PTAB

IPR2015-01732

IBM Corp v. Parallel Networks Licensing LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Managing Dynamic Web Page Generation Requests
  • Brief Description: The ’335 patent discloses a "partitioned architecture" for managing web page requests to overcome processing bottlenecks associated with single-server environments. The invention describes a system where a primary Web server intercepts requests and routes them to one of a plurality of "page servers" for processing, thereby freeing the primary Web server to handle additional incoming requests.

3. Grounds for Unpatentability

Ground 1: Anticipation by SWEB 95 - Claims 30-35, 40, 43-48, 53, 56-68, 70-83, and 85 are anticipated by SWEB 95.

  • Prior Art Relied Upon: SWEB 95 (Andresen et al., "SWEB: Towards A Scalable World Wide Web Server On Multicomputers," Sept. 1995).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that SWEB 95, which discloses a scalable web server architecture implemented on a cluster of workstations, teaches every limitation of the challenged claims. The SWEB 95 system was designed to solve the same problem as the ’335 patent: the performance limitations of a single web server. Petitioner asserted that SWEB 95 discloses a system where an initial server (the "Web server") receives an HTTP request for a dynamic page. This server's "distributed scheduler" software intercepts the request and, instead of processing it, selects an optimal server (a "page server") from a plurality of available servers to handle the task. The selection is based on dynamic load information (e.g., CPU loads, transfer times) that is periodically updated and exchanged between the servers. The request is then routed to the selected page server, which frees, or "releases," the initial server to process other requests. The selected page server then executes the request, including invoking CGI programs to dynamically generate a web page by retrieving data from connected data sources like SCSI disks or RAID subsystems.

Ground 2: Obviousness over SWEB 95 - Claims 30-40, 43-53, and 56-85 are obvious over SWEB 95.

  • Prior Art Relied Upon: SWEB 95 (Andresen et al., "SWEB: Towards A Scalable World Wide Web Server On Multicomputers," Sept. 1995).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented this ground as an alternative, arguing that to the extent any challenged claim limitation is not explicitly taught by SWEB 95, incorporating that feature would have been obvious to a Person of Ordinary Skill in the Art (POSITA) at the time. The fundamental mapping of SWEB 95’s load-balancing, multi-server architecture to the claims remains the same as in the anticipation ground.
    • Motivation to Combine: The motivation to modify the SWEB 95 system to include any allegedly missing feature stemmed from the stated goals of SWEB 95 itself—to create a scalable, high-performance web server architecture. A POSITA would have been motivated to employ well-known techniques, such as dynamic page generation, connection caching, or specific load-balancing metrics, to further SWEB 95's goal of efficiently handling high-volume web traffic. For example, if SWEB 95 was found to not explicitly teach "releasing" the initial server, a POSITA would combine SWEB 95's architecture with the common-sense principle of freeing up resources after offloading a task to predictably improve system throughput.
    • Expectation of Success: A POSITA would have had a high expectation of success because any proposed modification involved applying conventional and well-understood web technologies and load-balancing principles to the SWEB 95 system. The outcome of such combinations—improved performance and efficiency—was predictable and sought-after in the field.

4. Key Claim Construction Positions

  • "releasing said [Web server / HTTP-compliant device] to process other requests": Petitioner argued this term should be construed broadly as "freeing said [Web server / HTTP-compliant device] to process other requests." This interpretation means that making the web server's hardware resources (e.g., processor, memory) available for other uses satisfies the limitation, a condition met when SWEB 95's initial server routes a request to a different machine for processing.
  • "intercepting said request": Petitioner proposed this term means "to stop or interrupt the handling of said request" at the web server. This construction is central to its argument that SWEB 95's distributed scheduler, which diverts an incoming request to a selection algorithm rather than allowing the receiving server to process it fully, meets this claim limitation.
  • "routing": Petitioner argued for a construction of "passing from one portion of software or a machine to another portion of software or a machine." This broad interpretation allows the internal redirection of requests within the SWEB 95 system, including between software modules on the same machine, to satisfy the "routing" limitation of the claims.

5. Relief Requested

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