PTAB

IPR2018-00129

Riot Games, Inc. v. PalTalk Holdings, Inc.

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1. Case Identification

2. Patent Overview

  • Title: Server-Group Messaging System for Interactive Applications
  • Brief Description: The ’523 patent describes a system for managing networked, multi-person interactive applications. It purports to improve network efficiency by using a central "group messaging server" to receive messages from multiple host computers, aggregate them, and then forward the aggregated messages to the hosts participating in an application.

3. Grounds for Unpatentability

Ground 1: Obviousness over Aldred and RFC 1692 - Claims 1-10, 16-18, 31-37, 41-42, and 44-47 are obvious over Aldred in view of RFC 1692.

  • Prior Art Relied Upon: Aldred (International Publication No. WO 94/11814) and RFC 1692 (Transport Multiplexing Protocol, Aug. 1994).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Aldred discloses a collaborative working environment for networked workstations that performs all steps of the challenged claims except for "aggregating" message payloads. Aldred teaches a "Central Serialisation Point" (CSP), which Petitioner contended is analogous to the claimed "group messaging server." This CSP is located on a participating node and maintains consistency for a "sharing set" (the claimed "message group") by collecting all events at a central point and broadcasting them to ensure each application receives the same sequence of data. Petitioner asserted that RFC 1692, which describes the Transport Multiplexing Protocol (TMux), teaches the missing "aggregating" limitation by disclosing a method to combine multiple short transport segments into a single, larger IP datagram to reduce network and host load.
    • Motivation to Combine: A POSITA would combine Aldred with RFC 1692 to improve network efficiency. Aldred's system, which sends frequent small updates like drawing orders or chat messages, would generate many small packets. RFC 1692 is explicitly designed to solve this exact problem by multiplexing small packets. Furthermore, Aldred suggests implementing data multiplexing below the application layer and is designed to be transport-agnostic, making the integration of an IP-level enhancement like TMux a natural and predictable solution.
    • Expectation of Success: A POSITA would have had a high expectation of success because Aldred's system supports TCP/IP, and RFC 1692 is a well-known extension to the Internet Protocol. Combining the two would be a straightforward application of known networking principles to improve the performance of Aldred's collaborative system.

Ground 2: Obviousness over Aldred, RFC 1692, and RFC 1459 - Claims 38-40 are obvious over Aldred in view of RFC 1692 and RFC 1459.

  • Prior Art Relied Upon: Aldred (WO 94/11814), RFC 1692, and RFC 1459 (Internet Relay Chat Protocol, May 1993).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the combination of Aldred and RFC 1692 from Ground 1 and adds RFC 1459 to teach the limitations of claims 38-40, which relate to querying a server for a list of available message groups. While Aldred discloses APIs for applications to interact with the system, Petitioner argued it does not explicitly teach querying a central server to discover other message groups. RFC 1459, which describes the Internet Relay Chat (IRC) protocol, teaches a system where a client can send a control message to a central server to query for a list of available channels (which Petitioner asserted are analogous to message groups).
    • Motivation to Combine: A POSITA would be motivated to incorporate the querying functionality of RFC 1459 into the Aldred/RFC 1692 system to improve its usability. This would allow a user or node to discover new, existing "sharing sets" without needing to receive constant, traffic-intensive status broadcasts about all available sets. This modification would reduce unnecessary network traffic while allowing for dynamic discovery of collaborative sessions.
    • Expectation of Success: Adding a well-known query-response mechanism from a system like IRC to a collaborative messaging system like Aldred's was a simple and predictable design choice for a POSITA seeking to enhance functionality.

Ground 3: Obviousness over Aldred, RFC 1692, and Denzer - Claim 43 is obvious over Aldred in view of RFC 1692 and Denzer.

  • Prior Art Relied Upon: Aldred (WO 94/11814), RFC 1692, and Denzer (Patent 5,307,413).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Denzer to the base combination of Aldred and RFC 1692 to teach the specific limitation of "compressing said aggregated payload" recited in claim 43. The combination of Aldred and RFC 1692 results in an aggregated (multiplexed) message. Denzer discloses a data compression facility that intercepts TCP/IP packets, compresses their payloads using known algorithms, and then transmits the smaller packets.
    • Motivation to Combine: A POSITA would be motivated to add Denzer's compression technique to the Aldred/RFC 1692 system for the complementary benefits of network optimization. The RFC 1692 combination reduces the number of packets, while Denzer's compression reduces the size of each packet (the amount of data transmitted). Applying both techniques together provides a more comprehensive solution to reducing network load, a well-understood goal in network design.
    • Expectation of Success: Both multiplexing and compression were well-known, compatible techniques for improving network performance. A POSITA would have reasonably expected to successfully apply Denzer's compression to the multiplexed packets generated by the Aldred/RFC 1692 system, as it is a predictable combination of known elements to achieve a known benefit.

4. Key Claim Construction Positions

  • Petitioner argued that the challenged claims are obvious even under the claim constructions for key terms that the Patent Owner previously advanced in related district court litigation.
  • Specifically for "group messaging server" and "aggregating," Petitioner contended that Aldred's CSP and the teachings of RFC 1692, respectively, satisfy the limitations even as construed by the Patent Owner. Therefore, Petitioner asserted that the Board did not need to resolve the precise scope of these terms to find the claims unpatentable.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-10, 16-18, and 31-47 of Patent 5,822,523 as unpatentable under 35 U.S.C. §103.