PTAB

IPR2014-00136

Reloaded v. Parallel Networks LLC

Key Events

Petition

petition

Title: Dynamic Distributed Data Caching
Brief Description: The ’145 patent describes a method and system for dynamic data caching within a community network. The technology allows clients to join a "cache community" of peers, after which a peer list is updated to include the new client, and content storage is re-allocated among the peers in response to the new client's joinder.

Prior Art Relied Upon: Tiwana (Patent 7,069,324), which incorporates by reference U.S. Provisional Application No. 60/168,862.
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Tiwana discloses every limitation of the challenged claims. Tiwana teaches a distributed web-caching structure comprising a "web-cache cluster" or "Server Group" of peers. It explicitly describes a process where new cache systems (clients) join the cluster by sending a "Here I Am" message (a join request), after which the router updates a list of usable web-caches (a peer list) to include the new member. In response to a change in group membership, Tiwana teaches re-allocating or re-assigning traffic "buckets" (content) among the cluster members to balance the load, directly corresponding to the ’145 patent's claimed re-allocation of cache storage.

Prior Art Relied Upon: Smith (Patent 6,341,311).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Smith, which was not considered during prosecution, discloses a distributed data caching scheme using an array of proxy servers acting as a single distributed cache. Smith teaches a method for adding a new proxy server (a client) to the array. Upon joining, an "array membership list" (a peer list) is updated and propagated among all members. Critically, Smith teaches that when a new server is added, URL data object assignments are automatically changed via a hashing algorithm, causing content to be "moved or migrated" to the new server, which Petitioner argued is the same as the ’145 patent's claimed re-allocation of content.

Prior Art Relied Upon: Smith (Patent 6,341,311) and Inohara (Patent 6,256,747).
Core Argument for this Ground:
- Prior Art Mapping: Smith was asserted to teach the foundational distributed caching system where new servers can join an array, receive an updated peer list, and cause content to be re-allocated. Inohara was cited for its teaching of a method for managing distributed servers, where a new server can discover existing server groups by requesting a "group table transfer" from a known server (an administration module) and then select a group to join based on performance metrics like proximity or throughput.
- Motivation to Combine: A POSITA would combine Inohara's server discovery and selection mechanism with Smith's caching array to improve the scalability and efficiency of Smith's system. Smith teaches adding a server but provides limited detail on how a new server discovers the array; Inohara provides this missing functionality, teaching a method for servers to find and join optimal cache groups.
- Expectation of Success: Combining the references would involve implementing a known network discovery protocol (from Inohara) into an existing distributed cache architecture (from Smith), which would have yielded the predictable result of a more scalable and robust caching system.

Prior Art Relied Upon: Tiwana (Patent 7,069,324) and Inohara (Patent 6,256,747).
Core Argument for this Ground:
- Prior Art Mapping: This ground mirrors the logic of Ground 3, but uses Tiwana as the primary reference. Tiwana provides the base distributed "web-cache cluster" and the process for a new cache system to join it. Inohara again supplies the teaching of a server requesting a list of available cache groups from an administrative server and then selecting one to join.
- Motivation to Combine: A POSITA would have been motivated to enhance Tiwana's system with Inohara's teachings to allow cache systems to dynamically discover and choose from multiple available cache clusters, rather than being pre-configured for a single one. This would increase the flexibility and overall effectiveness of the caching network described in Tiwana.
- Expectation of Success: The combination was argued to be a straightforward application of Inohara's group discovery method to Tiwana's caching cluster, with a high and predictable likelihood of success.

Specific Data Messages: Petitioner argued that terms like “CRMSG_REQUESTTOJOIN” (claim 3) and “CRMSG_UPDATEPEERLIST” (claim 6) should be limited to the specific message types of the proprietary "Dynamic Reef Protocol (DRP)" disclosed in the ’145 patent. However, for the purposes of the petition, Petitioner adopted the Examiner's broader interpretation from prosecution and argued the prior art teaches data messages that meet even this broader construction.
Means-Plus-Function Terms: Petitioner contended that numerous limitations in claims 35 and 36 are means-plus-function limitations under 35 U.S.C. § 112, ¶6. For each, Petitioner proposed a construction identifying the claimed function (e.g., "allowing a client to join the cache community") and argued that the corresponding structure disclosed in the specification is a general-purpose computer programmed to perform that function. Petitioner then mapped the prior art to these construed functions and structures.

Petitioner requests the institution of an inter partes review and the cancellation of claims 1-36 of the ’145 patent as unpatentable under 35 U.S.C. §§ 102 and 103.