the same time in a compact docking station would create a concentration of heat, potentially exceeding the safe operating temperatures of the battery or other electronic components. A PHOSITA would be motivated to sequence these operations to mitigate thermal stress and improve safety and product longevity.
• Optimizing Battery Charging: Battery management systems (BMS) for lithium-ion and other rechargeable batteries often follow specific charging profiles (e.g., constant current, constant voltage) to ensure battery health and safety. The large, fluctuating power demands of the cleaning cycle's motors could interfere with the charging algorithm, leading to inefficient charging or potential damage to the battery. Disabling charging during the cleanout cycle would ensure a stable and optimal charging process once the cleaning is complete.

3. Application to the Claims

• Obviousness of Independent Claim 1 (The System):
  Stoll provides the blueprint for the claimed system: a surface cleaner (claim 1(a)) and a cleaning/charging tray (claim 1(b)). Stoll's system includes a fluid delivery system, recovery system, rechargeable battery, a battery charging circuit, and implicitly requires a controller to manage its automated cleaning functions. The only missing element is the specific control logic wherein the "controller...is further configured to disable the battery charging circuit during the automatic cleanout cycle."

  Given the motivations of cost reduction, thermal management, and improved battery health, it would have been an obvious design choice for a PHOSITA to program the controller in Stoll's device to manage the power loads. The simplest and most direct way to achieve this is to prevent the two most power-intensive operations—self-cleaning and battery charging—from running concurrently. Therefore, modifying Stoll's controller to disable the charging circuit upon initiation of the self-clean cycle would be a predictable implementation of a known engineering solution to a known problem.

• Obviousness of Independent Claim 13 (The Method):
  The argument for the method claim is parallel. Stoll teaches the initial steps of the method: docking a surface cleaning apparatus at a cleaning tray that can recharge the battery (claim 13 preamble) and initiating a self-cleaning mode of operation (claim 13(a)). For the reasons outlined above, it would have been obvious for a PHOSITA to add the step of "disabling a battery charging circuit that controls recharging of the battery during the cleanout cycle" (claim 13(b)) before running the cleanout cycle (claim 13(c)). This represents a routine optimization of the device's operation, not an inventive leap.

Secondary Obviousness Combination: Stoll in view of US 2018/0177372 (Han) or US 2018/0255938 (Oh)

The other cited references from LG (Han and Oh) reinforce the state of the art. They both teach docking stations that combine charging with an automated maintenance/cleaning function (cleaning brushes in Han, cleaning a filter in Oh).

While these references also fail to teach the specific "disabling" step, they establish a clear trend in the industry toward creating multifunctional docking stations that both charge and maintain cleaning appliances. A PHOSITA looking at Stoll's system would be aware of this trend and would consider the practical engineering challenges of implementing these combined functions. This context further supports the motivation to apply standard power management techniques, such as load sequencing (i.e., disabling one function while another runs), to create a reliable and cost-effective product.

Conclusion

The independent claims of U.S. Patent 11,076,735 would have been obvious under 35 U.S.C. § 103. The primary reference, Stoll (US 2018/0344070 A1), discloses all major structural and functional elements of the claimed system and method, short of the specific control logic of disabling the charging circuit during the self-clean cycle. A person of ordinary skill in the art would have been motivated to add this specific control feature to Stoll’s system to solve predictable and well-understood problems of power supply sizing, thermal management, and battery health. This modification represents the application of routine engineering principles to a known system to achieve a predictable result, and therefore lacks an inventive step.