PTAB

IPR2016-00976

Talari Networks, Inc. v. FatPipe Networks India Limited

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1. Case Identification

2. Patent Overview

  • Title: Tools and Techniques for Directing Packets Over Disparate Networks
  • Brief Description: The ’235 patent relates to computer network data transmission. The technology involves systems and methods for directing data packets over multiple disparate and parallel networks, such as a public Internet-based network and a private network, using a controller to manage traffic.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 4, 5, 7-11, 14, and 19 by Karol

  • Prior Art Relied Upon: Karol (Patent 6,628,617).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Karol, which teaches the internetworking of parallel connectionless (CL) and connection-oriented (CO) networks, discloses every element of the challenged claims. Karol’s “CL-CO gateway” was asserted to be the claimed “controller.” This gateway controls access to a CL network (disclosed as typically an IP network, i.e., an “Internet-based network”) and a parallel CO network (disclosed as an MPLS or telephony network, i.e., a “private network”). Petitioner noted that Karol discloses these networks can be offered by different service providers. The gateway includes a “packet path selector” comprising a gateway processor and databases that determines, on a per-packet basis, whether to route a packet over the CL or CO network. This selection is based on criteria including the packet’s destination address and network conditions like bandwidth availability, satisfying the limitations of independent claims 4 and 5.
    • Key Aspects: Petitioner contended that Karol also anticipates the dependent claims. Karol teaches selecting paths based on sessions (claim 10), implementing dynamic load-balancing by diverting connections away from congested links (claim 11), and ensuring a guaranteed quality of service, which inherently addresses reliability (claim 14).

Ground 2: Obviousness over Karol in view of Stallings

  • Prior Art Relied Upon: Karol (Patent 6,628,617) and Stallings (a 1997 textbook, "Data and Computer Communications").
  • Core Argument for this Ground:
    • Prior Art Mapping: As an alternative, Petitioner argued that if Karol is found not to explicitly disclose every element, the combination with the Stallings textbook renders claims 5, 11-15, and 19 obvious. Stallings, a foundational text on networking, was argued to supply any missing details by teaching common industry knowledge. Specifically, Stallings teaches dynamic routing tables that contain topology information and location address ranges for associated networks (addressing elements of claim 5). Stallings also explicitly describes making routing decisions based on dynamic load-balancing to avoid congestion, reliability criteria using protocols like ICMP to provide feedback about network problems, and security criteria using virtual private networks and security gateways. These teachings directly map to the limitations of dependent claims 11, 14, and 15.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Karol with Stallings. Karol itself cites Stallings, demonstrating its relevance. A POSITA would have been motivated to apply the fundamental routing techniques from Stallings to Karol’s specific gateway system to improve its functionality with predictable results, such as enhanced load-balancing and reliability. The combination amounts to the application of known techniques to a known system to yield predictable outcomes.
    • Expectation of Success: A POSITA would have had a high expectation of success because the combination involves implementing standard, well-understood IP networking protocols and criteria within a system designed for IP networking. Petitioner asserted this was an "obvious to try" scenario, as there were a finite number of well-known solutions for routing packets based on performance, reliability, and security.

Ground 3: Obviousness over Karol

  • Prior Art Relied Upon: Karol (Patent 6,628,617).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented a final alternative ground that all challenged claims would have been obvious over Karol alone. This argument posited that a POSITA would have found it obvious to adapt or modify Karol's system using general knowledge in the art. For instance, if the claim term “private network” were construed to require a “frame relay” network, a POSITA would have understood that frame relay is a well-known type of CO network. It would have been a simple and obvious substitution to use a frame relay network in place of the exemplary MPLS or telephony networks mentioned in Karol.
    • Motivation to Combine (or Modify): The motivation was framed as the simple substitution of one known element for another to obtain a predictable result. A POSITA would have been motivated to use known CO network technologies, like frame relay, interchangeably within Karol's architecture. Likewise, modifying Karol’s selection logic from one based on session flows to one based purely on per-packet analysis would be an obvious design choice to simplify the system.
    • Expectation of Success: The likelihood of success was argued to be high. Such modifications involve using known, interchangeable components and established methods in the networking field, leading to a predictable and successful implementation.

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 4, 5, 7-15, and 19 of Patent 6,775,235 as unpatentable.