PTAB

IPR2015-01805

Amazon.com Inc v. Ac Technologies SA

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Access and Management System as Well as a Method for Data Access and Data Management for a Computer System
  • Brief Description: The ’125 patent describes a client-server network system designed to mitigate server bottlenecks when handling requests from numerous clients. The system employs multiple servers (“data storage devices”) that host replicated data and dynamically manage data storage and copying between servers based on measured “data transmission performance” parameters.

3. Grounds for Unpatentability

Ground 1: Claims 1-14 are obvious over Rabinovich in view of Carter.

  • Prior Art Relied Upon: Rabinovich (“Dynamic Replication on the Internet,” a March 1998 technical memorandum) and Carter (“Server Selection using Dynamic Path Characterization in Wide-Area Networks,” an April 1997 IEEE article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rabinovich taught a classic client-server network that uses dynamic server selection, load balancing, and data replication to optimize performance. In Rabinovich, servers store multiple copies of data objects and decide whether to create new replicas on other servers based on parameters like server load and network distance (e.g., hop counts). Carter was asserted to address the same problem but taught more advanced techniques for server selection, specifically by measuring transmission parameters like round-trip latency (using "pings") and network bandwidth. Petitioner contended that the combination of these references disclosed the core limitations of the challenged claims, including storing and copying data between data storage devices as a function of measured transmission parameters.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine these references because they both address the identical problem of selecting the best server from a plurality of replicated servers to quickly service a client request. Carter explicitly taught that measuring latency and bandwidth provides improved performance over systems using simpler metrics like hop counts. Therefore, a POSITA would be motivated to integrate Carter's superior measurement techniques into Rabinovich's dynamic replication system to achieve a predictable improvement in overall system performance.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining the references, as it involved applying known, superior performance measurement techniques (Carter) to a known type of dynamic data replication system (Rabinovich) to achieve the expected benefit of improved server selection and data access speed.

Ground 2: Claims 1-14 are obvious over Rabinovich in view of Carter and Akizawa.

  • Prior Art Relied Upon: Rabinovich, Carter, and Akizawa (Patent 5,548,724).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground incorporated the teachings of Rabinovich and Carter from Ground 1 and added Akizawa to strengthen the combination. Petitioner argued Akizawa explicitly taught a system for dynamically selecting a server to handle both client read (download) and write (upload) requests based on server load measurements. Akizawa further disclosed that files could be stored in pieces as distinct data blocks, which could be stored on a single server or distributed amongst different servers. The addition of Akizawa was intended to counter any argument that the Rabinovich/Carter combination was limited to optimizing downloads and to explicitly supply the teaching of storing data in pieces.
    • Motivation to Combine: Petitioner argued a POSITA, having already combined Rabinovich and Carter to optimize data retrieval, would be motivated to incorporate Akizawa's teachings for several reasons. First, Akizawa provided an express solution for applying the same optimization principles to the parallel problem of data uploads, a natural and obvious extension. Second, Akizawa's disclosure of handling files in pieces provided a known and logical method for managing data transmission in the combined Rabinovich/Carter system. All three references addressed the same fundamental problem of selecting an optimal server based on performance metrics.
    • Expectation of Success: Success was reasonably expected because the combination involved integrating known techniques for optimizing both uploads and downloads and for handling data in discrete blocks, all within the established framework of a replicated server network.

4. Key Claim Construction Positions

Petitioner proposed the following constructions under the Broadest Reasonable Interpretation (BRI) standard, arguing they were critical to mapping the prior art to the claims.

  • "Data Storage Device": Proposed as "memory for storing data." Petitioner argued the term is not one of art and that the specification uses it interchangeably with "memory" and "cluster of memory cells."
  • "Computer Unit": Proposed as "a client computer, for example, an Internet Service Provider, personal computer, or network computer." This construction was based on the specification's interchangeable use of "computer unit" and "client."
  • "Data Transmission Performance" / "Predetermined Parameters": Proposed broadly to mean "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." Petitioner argued this broad construction was supported by the specification and prosecution history and was necessary to encompass the various performance metrics taught by the prior art, such as server load (Rabinovich, Akizawa), latency, and bandwidth (Carter).

5. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-14 of Patent 8,656,125 as unpatentable under 35 U.S.C. §103.