PTAB

IPR2015-00485

Microsoft Corp v. Parallel Networks Licensing LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Managing Dynamic Web Page Generation Requests
  • Brief Description: The ’335 patent discloses methods and systems for managing web page generation requests in a "partitioned architecture." The system routes requests received at a front-end web server to one of a plurality of back-end page servers for processing, thereby freeing the web server to handle other incoming requests and overcoming the performance bottlenecks of a single-server environment.

3. Grounds for Unpatentability

Ground 1: Anticipation over SWEB 95 - Claims 30-35, 40, 43-48, 53, 56-68, 70-83, and 85 are anticipated by SWEB 95 under 35 U.S.C. §102.

  • Prior Art Relied Upon: Andresen et al., SWEB: Towards A Scalable World Wide Web Server On Multicomputers (a September 1995 technical report, hereinafter “SWEB 95”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that SWEB 95, which was published before the patent’s effective filing date, explicitly discloses every element of the challenged claims. SWEB 95 describes a scalable web server architecture built on a cluster of workstations to solve the exact problem of single-server bottlenecks addressed by the ’335 patent. Petitioner asserted that SWEB 95’s system constitutes a "Web server" that receives a "dynamic Web page generation request," as required by the preamble of independent claim 30.
    • Prior Art Mapping (cont.): SWEB 95’s "distributed scheduler" software, located on each server, was alleged to meet the limitations of intercepting a request, selecting a server from a plurality of servers based on dynamic load information, and routing the request to the selected server. The scheduler in SWEB 95 analyzes dynamically updated information, such as CPU load and data location, to determine the optimal server to handle a request, which directly maps to the claim limitation of selecting a page server "based on dynamic information." The act of routing the request to a different server for processing inherently satisfies the limitation of "releasing said Web server to process other requests." Finally, SWEB 95 explicitly discloses invoking Common Gateway Interface (CGI) programs to handle requests, which was argued to meet the limitation of "dynamically generating a Web page."

Ground 2: Obviousness over SWEB 95 - Claims 30-40, 43-53, and 56-85 are obvious over SWEB 95 under 35 U.S.C. §103.

  • Prior Art Relied Upon: SWEB 95.
  • Core Argument for this Ground:
    • Prior Art Mapping: As an alternative to its anticipation argument, Petitioner contended that to the extent SWEB 95 was found not to explicitly disclose any claimed feature, it would have been obvious for a person of ordinary skill in the art (POSITA) to modify the SWEB 95 system to include it. Petitioner argued that all core functionalities—such as routing requests between servers, load balancing based on dynamic information, using connection caches, and dynamic page generation—were well-known techniques in 1995 for improving the efficiency and scalability of network servers.
    • Motivation to Combine: A POSITA would have been motivated to incorporate any allegedly missing features into the SWEB 95 system to further its explicitly stated goals. SWEB 95 was expressly concerned with achieving "scalable performance" and minimizing response time. Implementing known techniques like dynamic load balancing or page caching would have been a straightforward and logical step to advance these objectives.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because it would have involved applying known, conventional techniques for their recognized purposes to achieve predictable results. For example, incorporating tag-based templates for page generation or maintaining a connection cache were standard practices for improving server performance and would have been readily implemented in the SWEB 95 architecture.

4. Key Claim Construction Positions

  • “releasing said [Web server...] to process other requests”: Petitioner argued this term should be construed as "freeing said [Web server...] to process other requests." This construction is central to the argument that by routing a request to a separate page server, the web server’s resources are freed and thus "released," a condition Petitioner alleges is inherently met by the load-balancing architecture of SWEB 95.
  • “intercepting said request...”: Petitioner proposed this term means "to stop or interrupt the handling of said request." This supports the argument that SWEB 95’s scheduler, which diverts a request from its normal processing path to make a routing decision, performs the claimed "intercepting" step.
  • “connection cache”: Petitioner argued this term means "stored information for allowing persistent and reusable connections to a data source." This construction was used to argue that the "NFS mounts" described in SWEB 95, which establish persistent connections to file systems, function as a connection cache.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 30-40, 43-53, and 56-85 of Patent 6,415,335 as unpatentable.