PTAB

IPR2017-01559

Intel Corp v. Alacritech Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Obtaining a Destination Address So That a Network Interface Device Can Write Network Data Without Headers Directly Into Host Memory
  • Brief Description: The ’699 patent describes a method for offloading network protocol processing to a network interface device (NID). The NID receives data packets, provides a header portion to the host computer to determine a destination memory address, and then directly transfers the data portions of subsequent packets to that host memory destination, bypassing the host CPU and without transferring the network or transport layer headers.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kiyohara and SMB - Claims 1-3, 6, 7, 10, 11, 13, 16, and 17 are obvious over Kiyohara in view of SMB.

  • Prior Art Relied Upon: Kiyohara (Patent 5,237,693) and SMB (“Protocols for X/Open PC Networking: SMB, Version 2,” a technical standard).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Kiyohara taught the fundamental architecture claimed in the ’699 patent. Kiyohara disclosed an "intelligent board system"—a network interface coupled to a host computer—that offloads protocol processing for lower layers (network, transport) to improve performance. In Kiyohara’s system, the network interface received packets, separated the headers from the data payload, and stored only the data in a "data storage area" in host memory for use by an application. The host computer was responsible for processing the upper-layer protocols, including the session layer. Petitioner contended that Kiyohara’s system met the core limitations of independent claim 1, including receiving packets, obtaining a destination in host memory controlled by an application, and transferring data to that destination without the network or transport layer headers being processed by the computer.

    Petitioner argued that while Kiyohara taught using a session layer protocol, it did not specify a particular one. SMB, a well-known industry standard for file and printer sharing, was asserted to be a session layer protocol that supplied the missing details. SMB headers contain command codes (e.g., SMBreadX) that an application on the host computer would analyze to determine the appropriate action and the memory destination for the incoming data payload. Combining SMB's session layer header analysis with Kiyohara’s hardware offloading architecture rendered the claims obvious. Dependent claims were addressed by arguing that features like using a port number (claim 3) were inherent to TCP, which Kiyohara explicitly disclosed, and that transferring data via the network interface (claims 6, 11, 17) was an obvious implementation of Kiyohara's goal to reduce data copying.

    • Motivation to Combine (for §103 grounds): Petitioner asserted a strong motivation to combine these references. A person of ordinary skill in the art (POSITA) seeking to implement Kiyohara’s high-speed peripheral sharing system, which explicitly contemplated a session layer, would naturally look to a prevalent and standardized session-level protocol like SMB for that very purpose. Implementing Kiyohara’s system with SMB would facilitate interoperability with the vast number of systems using Microsoft operating systems, providing the predictable and advantageous result of a high-performance, compatible file and print sharing system.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because SMB was designed to be implemented over standard network stacks like OSI and TCP/IP, both of which were disclosed and supported by Kiyohara’s intelligent board system. The combination represented the integration of a standard software protocol onto a known, compatible hardware architecture and would not have presented undue technical burden.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 6, 7, 10, 11, 13, 16, and 17 of the ’699 patent as unpatentable.