PTAB

IPR2017-01736

Cavium Inc 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 describes a system for improving network performance by offloading protocol processing tasks from a host computer’s main CPU to a specialized processor on an "intelligent" network interface card. This creates a "fast path" that avoids burdening the host CPU with routine processing of TCP/IP packets.

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 Reduced Operation Protocol Engine (ROPE) for a multiple-layer bypass architecture,” 1995)
    • Tanenbaum96 (“Computer Networks,” 1996)

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Thia teaches the core inventive concept: a hardware-based system for offloading protocol processing to a network interface to create a high-speed "bypass" or "fast path." Thia’s system uses a Reduced Operation Protocol Engine (ROPE) chip on a network interface adapter to examine inbound packets and process them independently of the host CPU if they meet certain criteria, thereby relieving the host processor. While Thia described its architecture in the context of the OSI protocol, it explicitly stated its bypass concept could be used with "any standard protocol."

      Petitioner asserted that Tanenbaum96, a widely-cited textbook, supplied the missing details for applying Thia’s general architecture to the dominant TCP/IP protocol. Tanenbaum96 taught that TCP/IP had become the standard protocol for internetworking by the mid-1990s, displacing OSI. It described all the conventional TCP processing steps recited in the challenged claims, such as parsing packet headers to determine the protocol, using header prediction for fast-path processing, and generating a "flow key" (from source/destination IP addresses and ports) to look up a connection record in a hash table. Critically, Tanenbaum96 also explicitly taught that the "transport entity" performing TCP processing could be located on the network interface card. The combination of Thia’s offloading hardware architecture with the standard TCP/IP processing details from Tanenbaum96 allegedly rendered the claimed invention obvious.

    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would have been strongly motivated to combine the references. The primary motivation was to improve the performance of the dominant and rapidly growing TCP/IP protocol suite used for the Internet. A POSITA would have recognized the benefit of applying Thia's hardware acceleration and host-offloading concepts to the protocol that mattered most. Since Tanenbaum96 described TCP/IP as having "vanished" the OSI protocols (used in Thia’s example), adapting Thia’s system to TCP/IP was a logical and necessary step to make it commercially and technologically relevant. Further motivation arose from improving Thia's implementation; Tanenbaum96 provided specific, well-understood methods for TCP fast-pathing, such as using a hash key for connection lookup, which would optimize the general bypass test described in Thia.

    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success. Thia’s architecture was expressly designed to be protocol-agnostic. The layered nature of both OSI and TCP/IP protocols is intended to allow for such modular implementation, where a specific transport layer protocol (TCP) could be implemented on hardware (Thia's ROPE chip) without undue experimentation. The functional similarities between the OSI and TCP transport layers (e.g., checksumming, flow control, resequencing) would have made the adaptation straightforward. Furthermore, Tanenbaum96 presented TCP/IP not as a new or experimental protocol, but as a well-understood, standard one whose implementation details were widely known and available.

4. Relief Requested

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