PTAB

IPR2017-01409

Intel Corp v. Alacritech Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Intelligent Network Interface Device and System for Accelerated Communication
  • Brief Description: The ’880 patent discloses a method and system for offloading network protocol processing from a host computer’s CPU to an intelligent network interface device. This creates a "fast path" for network packets, particularly TCP/IP packets, to avoid the processing burden on the host system, thereby accelerating communication.

3. Grounds for Unpatentability

Ground 1: Obviousness over Thia and Tanenbaum96 - Claims 1, 5-10, 12, 14, 16, 17, 20-23, 27, 28, 45, and 55 are obvious over Thia in view of Tanenbaum96.

  • Prior Art Relied Upon: Thia (a 1995 article titled “A Reduced Operation Protocol Engine (ROPE) for a multiple-layer bypass architecture”) and Tanenbaum96 (a 1996 textbook titled “Computer Networks”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Thia and Tanenbaum96 teaches every limitation of the challenged claims. Thia disclosed a general framework for improving network performance by offloading protocol processing from the host CPU to a dedicated hardware engine (a "ROPE chip") on a network interface. This creates a "bypass" or "fast path" for certain data packets. While Thia taught the core concept of offloading, it described its implementation in the context of the Open Systems Interconnection (OSI) protocol and explicitly stated its architecture could be used with "any standard protocol."
    • Petitioner asserted that Tanenbaum96, a widely-cited textbook, provided the missing details for applying Thia's offloading architecture to the TCP/IP protocol, which by the mid-1990s was the dominant industry standard. Tanenbaum96 taught the conventional steps of TCP/IP processing recited in claim 1, including parsing a packet header to identify it as TCP, generating a "flow key" from source/destination IP addresses and ports to identify a specific communication flow, and updating a connection record (a control block). Crucially, Tanenbaum96 also expressly taught that the "transport entity" performing these TCP functions could be implemented on a network interface card. Petitioner contended that combining Thia's offloading architecture with the specific TCP/IP protocol details from Tanenbaum96 rendered the claimed invention obvious. The dependent claims were argued to recite further standard, well-known TCP/IP functionalities (e.g., using a hash table for connection lookup, resequencing packets) that were also disclosed in Tanenbaum96.
    • Motivation to Combine: Petitioner asserted multiple motivations for a person of ordinary skill in the art (POSITA) to combine the references. The primary motivation was to apply Thia's performance-enhancing offloading architecture to the commercially relevant and dominant TCP/IP protocol. As Tanenbaum96 explained, the OSI protocol (used in Thia's example) had "quietly vanished" by the mid-1990s, while TCP/IP was the standard for the rapidly growing Internet. A POSITA would have been motivated to adapt Thia's protocol-agnostic system to the prevailing TCP/IP standard to make its benefits available to internet users.
    • Further, a POSITA would combine the references to improve Thia's generalized disclosure with the specific, well-understood TCP/IP fast-path and header prediction techniques described in Tanenbaum96, such as using a hash table for efficient connection lookup. This would have been a predictable optimization of Thia’s system.
    • Expectation of Success: Petitioner argued a POSITA would have had a high expectation of success. Both OSI and TCP/IP are layered protocols, designed to be modular, which allows for protocols at a given layer to be replaced without affecting others. Thia's architecture was explicitly designed to be flexible for "any standard protocol." The TCP/IP implementation details from Tanenbaum96 were well-known, standard, and widely available, requiring no undue experimentation to integrate into Thia's offloading hardware framework. The combination was a straightforward application of a known technique (TCP/IP processing) to a known system (Thia's offloading hardware) to yield predictable results.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1, 5-10, 12, 14, 16, 17, 20-23, 27, 28, 45, and 55 of the ’880 patent as unpatentable.