PTAB

IPR2016-00977

Talari Networks Inc v. Fatpipe Networks India Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Tools and Techniques for Directing Packets Over Disparate Networks
  • Brief Description: The ’048 patent discloses a system and method for computer network data transmission using a controller that manages access to multiple disparate, parallel networks, such as a private network and an Internet-based network, to route data packets.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 3, 4, 6, 7, 9, 10, 12, 13, 15, 16, 18, 19, 21, 22, and 24 under 35 U.S.C. §102 by Karol

  • Prior Art Relied Upon: Karol (Patent 6,628,617)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Karol disclosed every limitation of the challenged claims. Karol’s “CL-CO gateway” was presented as the claimed “controller” that controls access to parallel, disparate networks. Karol’s connectionless (CL) network, based on Internet Protocol, was mapped to the claimed “Internet-based network,” while its connection-oriented (CO) network (e.g., ATM, MPLS, or telephony) was mapped to the “private network.” Petitioner asserted Karol’s gateway includes a “packet path selector” that uses routing tables (a forwarding database and a flow database) to select paths based on packet destination and other criteria, such as maximizing efficiency or bandwidth availability, which corresponds to the claimed load-balancing and reliability criteria (claims 3 and 4). Karol’s disclosure of point-to-point links within its CO network was argued to meet the limitations of claim 6.

Ground 2: Obviousness over Karol in view of Stallings - Claims 1-5, 7-11, 13-17, and 19-23 are obvious over Karol in view of Stallings

  • Prior Art Relied Upon: Karol (Patent 6,628,617) and Stallings (“Data and Computer Communications,” 5th Edition, 1997)
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1, particularly if the Board found that Karol did not expressly disclose the limitation of using “at least two known location address ranges” (claim 1[d]). Petitioner argued that Stallings explicitly disclosed that IP routers use routing tables to route packets based on the network identifier portion of an IP address, which corresponds to a range of addresses. For dependent claims, Petitioner asserted Stallings taught specific network types, such as frame relay (claim 2) and VPNs (claim 5), as well as dynamic routing protocols like OSPF for load-balancing (claim 3) and ICMP for reliability (claim 4).
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Karol and Stallings for several reasons. First, Karol itself cited Stallings to describe attributes of its gateway, indicating the references are from the same field of art. Second, combining Stallings’s well-known routing table techniques with Karol’s parallel network architecture was presented as a simple application of a known technique (routing based on address ranges) to improve a similar system, yielding predictable results. Third, it was argued to be obvious to try, as there was a known need to route packets over multiple parallel routes, and substituting known network types (like frame relay from Stallings) into Karol's system was a simple substitution of one known element for another.
    • Expectation of Success: A POSITA would have pursued the combination with a high likelihood of success because implementing standard IP routing protocols and network types as described in Stallings within Karol’s framework involved applying conventional networking principles to achieve predictable routing improvements.

Ground 3: Obviousness over Karol - Claims 1-24 are obvious over Karol

  • Prior Art Relied Upon: Karol (Patent 6,628,617)
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that even without a secondary reference, all claims were obvious over Karol combined with the general knowledge of a POSITA at the time. Petitioner argued that features not expressly disclosed in Karol, such as using specific network types like frame relay or a point-to-point T1/T3 connection, were well-known examples of the CO networks Karol taught. The ’048 patent itself admitted that such networks were known. Similarly, associating routing paths with destination address ranges was argued to be common knowledge for a POSITA in IP networking.
    • Motivation to Combine: The motivation was framed as applying common knowledge and predictable design choices to Karol’s system. For example, a POSITA would have understood that Karol's teaching of a "telephony network" as a CO network inherently includes well-known point-to-point connections like T1/T3 lines. Implementing load-balancing or reliability criteria was described as using well-understood routing protocols (like OSPF) to solve known problems (congestion, link failure) in a predictable way.
    • Expectation of Success: A POSITA would have had a high expectation of success because these modifications involved implementing standard, well-documented networking technologies and protocols to enhance the functionality of Karol’s disclosed system in a straightforward manner.

4. Relief Requested

  • Petitioner requests that inter partes review of the ’048 patent be instituted and that the challenged claims (1-24) be cancelled as unpatentable.