PTAB

IPR2018-01594

Microsoft Corp v. Saint Regis Mohawk Tribe

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Accelerating Web Site Access Utilizing Reconfigurable Processors
  • Brief Description: The ’687 patent discloses systems for accelerating data processing at an internet site. The invention uses a hybrid computer system comprising standard microprocessors and reconfigurable processors, such as Field Programmable Gate Arrays (FPGAs), that operate under a single operating system image to overcome the performance limitations of conventional web servers.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-5, 8-12, 16-19, and 22-25 by Obelix

  • Prior Art Relied Upon: Obelix (Knezevic, P. et al., “The Architecture Of The Obelix-An Improved Internet Search Engine,” a paper published in January 2000).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Obelix, which was not before the examiner, disclosed every limitation of the challenged claims. Obelix described an internet search engine server implemented on a PC or Alpha computer (the microprocessor) augmented with commercially available reconfigurable PCI boards containing Xilinx FPGAs (the reconfigurable processing elements). This server, located at an internet site, received IP packets containing user action data (the “N data elements”) from remote client computers. Petitioner asserted Obelix taught instantiating multiple “basic units” on the FPGAs to process these data elements in parallel, with each basic unit calculating a weighted score for a specific URL based on user actions. Dependent claims relating to selecting and displaying content were allegedly met by Obelix’s function of re-ranking and returning search results to the user.

Ground 2: Claims 1-10, 16, 17, 22, and 23 are obvious over Obelix in view of Spencer

  • Prior Art Relied Upon: Obelix (the 2000 journal article) and Spencer (Patent 5,577,241).
  • Core Argument for this Ground:
    • Prior Art Mapping: To the extent Obelix might not explicitly teach processing data elements “with corresponding ones” of reconfigurable processing elements, Petitioner argued Spencer supplied this teaching. Spencer disclosed an information retrieval system using FPGAs with multiple “QueryNodes,” where N processing nodes were instantiated, one for each of the N received data elements (operators) comprising a complex query. The combination would therefore result in a system where each data element from Obelix is processed by a corresponding processing unit as taught by Spencer.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Spencer's technique of parsing complex queries into component parts with Obelix's parallel FPGA processing architecture. Both references are in the analogous art of information retrieval using reconfigurable hardware. The combination would have been a predictable way to improve the database searching algorithm, handle more complex queries, and increase overall system speed.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved applying the known query-parsing benefits of Spencer to the known parallel processing hardware of Obelix to achieve the predictable result of a faster, more efficient search system.

Ground 3: Claims 5, 12, 13, and 19 are obvious over Obelix in view of Perkins

  • Prior Art Relied Upon: Obelix (the 2000 journal article) and Perkins (Patent 7,072,888).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that if Obelix was found not to disclose the use of “demographic data” as required by claims 5, 12, 13, and 19, Perkins remedied this deficiency. Perkins taught a process for refining internet search engine results using a registered user’s demographic profile data, such as gender, age, and location, to rank and select search results.
    • Motivation to Combine: A POSITA would combine the teachings of Perkins with the Obelix system to provide more personalized and relevant search results. It was well-known in the art that combining different data types, such as the user activity data from Obelix and the demographic data from Perkins, could improve search result quality. This would have been a simple and logical enhancement to the Obelix system.
    • Expectation of Success: The combination represented an arrangement of old elements for their known purposes, yielding the predictable result of search rankings based on both user actions and demographic data. A POSITA would have expected this combination to work without unpredictable results.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations of Obelix with Leong (for teaching decryption of data elements on FPGAs), Curtis (for teaching database query elements), Davis (for teaching a single system image operating system for reconfigurable hardware), and Skillen (for teaching the selection of content like advertisements based on user data).

4. Key Claim Construction Positions

  • “a content of said site”: Petitioner argued this phrase should be construed to mean information whose substance or meaning can be altered by the site, connoting an ownership or control relationship (e.g., the site’s own editorial content). Petitioner contended this is distinct from the Patent Owner’s apparent litigation position that the phrase means any content transmitted from the site, such as a list of third-party search results. This distinction is critical, as Obelix’s search results would likely not meet Petitioner’s proposed construction.
  • “a single system image of an operating system”: Petitioner asserted this is a term of art that should be construed to mean an operating system that provides the user the illusion that a collection of otherwise independent computing engines is a single computational resource. This construction is central to Petitioner’s argument that Obelix’s system, where the host CPU’s operating system controls the attached FPGA boards, meets the limitations of claims 10, 11, and 24.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-25 of the ’687 patent as unpatentable.