PTAB

IPR2015-01801

Amazon.com Inc v. Ac Technologies SA

Key Events

Petition

petition Intelligence

Title: Data Access and Management System as Well as a Method
Brief Description: The ’521 patent describes a client-server network designed to mitigate data transmission delays, particularly for applications like interactive computer games. The system utilizes multiple data storage means (servers) with replicated data, which are accessed by computer units (clients) based on "prespecified parameters" of the data transmission, such as performance or load, to optimize data access. The patent also discloses methods for copying or "shifting" data between servers based on detected transmission parameters, independent of a specific client request.

Prior Art Relied Upon: Rabinovich (“Dynamic Replication on the Internet,” an AT&T Labs Research Technical Memorandum, March 1998).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Rabinovich discloses every element of the challenged claims. Rabinovich describes a client-server network with multiple servers ("hosts") storing replicated data ("objects") to address scalability and performance issues. Clients access data from the hosts over a network, and a "Request Distribution Algorithm" selects the optimal server based on connection characteristics, including server load (request counts) and network proximity (hop counts), which Petitioner equated to the ’521 patent’s "prespecified parameters." Rabinovich further discloses algorithms for dynamically replicating or migrating (shifting) data between servers based on these same parameters, performed autonomously by the hosts independent of client access, to improve overall system performance.
- Key Aspects: Petitioner contended that Rabinovich's detailed discussion of dynamic server selection and autonomous data replication/migration based on performance metrics like load and proximity directly reads on the core limitations of the challenged claims.

Prior Art Relied Upon: Rabinovich and the general knowledge of a person of ordinary skill in the art (POSITA) regarding online computer games.
Core Argument for this Ground:
- Prior Art Mapping: This ground addresses dependent claims reciting the use of the system for interactive computer games provided via the Internet. Petitioner asserted that Rabinovich teaches a system for improving data access performance in a networked environment. At the time of the invention, interactive multiplayer online games were well-known and notoriously suffered from performance issues like lag, a problem the ’521 patent explicitly acknowledges.
- Motivation to Combine: A POSITA, faced with the known problem of reducing latency in online games, would have been motivated to apply the performance-enhancing techniques taught by Rabinovich to this specific field. The motivation was to use a known solution (dynamic server selection and replication) to solve a known problem (performance bottlenecks in a specific application).
- Expectation of Success: A POSITA would have a reasonable expectation of success in applying Rabinovich’s system to online games, as the system was expressly designed to optimize data delivery and reduce latency in client-server networks.

Prior Art Relied Upon: Rabinovich and Carter (“Server Selection using Dynamic Path Characterization in Wide-Area Networks,” a 1997 IEEE Infocom proceeding).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Rabinovich discloses the fundamental architecture of the claimed system. Carter, like Rabinovich, addresses the problem of dynamic server selection in a system with replicated servers. However, Carter teaches using more direct and varied network performance measurements, such as round-trip latency (measured with "pings") and available bandwidth, to select the best server. This provides a more robust set of "prespecified parameters" than Rabinovich's hop and access counts.
- Motivation to Combine: A POSITA would combine these references because they both address the identical problem of optimizing server selection. A POSITA would be motivated to improve the performance of the system disclosed in Rabinovich by incorporating the more sophisticated and effective parameter measurement techniques taught by Carter (e.g., latency and bandwidth) to make better server selection and data placement decisions.
- Expectation of Success: A POSITA would expect success, as Carter explicitly demonstrates that using dynamic measurements like latency and bandwidth improves performance over more static approaches.

"Data Storage Means": Petitioner proposed this means-plus-function term be construed as "a memory for storing data," based on disclosures in the specification.
"Computer Unit": Petitioner proposed construing this term as "a client computer, for example, an Internet Service Provider, personal computer, or network computer," arguing the specification uses "computer unit" and "client" interchangeably.
"Prespecified Parameters Of The Data Transmission": Petitioner argued for a broad construction including "the duration of transmission, fault rate, duration of data processing operations prior to transmission, transmission quality, transmission rate, load, computing performance, network performance, or other performance measures." This construction was central to mapping the claims onto prior art network performance metrics.
"Shifting": Petitioner proposed this term means "moving to a new location and deleting from the prior location," based on explicit language in the patent distinguishing "shifting" from mere copying.

Petitioner requested the institution of an inter partes review and cancellation of claims 1, 4, 11-18, 20-22, 30-31, 33, and 40-46 of the ’521 patent as unpatentable.