PTAB

IPR2013-00440

Dell Inc v. Acceleron LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Cluster Component Network Appliance System and Method for Enhancing Fault Tolerance and Hot-Swapping
  • Brief Description: The ’021 patent describes a computer network appliance designed for high availability, comprising a backplane and multiple hot-swappable modules, including CPU modules, power modules, and ethernet switch modules. The system allows these components to be shared resources, enhancing fault tolerance and enabling component replacement without system downtime.

3. Grounds for Unpatentability

Ground 1: Anticipation - Claims 1–4, 6–9, 13–20, and 22–24 are anticipated by Hipp

  • Prior Art Relied Upon: Hipp (Patent 6,757,748).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hipp, which was not considered during prosecution, discloses every element of the challenged claims. Hipp describes a high-density modular server system with a chassis containing a plurality of hot-swappable "web server processing cards" (CPU modules) that function as independent, single-board computers. The system also includes hot-swappable power supplies and switched network interface cards connected to a midplane (backplane), which distributes power and data signals, allowing these components to be used as shared resources. Further, Hipp allegedly discloses a microcontroller module (a "single board computer" on a management network interface) that remotely polls the health of other components via a dedicated ethernet path, as required by claim 20. Hipp also discloses remote booting from network-attached storage (NAS) and an embodiment without local hard drives, anticipating claims related to remote booting and increased system reliability.

Ground 2: Obviousness over Hipp in view of Gasparik - Claims 10–12, 30, and 34–36

  • Prior Art Relied Upon: Hipp (Patent 6,757,748) and Gasparik (Patent 6,157,974).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims requiring a specific sequence of pin connections in hot-swap connectors (ground first, then pre-charge power, then power, then signal). Petitioner contended that while Hipp discloses hot-swappable connectors, Gasparik explicitly teaches a hot-swappable connector with four different pin lengths to achieve this exact sequential connection. The purpose of this staged connection in Gasparik is to provide electrostatic discharge (ESD) protection and prevent electrical issues during hot-swapping.
    • Motivation to Combine: A POSITA would combine Hipp’s modular server system with Gasparik’s staged connector design to implement robust ESD protection. Since both references address the technical challenges of hot-pluggable systems, combining a known solution for ESD protection (Gasparik) with a modular server architecture (Hipp) would have been a simple and logical design choice.
    • Expectation of Success: The combination involved applying a known connector design principle to improve the reliability of a known type of system, which would have been a predictable and straightforward modification with a high expectation of success.

Ground 3: Obviousness over Hipp in view of the SCSI Standard - Claims 8 and 9

  • Prior Art Relied Upon: Hipp (Patent 6,757,748) and the SCSI Standard (SFF-8046 Specification for 80-pin SCA-2 Connector).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground focused on claims requiring hot-swap connectors to include specific pin types: ground, pre-charge power, power, and signal pins. Petitioner argued that Hipp explicitly discloses the use of "80 pin SCA connectors." The SCSI Standard, which is the public industry specification for that exact connector, details the complete pinout, including designated pins for ground, pre-charge power ("12V CHARGE"), power, and signals. Therefore, the combination of Hipp's disclosure and the standard it references teaches all required elements.
    • Motivation to Combine: A POSITA, when implementing the system described in Hipp, would have been directly motivated to consult the publicly available SCSI Standard to determine the proper pin assignments and electrical characteristics of the specified "80 pin SCA connector." This is a routine step in engineering design.
    • Expectation of Success: There would be a very high expectation of success, as this combination merely involves implementing a component according to its established and universally accepted industry standard.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 10–12 based on the combination of Hipp, the SCSI Standard, and Gasparik, arguing these references together teach the required pin types and their sequential connection.

4. Key Claim Construction Positions

  • "Independently-Functioning Computer": Petitioner argued this term, added during prosecution to overcome prior art, should be construed as a computer that "functions independently of the operations or functions of any other CPU in the computer network appliance." This construction was central to distinguishing the claimed invention from prior art systems where processors operated in a master/slave relationship.
  • "Stand-Alone Computer": Petitioner proposed that "wherein each CPU module is a stand-alone...computer" (claim 1) should be construed to mean "wherein each CPU module is capable of operating as a stand-alone computer." This construction was argued to be necessary to encompass the patent’s own disclosure, which describes modules that function as part of a larger system but have the capability to operate alone, and to ensure the broader independent claim properly covered the narrower dependent claim 13, which recites a module that "operates as a stand-alone computer."

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1–4, 6–20, 22–24, 30, and 34–36 of the ’021 patent as unpatentable.