PTAB

IPR2015-01804

Amazon.com, Inc. v. AC TECHNOLOGIES S.A.

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1. Case Identification

2. Patent Overview

  • Title: Data Access and Management System as Well as a Method
  • Brief Description: The ’125 patent describes a system to address performance bottlenecks in client-server networks, such as lag in interactive computer games. The invention proposes using multiple, networked data storage devices that host replicated data and serve requests from computer units based on measured data transmission parameters between the devices.

3. Grounds for Unpatentability

Ground 1: Obviousness over Rabinovich - Claims 1-14 are obvious over Rabinovich under 35 U.S.C. §103.

  • Prior Art Relied Upon: Rabinovich, M., et al., “Dynamic Replication on the Internet,” (AT&T Labs Research Technical Memorandum, Mar. 5, 1998) (“Rabinovich”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rabinovich taught a client-server system for improving performance by using multiple servers ("hosts") to store replicated copies of data ("objects"). In Rabinovich, client requests are routed to an optimal server based on network performance metrics like proximity (which correlates to transmission delay/duration) and server load. Petitioner contended that Rabinovich’s clients correspond to the claimed “computer units” and its servers correspond to the “data storage devices.” The core teachings of dynamically replicating and moving data between servers based on measured performance parameters (load, proximity) to optimize service to clients rendered the claimed invention obvious. For example, the pseudocode in Rabinovich disclosed algorithms for a server to evaluate other servers as candidates for a new replica based on communication costs and load, and then send the data to a selected server, all independent of a new client access.
    • Motivation to Combine: This ground relied on Rabinovich in view of the knowledge of a person of ordinary skill in the art (POSITA). Petitioner asserted that while Rabinovich was primarily focused on speeding up downloads to clients, a POSITA would have been motivated to apply the same disclosed techniques for dynamically selecting a server to the analogous problem of optimizing uploads from a client. The principles of measuring network load and proximity to select the best-performing server are directly applicable to both download and upload operations.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in applying Rabinovich's techniques to uploads, as the network performance issues are symmetric and the disclosed solutions for managing data replication based on server load and client proximity are not specific to the direction of data flow.

Ground 2: Anticipation by Rabinovich - Claims 1-14 are anticipated by Rabinovich under 35 U.S.C. §102(b) using Patent Owner's alleged claim constructions.

  • Prior Art Relied Upon: Rabinovich, M., et al., “Dynamic Replication on the Internet,” (AT&T Labs Research Technical Memorandum, Mar. 5, 1998) (“Rabinovich”).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative based on the allegedly broad claim constructions advanced by the Patent Owner in related litigation. Petitioner argued that if the term “computer unit” is construed broadly to be any computing device (not just a client), then the server-to-server interactions in Rabinovich anticipated every claim limitation. Under this construction, one of Rabinovich's servers (a "host") could be considered the "computer unit" storing a complete file, and the other servers it replicates data to would be the "data storage devices." The process in Rabinovich where a host server decides to create a new replica on another host based on measured performance parameters (load, communication distance) and then copies the data to that new host was argued to directly read on the claim limitations. This includes measuring performance between storage devices and sending data between them as a function of that performance, independent of access by an end-user client.
    • Key Aspects: This argument's viability depends entirely on the adoption of a broad construction of "computer unit" that eliminates the client-server distinction maintained in Petitioner's primary argument. It re-characterizes the server-to-server replication functions within Rabinovich as fulfilling all claim elements.

4. Key Claim Construction Positions

Petitioner asserted that the following constructions, under the Broadest Reasonable Interpretation (BRI) standard, were critical to the invalidity analysis.

  • "Computer Unit": Petitioner proposed this term be construed as “a client computer, for example, an Internet Service Provider, personal computer, or network computer.” This construction was central to Ground 1, as it maintained the client-server architecture where "computer units" (clients) are serviced by "data storage devices" (servers). This contrasted with the broader construction allegedly used by the Patent Owner and relied upon by Petitioner for Ground 2.
  • "Data Storage Device": Proposed as “memory for storing data.” Petitioner argued this generic construction was appropriate under BRI as the term is not one of art and is used interchangeably with "memory" in the specification.
  • "Data Transmission Performance" / "Predetermined Parameters": Petitioner proposed these related terms be construed broadly as encompassing “the duration of transmission, fault rate, duration of data processing operations prior to transmission, transmission quality, transmission rate, computing performance/load, network performance, or other performance measures.” This broad construction was necessary to map the performance metrics disclosed in Rabinovich, such as communication distance (proxy for duration/delay) and server load, to the claim language.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-14 of Patent 8,656,125 as unpatentable.