PTAB

IPR2016-00021

Amazon.com, Inc. v. ZitoVault, LLC

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1. Case Identification

2. Patent Overview

  • Title: SYSTEM AND METHOD FOR MAINTAINING N NUMBER OF SIMULTANEOUS CRYPTOGRAPHIC SESSIONS USING A DISTRIBUTED COMPUTING ENVIRONMENT
  • Brief Description: The ’257 patent describes techniques for managing multiple cryptographic sessions by distributing the computationally intensive workload of encryption and decryption across a number of servers ("agents"). This architecture is intended to improve scalability and prevent a single main server from being overloaded by client communications.

3. Grounds for Unpatentability

Ground 1: Claims 6 and 10 are anticipated by Feinberg under 35 U.S.C. §102(e).

  • Prior Art Relied Upon: Feinberg (Patent 6,065,046).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Feinberg disclosed every element of claims 6 and 10. Feinberg described a scalable, distributed network with a primary server that offloads user requests to a plurality of secondary servers based on load, which maps directly to the ’257 patent’s "main server" and "agent server" architecture. Petitioner asserted that Feinberg’s system is a "software crypto system" because it explicitly teaches encrypting communications for security, using software-implemented "plug-in encryption code modules" on both primary and secondary servers. Feinberg’s system was argued to be scalable to meet demand by enlisting additional secondary servers when the primary server cannot handle the load, thereby eliminating bandwidth and server load issues and maintaining performance. For claim 10, Petitioner contended that Feinberg’s servers running encryption/decryption software constitute the claimed "distributed automaton comprising M automata" providing bandwidth scalability limited only by the number of available servers.

Ground 2: Claims 1, 3, 4, 6, and 10 are obvious over Feinberg in view of Bhaskaran under 35 U.S.C. §103.

  • Prior Art Relied Upon: Feinberg (Patent 6,065,046) and Bhaskaran (Patent 6,266,335).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Feinberg provided the foundational architecture of a distributed, load-balanced crypto system. Bhaskaran was argued to supply specific teachings that render the claims obvious. For claim 3, which requires partitioning bandwidth such that each of N agents receives 1/N of the encrypted bandwidth, Petitioner asserted that while Feinberg teaches load balancing, Bhaskaran explicitly discloses a network flow switch that divides the overall load "evenly" among IP servers by distributing individual packets. For claims 6 and 10, to the extent Feinberg was found not to teach scalability to meet "any demand," Petitioner argued Bhaskaran explicitly teaches adding or removing servers from a cluster to compensate for varying traffic volumes, making the system fully scalable.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Feinberg and Bhaskaran because both references address the same problem: overcoming network bandwidth limitations in distributed computing networks. They disclose complementary methods for load balancing. A POSITA seeking to improve the load distribution of Feinberg's system would have been motivated to incorporate Bhaskaran's teaching of per-packet, even workload distribution to achieve more predictable results and better performance.
    • Expectation of Success: A POSITA would have had a high expectation of success because combining the known techniques from these highly similar network architectures would predictably result in a more evenly distributed load and the ability to adapt to traffic demands.

Ground 3: Claims 5, 7, and 8 are obvious over Feinberg in view of Molva under 35 U.S.C. §103.

  • Prior Art Relied Upon: Feinberg (Patent 6,065,046) and Molva (R. Molva et al., Authentication of Mobile Users, IEEE Network 1994).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Feinberg’s system, when combined with Molva’s teachings, renders claims 5, 7, and 8 obvious. These claims relate to handling server saturation by passing session keys to an alternate server and notifying the client. While Feinberg teaches offloading requests when a server is busy, Petitioner asserted Molva explicitly discloses a "fast handover protocol" for when a server becomes unavailable (e.g., a mobile user changes domains). Molva teaches the current server forwarding the session key to the new server, which then uses the key to continue the secure session. Molva also teaches that the original server must notify the user to redirect communications to the new server, directly mapping to the limitations of claims 5 and 7. Claim 8, dependent on claim 7, adds registering agent servers and defining session keys, elements Petitioner argued were already present in Feinberg.
    • Motivation to Combine: A POSITA would combine Feinberg and Molva because both address the problem of maintaining secure communications in a distributed network when a handling server becomes unavailable or overloaded. A POSITA seeking to improve the fault tolerance and session continuity of Feinberg’s system would have been motivated to incorporate Molva's well-known technique for session key handoff to ensure continuous, secure service.
    • Expectation of Success: A POSITA would expect success because applying Molva’s standard key-passing protocol to Feinberg’s architecture is a straightforward implementation that would predictably result in maintaining connectivity and security when a server becomes saturated.

4. Key Claim Construction Positions

  • "A Distributed Automaton ... / Automata" (Claims 1, 4, 10): Petitioner proposed that this term should be construed as "a collection of software that encrypts and/or decrypts packets." This broad construction, based on the specification's description of "automata" as software components residing on servers to handle encryption, is critical for mapping the term onto the prior art's general descriptions of servers with encryption capabilities.
  • "Registration Entity" (Claim 5): Petitioner proposed this term should be construed as "data structure(s) containing identification information for agents and clients in the network and keys used to encrypt and decrypt communications within the network." This construction is based on the ’257 patent’s disclosure of a "registry" on the main server that stores lists of agent servers, client information, and session keys, and is crucial for arguing that Feinberg's system, which stores similar information in memory, meets this limitation.

5. Relief Requested

  • Petitioner requested that the Board institute an inter partes review and cancel claims 1, 3-8, and 10 of the ’257 patent as unpatentable.