PTAB

IPR2015-00483

Microsoft Corp v. Parallel Networks Licensing LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Managing Dynamic Web Page Generation Requests by Intercepting Request at Web Server and Routing to Page Server Thereby Releasing Web Server to Process Other Requests
  • Brief Description: The ’554 patent discloses methods and systems for managing web page requests in a high-traffic environment. The technology uses a "partitioned architecture" where an initial web server intercepts incoming requests and routes them to one of a plurality of "page servers" for processing, thereby freeing the primary web server to handle other incoming requests and avoid becoming a performance bottleneck.

3. Grounds for Unpatentability

Ground 1: Anticipation - Claims 12-17, 32, 34, 46, and 48 are anticipated by SWEB 95.

  • Prior Art Relied Upon: SWEB 95 (Andresen et al., "SWEB: Towards A Scalable World Wide Web Server On Multicomputers," a 1995 technical report).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that SWEB 95, which addresses the scalability limitations of single-server web systems, discloses every element of the independent claims. The SWEB 95 system comprises multiple servers on different workstations that collectively handle web requests. Incoming requests are routed to one of these servers, which functions as the claimed "Web server." This server uses a "distributed scheduler" to determine the optimal server in the system to process the request based on dynamic load information. This scheduler allegedly performs the claimed "intercepting" and "dispatching" functions. The request is then sent to the selected optimal server (the "page server"), which frees the initial server to process other requests, thus meeting the "releasing" limitation. SWEB 95 also explicitly discloses dynamic page generation via CGI programs and the use of dynamic load information for server selection.
    • Key Aspects: Petitioner contended that the core innovation claimed in the ’554 patent—using multiple servers with load-based routing to improve performance—was the central teaching of the SWEB 95 prior art.

Ground 2: Obviousness over SWEB 95 and Leaf - Claims 14, 15, 18, and 19 are obvious over SWEB 95 in view of Leaf.

  • Prior Art Relied Upon: SWEB 95 (a 1995 technical report by Andresen et al.) and Leaf (Patent 5,754,772).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that to the extent SWEB 95 does not explicitly teach certain dependent claim features, they are rendered obvious by Leaf. Leaf discloses a server system for accessing databases via a web interface. For claim 14 (dynamically retrieving data), Leaf teaches retrieving data from a database and transforming it into an HTML document. For claim 15 (maintaining a connection cache), Leaf discloses a connection cache to avoid time wasted connecting and disconnecting from data sources. For claims 18 and 19 (custom HTML extension templates), Leaf teaches using placeholders in HTML templates to insert dynamically retrieved data.
    • Motivation to Combine: A POSITA would combine the teachings of Leaf with SWEB 95 because both references address the common problem of efficiently accessing and presenting data over the World Wide Web. A POSITA would have been motivated to incorporate Leaf's known techniques for efficient data handling (connection caching, templates) into the scalable server architecture of SWEB 95 to improve its performance and functionality, a predictable and desirable outcome.
    • Expectation of Success: The combination involved applying known web data access techniques from Leaf to the known scalable server architecture of SWEB 95, providing a POSITA with a high expectation of success.

Ground 3: Obviousness over SWEB 95 and Bradley - Claim 17 is obvious over SWEB 95 in view of Bradley.

  • Prior Art Relied Upon: SWEB 95 (a 1995 technical report by Andresen et al.) and Bradley (a 1995 publication, "Web-based Access to an Online Atlas of Anatomy").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bradley teaches the limitation of claim 17, which requires "maintaining a page cache containing said Web page." Bradley discloses a web server that uses CGI programs to convert image files (PICT to GIF) on the fly. To improve performance, Bradley’s server first checks a cache to see if the requested GIF file already exists, thereby avoiding the costly re-conversion process. This, Petitioner argued, is a direct teaching of maintaining a page cache.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Bradley's caching technique into the SWEB 95 system for the explicit and known purpose of improving performance. Since SWEB 95 was focused on scalability and reducing response times, adding a well-understood performance enhancement like caching dynamic content would have been an obvious improvement.
    • Expectation of Success: Implementing a file cache for CGI-generated output was a known technique for improving web server performance, ensuring a POSITA would have expected success.
  • Additional Grounds: Petitioner asserted an alternative obviousness challenge for claims 12-19, 32, 34, 46, and 48 based on SWEB 95 alone, arguing that to the extent any element was not explicitly disclosed, its inclusion would have been an obvious modification to implement well-known load-balancing and resource-management techniques.

4. Key Claim Construction Positions

  • "intercepting said request at said Web server": Petitioner argued this term should be construed as "to stop or interrupt the handling of said request at the Web server." This construction, supported by the patent’s specification and flowcharts, requires the server to first receive the request and then have its normal processing pathway interrupted, which aligns with how SWEB 95's scheduler diverts requests.
  • "releasing said Web server to process other requests": Petitioner proposed this term means "freeing said Web server to process other requests." This construction focuses on freeing up the server’s hardware resources (e.g., CPU, memory), which Petitioner argued is the inherent and predictable result of offloading a task to another server for load-balancing purposes, as disclosed in SWEB 95.
  • "routing": Petitioner argued this term should encompass "passing from one portion of software or a machine to another." This construction is broad enough to cover routing between software modules on the same machine, consistent with SWEB 95’s scheduler algorithm, and not strictly limited to routing between physically separate machines.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 12-19, 32, 34, 46, and 48 of the ’554 patent as unpatentable.