PTAB

IPR2015-01805

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 discloses a system and method to improve performance in networked computer systems by mitigating data transmission delays. The technology involves multiple "data storage devices" (servers) storing replicated data and multiple "computer units" (clients) that access this data, where data storage and transfer decisions are made as a function of "predetermined data transmission parameters" measured between the system components.

3. Grounds for Unpatentability

Ground 1: Claims 1-14 are obvious over Rabinovich and Carter.

  • Prior Art Relied Upon: Rabinovich (“Dynamic Replication on the Internet,” a 1998 technical memorandum) and Carter (“Server Selection using Dynamic Path Characterization in Wide-Area Networks,” a 1997 conference proceeding).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that independent claims 1 and 8 are obvious over the combination of Rabinovich and Carter. Rabinovich was asserted to teach a client-server network with multiple servers that dynamically replicate data objects to improve performance. This replication is based on performance metrics, including server load and network distance (a proxy for transmission performance) between servers, satisfying the limitation of copying data between storage units based on performance parameters independent of client access. Carter was asserted to teach improving server selection by measuring more sophisticated transmission parameters, specifically round-trip latency and bandwidth, between clients and servers.
    • Motivation to Combine: Petitioner contended that because both references address the same problem of dynamic server selection in a distributed network, a person of ordinary skill in the art (POSITA) would combine them. A POSITA would have been motivated to replace or augment Rabinovich’s simpler performance metrics (hop counts, access counts) with Carter’s more effective and detailed measurements (latency, bandwidth) to achieve superior system performance, which Carter itself suggests is an advantage of its dynamic policy.
    • Expectation of Success: A POSITA would have a high expectation of success because Carter explicitly demonstrates that using dynamic latency and bandwidth measurements results in better performance than more static methods. Integrating these known measurement techniques into Rabinovich's known dynamic replication framework was presented as a predictable improvement.

Ground 2: Claims 1-14 are obvious over Rabinovich, Carter, and Akizawa.

  • Prior Art Relied Upon: Rabinovich (1998 technical memorandum), Carter (1997 conference proceeding), and Akizawa (Patent 5,548,724).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground supplements the combination of Rabinovich and Carter with the teachings of Akizawa. Petitioner argued Akizawa addresses the same fundamental problem of network lag by dynamically selecting a server from a plurality of servers based on load measurements. Crucially, Akizawa explicitly teaches applying this dynamic selection method to both read (download) and write (upload) requests, directly addressing the claims’ requirement of a data storage device receiving data from a computer unit as a function of performance parameters. Akizawa also discloses storing files in pieces ("data blocks") across one or more servers.
    • Motivation to Combine: Petitioner asserted a POSITA would combine all three references as they all target the same problem of optimizing client-server interactions in a distributed system. A POSITA would look to Akizawa to confirm that the performance-based server selection taught by Rabinovich and Carter was applicable not just to downloads but also to uploads, a common and necessary network function. Akizawa’s teachings on handling file pieces would also be a well-known design choice for implementing the systems of Rabinovich and Carter.
    • Key Aspects: This ground was presented to preemptively counter any potential argument from the Patent Owner that applying dynamic server selection to uploads (receiving data) was not an obvious extension of art focused primarily on downloads.

4. Key Claim Construction Positions

Petitioner proposed constructions for key terms under the Broadest Reasonable Interpretation (BRI) standard, arguing they are critical to the invalidity analysis.

  • "Data Storage Device": Proposed as "memory for storing data." Petitioner argued the term is not one of art and the specification uses it interchangeably with "memory" and "cluster of memory cells." This construction allows prior art servers and hosts to meet the limitation.
  • "Computer Unit": Proposed as "a client computer, for example, an Internet Service Provider, personal computer, or network computer." The specification was argued to use "computer unit" and "client" interchangeably, linking the term to the client side of a client-server architecture.
  • "Data Transmission Performance" / "Predetermined Parameters": Proposed as "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 asserted the patent provides a broad, non-limiting list of such parameters, and the prosecution history confirms that even general "workload" was considered a parameter of transmission. This broad construction encompasses the various metrics disclosed in the prior art, such as load, network distance, latency, and bandwidth.

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.