PTAB

IPR2015-01729

IBM Corp v. Parallel Networks Licensing LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method 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 server workload by offloading requests for dynamically generated web pages. The system uses a partitioned architecture where a primary web server intercepts requests and routes them to one of a plurality of specialized page servers for processing, thereby freeing the web server to handle other incoming requests.

3. Grounds for Unpatentability

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

  • Prior Art Relied Upon: SWEB 95 (Andresen et al., "SWEB: Towards A Scalable World Wide Web Server On Multicomputers," a September 1995 technical report).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that SWEB 95, which addresses the performance bottlenecks of single-server systems, discloses every element of the challenged claims. SWEB 95 describes a scalable web server system implemented on a cluster of workstations. Incoming requests are received by a SWEB server (the claimed "Web server") and its "distributed scheduler" software determines whether to process the request locally or redirect it to another server in the cluster. This scheduler acts as the claimed "dispatcher," and the server that ultimately processes the request is the claimed "page server." Petitioner contended that this redirection of the request constitutes the claimed "routing" and "dispatching," and that by offloading the request, the initial server is "released" to process other requests, as it can handle new tasks while the chosen server processes the redirected one. SWEB 95 also taught using dynamic information like CPU load to select the optimal processor, satisfying limitations in claims 32, 34, 46, and 48 regarding selecting a "least busy" server.
    • Motivation to Combine (for §103 grounds): As an alternative to anticipation, Petitioner argued that any minor differences between SWEB 95 and the claims would have been obvious modifications. A person of ordinary skill in the art (POSITA) reviewing SWEB 95, which is explicitly concerned with efficient load balancing and resource use, would have found it obvious to implement known techniques for routing, dispatching, and releasing server resources to achieve the predictable result of improved scalability and performance.
    • Expectation of Success: A POSITA would have a high expectation of success because SWEB 95 already provides the fundamental architecture and describes using load-balancing algorithms, making any implementation of the claimed steps a straightforward application of known principles for a known purpose.

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

  • Prior Art Relied Upon: SWEB 95 and Leaf (Patent 5,754,772).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that SWEB 95 teaches the core scalable server architecture, while Leaf supplies the teachings for specific data handling and page generation features in the dependent claims. Leaf discloses a system for accessing online transaction processing databases via a web server. It explicitly teaches dynamically retrieving data from a data source to generate an HTML document (claim 14), using a "connection cache" to avoid time wasted in connecting and disconnecting from data sources (claim 15), and using "custom HTML extension templates" with placeholders to insert the retrieved data into a web page (claims 18 and 19).
    • Motivation to Combine: A POSITA would combine Leaf’s data access and templating techniques with SWEB 95’s scalable server architecture to solve the known problem of efficiently providing dynamic, database-driven content on the World Wide Web. Since both references address improving web server performance and data access, a POSITA would have been motivated to integrate Leaf's efficient data handling methods into SWEB 95's high-performance server environment to create a more robust and scalable system.
    • Expectation of Success: The combination would have been a predictable integration of two known solutions for related problems in the same field, with a high expectation of success.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 17 over SWEB 95 in view of Bradley (a 1995 paper on CGI), arguing Bradley taught caching the output of dynamically generated web pages to improve performance, a feature that would have been obvious to add to the SWEB 95 system.

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 critical because it does not require the web server to be completely idle, only that its resources (e.g., CPU cycles, memory) are made available for other tasks once a request is handed off, a condition Petitioner argued is inherently met in any load-balancing system like SWEB 95.
  • "dispatching": Petitioner proposed this term means "transferring processing responsibility." This broad construction allows the term to cover various methods of handing off a request, including the URL redirection method disclosed in SWEB 95, and does not require a specific software component separate from the web server itself.
  • "intercepting said request at said Web server": Petitioner argued this means "to stop or interrupt the handling of said request at the Web server." This construction aligns with SWEB 95's disclosure of a scheduler that diverts a request from its normal processing path to determine the optimal server for handling it.

5. Relief Requested

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