PTAB

IPR2018-00338

Dell Inc v. Alacritech Inc

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1. Case Identification

2. Patent Overview

  • Title: Intelligent Network Interface Device and System for Accelerated Communication
  • Brief Description: The ’880 patent relates to a network interface device designed to accelerate network communications by offloading TCP/IP protocol processing from a host computer’s CPU. The device provides a "fast path" that identifies and processes certain network packets directly on the network interface hardware, thereby avoiding the processing overhead on the host system.

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 (Y. H. Thia and C. Murray Woodside, “A Reduced Operation Protocol Engine (ROPE) for a multiple-layer bypass architecture,” 1995)
    • Tanenbaum96 (Andrew S. Tanenbaum, “Computer Networks,” 1996)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Thia and Tanenbaum96 discloses all limitations of the challenged claims. Thia taught a hardware-based "fast path" system on a network interface adapter (NIA) using a Reduced Operation Protocol Engine (ROPE) chip to offload protocol processing from the host. Thia’s system used a "receive bypass test," a form of header prediction, to determine if an incoming packet should be processed on the fast path or by the host’s standard protocol stack. While Thia described its system using the OSI protocol model, it explicitly stated its architecture was suitable for "any standard protocol." Tanenbaum96, a widely-cited textbook, provided the specific details for implementing fast-path processing for the TCP/IP protocol, which it described as the dominant standard by the mid-1990s. Tanenbaum96 taught parsing packet headers to determine the protocol, using a "flow key" (composed of source/destination IP addresses and ports) to look up connection records in a hash table, and performing these transport layer functions on a network interface card. Petitioner contended that implementing Tanenbaum96's well-known TCP/IP fast-path methods on Thia's offloading hardware architecture would result in the claimed invention. For example, claim 1’s limitation of "parsing a header portion...to determine if said first packet conforms to a TCP protocol" on a network interface was met by combining Thia’s teaching of header processing on the NIA with Tanenbaum96’s teaching of standard TCP header parsing.
    • Motivation to Combine: Petitioner asserted that a Person of Ordinary Skill in the Art (POSITA) would have been motivated to combine the references to improve Thia's system and apply it to the prevalent networking environment of the time. By 1996, the OSI protocol described by Thia was largely obsolete, while TCP/IP, detailed in Tanenbaum96, was the dominant protocol for the rapidly growing internet. A POSITA would have sought to adapt Thia's performance-enhancing hardware offloading concept to the TCP/IP standard to make it commercially relevant and broadly applicable. Thia’s own disclosure that its architecture could be used with "any standard protocol" would have directly suggested this modification to a POSITA. Further, a POSITA would incorporate Tanenbaum96's specific methods for expediting connection lookups (e.g., using a hash table and key) to further optimize Thia's general framework.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. Both OSI and TCP/IP are layered protocol models with functionally similar transport layers, making the principles of protocol offloading readily transferable. The modular nature of layered protocols, as explained in Tanenbaum96, is designed to allow individual protocol layers to be replaced or modified without affecting others. Given that TCP/IP implementation code was widely available and understood, adapting Thia’s hardware offloading architecture from the general principles of OSI transport layer processing to the specific, well-documented steps of TCP/IP processing would have been a straightforward and predictable task for a POSITA, not requiring undue experimentation.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1, 5-10, 12, 14, 16, 17, 20-23, 27, 28, 45, and 55 of Patent 8,131,880 as unpatentable.