PTAB

IPR2015-00480

Amazon.com Inc v. Appistry Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Distributed Computing System
  • Brief Description: The ’746 patent discloses systems and methods for distributed computing. The system comprises a plurality of networked computers, termed "hive engines," which are organized into logical groups called "territories" to execute processing jobs across multiple computers.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hariri - Claims 1-17, 19-20, and 22-27 are obvious over Hariri.

  • Prior Art Relied Upon: Hariri (Air Force Research Laboratory Final Technical Report, Mar. 2000).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hariri, which describes a "Virtual Distributed Computing Environment" (VDCE), taught every limitation of the challenged claims. Hariri's VDCE is composed of geographically distributed computation sites ("domains"), which correspond to the claimed "territories." These domains contain clusters of heterogeneous computers, which correspond to the claimed "hive engines." A user submits a processing job, defined by an "Application Flow Graph" (AFG), to a VDCE server via a web-based "Application Editor." This maps to the claimed computer configured to receive a service request. The system then distributes the processing tasks for execution in a distributed manner. Communication and synchronization links between nodes in the AFG correspond to the claimed "state information," and the system generates a final result.
    • Key Aspects: Petitioner contended that Hariri's architecture directly maps to the three-tiered handler structure recited in claims 7-9. Hariri’s local VDCE server software (Application Editor, site scheduler) functions as the "request handler," the remote VDCE server software (host selection algorithm) acts as the "process handler," and the individual "Data Virtual Machines" executing tasks on processors function as the "task handlers."

Ground 2: Obviousness over Lowery and Cardellini - Claims 1-10, 15-17, 19-20, and 23-27 are obvious over Lowery in view of Cardellini.

  • Prior Art Relied Upon: Lowery (Patent 5,894,554) and Cardellini (a 2000 IEEE symposium publication).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Lowery taught a system for managing dynamic web page requests using a three-component architecture analogous to the ’746 patent. Lowery’s web server, interceptor, and dispatcher act as the "request handler"; its multiple "page servers" function as the "process handlers" (and "hive engines"); and its data sources or OLE extensions serve as the "task handlers." Lowery’s page servers are grouped based on the data sources they can access, meeting the "territories" limitation. Cardellini was introduced to explicitly teach geographically distributed web server clusters organized into "Internet regions." Petitioner argued that combining the references meant implementing Lowery's locally distributed architecture within each of Cardellini's geographically distinct "Internet regions" (territories).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Lowery and Cardellini to solve the well-known problem of distributing web server requests to avoid overloading a single server. Lowery addressed this problem on a local level, while Cardellini addressed it on a geographic level. Applying Lowery’s local load-balancing architecture to Cardellini’s globally distributed framework was presented as a predictable step to improve scalability and reliability.
    • Expectation of Success: The combination represented a predictable use of known prior art elements according to their established functions, leading to a high expectation of success.

Ground 3: Obviousness over Buyya and Abramson - Claims 1-4 and 22-27 are obvious over Buyya in view of Abramson.

  • Prior Art Relied Upon: Buyya (a May 2000 IEEE paper) and Abramson (a 2000 IPDPS paper).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Buyya disclosed a resource management and scheduling system called "Nimrod/G" that operated over geographically scattered computer resources. These scattered resources, such as dedicated computer clusters, constituted the claimed "territories" of "hive engines." In Buyya's system, clients submit requests to a "parametric engine," which schedules and distributes computational jobs. The system's "dispatcher" and "job-wrapper" components return status updates and results, satisfying the limitations for state information and a processing result. Abramson, which also describes the Nimrod/G system, was cited to show that a single request can be divided into hundreds of individual jobs for execution on multiple nodes, satisfying the "plurality of processing tasks" limitation.
    • Motivation to Combine: A POSITA would have been motivated to read Buyya and Abramson together because they describe the same Nimrod/G system, and Buyya explicitly cites Abramson for additional detail. To fully understand the capabilities of the system disclosed in Buyya, a POSITA would have naturally consulted Abramson.
    • Expectation of Success: Since both references describe the same system, a POSITA would have had a high expectation of success in combining their teachings to gain a complete understanding of its operation.

4. Key Claim Construction Positions

  • Hive engine: Petitioner proposed this term means "at least a computer."
  • Grouped into a plurality of territories: Petitioner proposed this term means "divided into two or more groups, each sharing a common characteristic," such as physical location or network type.
  • State information: Petitioner proposed this term includes "at least indications of processing performed or not performed, partial or final results, and error descriptors."
  • Handler: Petitioner proposed this term means "at least a software application capable of interacting with a different software application."

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-17, 19-20, and 22-27 of the ’746 patent as unpatentable.