PTAB

IPR2015-00013

Edmit Industries Inc v. SmartDoor Holdings Inc

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1. Case Identification

2. Patent Overview

  • Title: Network having simplified data packet header
  • Brief Description: The ’290 patent discloses a communication system designed to improve data routing efficiency by using simplified data packet headers. The technology replaces full destination and source network addresses with shorter, locally significant "super-header" information that network nodes use to forward packets according to pre-established routing tables.

3. Grounds for Unpatentability

Ground 1: Obviousness over Newman in view of Tanaka - Claims 1-5, 8-11, 20-24, 27-29, and 47-50 are obvious over Newman in view of Tanaka.

  • Prior Art Relied Upon: Newman (Patent 5,519,704) and Tanaka (Patent 5,689,504).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Newman discloses a base communication system with all major elements of independent claim 1, including a network with multiple nodes, data packets, and routing tables. Newman’s system uses "virtual circuit identifiers" (VCIs) as simplified headers to route data, which Petitioner contended is analogous to the ’290 patent's "super-header." While Newman teaches updating routing tables, Petitioner asserted that Tanaka teaches a more specific and advantageous method for dynamically updating routing tables in response to network changes, as required by several dependent claims. For instance, Tanaka discloses propagating routing information from a central node to peripheral nodes to maintain network coherency, directly teaching the limitation of updating routing information "in other nodes" as recited in dependent claim 3.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Newman's efficient packet forwarding system with Tanaka's superior routing table management techniques to enhance network performance and adaptability. The primary motivation was to improve the robustness of Newman's network, which relied on relatively static routing, by incorporating Tanaka's dynamic update mechanism to handle network congestion or node failures—a well-known problem with a limited number of known solutions in the art at the time.
    • Expectation of Success: A POSITA would have had a high expectation of success in this combination, as implementing dynamic routing updates in a VCI-based network was a known design choice involving the application of predictable networking principles.

Ground 2: Obviousness over Clark in view of Comer and the RFC 791 Standard - Claims 1-11, 20-29, and 47-50 are obvious over Clark in view of Comer and RFC 791.

  • Prior Art Relied Upon: Clark (Patent 5,491,691), Comer (a 1991 textbook, Internetworking With TCP/IP Vol. 1), and the Internet Engineering Task Force’s RFC 791 standard.

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Clark teaches a packet-switched network that uses "source routing," where a packet header contains routing information directing it through the network. This, Petitioner argued, is a type of "super-header" as claimed. Clark discloses most limitations of the independent claims. However, to the extent Clark’s header was not considered a "super-header," Petitioner turned to Comer and RFC 791. Comer explains the fundamental principles of IP networking, including the use of fixed-length headers for efficient processing by routers, which is the stated goal of the ’290 patent. RFC 791, the foundational standard for the Internet Protocol, explicitly defines the structure of IP packet headers. Petitioner argued that Clark’s system could be implemented using standard IP packets as described in RFC 791, which would inherently provide the claimed header structure.
    • Motivation to Combine: A POSITA implementing the network described in Clark would be motivated to use the well-established and standardized IP packet format from RFC 791 for interoperability and to leverage existing hardware and software. Comer provides the background knowledge and rationale for why using such standardized, efficient headers is beneficial. The motivation was not to solve a new problem but to apply a common industry standard to implement a known network architecture, which is a routine design choice.
    • Expectation of Success: Combining Clark's architecture with the universal RFC 791 standard was argued to be not only predictable but a matter of standard engineering practice for anyone building an interoperable network at the time.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on other combinations of prior art, including a ground anticipating certain claims under 35 U.S.C. §102 based on the Newman reference alone. Further obviousness grounds replaced Tanaka or Comer with other secondary references teaching alternative methods for network traffic management and routing table synchronization.

4. Key Claim Construction Positions

  • "super-header": Petitioner argued this term should be construed as "routing information added to a data packet that is different from, and typically shorter than, the full source and destination network addresses." This construction was proposed to be broad enough to encompass various known routing labels, such as the VCIs in Newman or the source routing information in Clark. Petitioner argued against limiting the term to the specific multi-field structure shown in the ’290 patent’s embodiments, asserting such a narrow construction would improperly import limitations from the specification into the claims.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-11, 20-29, and 47-50 of the ’290 patent as unpatentable.