PTAB

IPR2014-00950

Reloaded Games Inc v. Parallel Networks LLC

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Method and System for Dynamic Distributed Data Caching
  • Brief Description: The ’145 patent describes a method and system for caching data within a community network to improve data retrieval efficiency. The technology allows clients to join a "cache community" of peers, which triggers an update to a peer list and a re-allocation of cache storage among the community members.

3. Grounds for Unpatentability

Ground 1: Claims 1, 4-5, 8-9, 11-15, 18-19, 22-23, and 25-28 are obvious over Smith in view of Inohara under 35 U.S.C. §103.

  • Prior Art Relied Upon: Smith (Patent 6,341,311) and Inohara (Patent 6,256,747).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of Smith and Inohara teaches every limitation of the challenged claims. Smith, which was not considered during prosecution, was asserted to disclose the core architecture of a distributed data caching scheme using an "array of proxy servers" that functions as the claimed "cache community." Smith taught a method for adding a new proxy server (a "client") to this array. Upon joinder, Smith's system updates and communicates an "array membership list" (a "peer list") among all members. Crucially, Petitioner argued that Smith disclosed the re-allocation of content by teaching that when the array membership changes, a deterministic hashing algorithm automatically changes the assignments of URL data objects. This causes content to be migrated to, or associated with, the newly joined server, thereby "re-allocating the cache storage"—the very limitation upon which the patent was granted.

      Petitioner contended that Inohara complemented Smith by disclosing a distributed caching infrastructure where servers can dynamically search for and join different server groups ("communities"). Inohara explicitly taught a group leader determining whether to "permit the presence of" a new server based on member capacity, directly mapping to the "allowing a client to join" limitation. For dependent claims, Petitioner argued Inohara taught the "generating an allow message" and "communicating the allow message" limitations of claims 4 and 5 through its disclosure of a leader creating and transmitting a "group update message" to the new server upon permitting it to join. The combination of Smith’s updated membership list with Inohara’s allow message was argued to teach claim 5’s limitation of an allow message comprising an updated peer list. Further, dependent claim limitations such as the point of presence being an ISP (claim 8) were argued to be disclosed by both references as the conventional environment for such caching systems.

    • Motivation to Combine: Petitioner asserted that a POSITA would combine the teachings of Smith and Inohara to improve the functionality of distributed caching systems, a well-known goal in the art. The motivation was to integrate Inohara’s flexible mechanism for forming and joining cache groups with Smith’s robust method for managing data within such a group. This combination would create a more effective and scalable system, a "large-scale cache that extends over a plurality of servers," directly addressing the known problem of increased internet response times that both references sought to solve. The combination simply applied Inohara's known technique for joining a group to Smith's known type of server group.

    • Expectation of Success: The petition argued that a POSITA would have had a reasonable expectation of success in this combination. Both references operate in the same technical field of distributed network caching, use similar client-server architectures, and aim to solve the identical problem of reducing data access latency. Therefore, integrating Inohara's group-joining protocol with Smith's data-management protocol was presented as a straightforward application of known principles that would have yielded the predictable result of a more scalable and efficient caching network.

4. Key Claim Construction Positions

  • Petitioner adopted claim constructions previously rendered by the Board in a related IPR (IPR2014-00136) involving the same patent, arguing they represented the broadest reasonable interpretation.
  • “allowing” and “allow”: Construed as "to permit the presence of." This construction was central to Petitioner's argument that Inohara's disclosure of a leader server deciding whether a new server can participate in a group—based on whether the total number of members exceeds a maximum—met the claim limitation.
  • “cache community” and “community”: Construed to mean "similarity or identity" or "sharing, participation, and fellowship." Petitioner relied on this broad construction to argue that the distinct technical structures described in the prior art—Smith’s "array of proxy servers" and Inohara’s "group of servers"—both fell within the scope of the claimed "community."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 4-5, 8-9, 11-15, 18-19, 22-23, and 25-28 of Patent 7,188,145 as unpatentable.