Microsoft Corp v. Saint Regis Mohawk Tribe

1. Case Identification

• Case #: IPR2018-01607
• Patent #: 7,620,800
• Filed: September 6, 2018
• Petitioner(s): Microsoft Corporation
• Patent Owner(s): Saint Regis Mohawk Tribe
• Challenged Claims: 1-5, 18, and 21-23

2. Patent Overview

• Title: Multi-Adaptive Processing Systems and Techniques for Enhancing Parallelism and Performance of Computational Functions
• Brief Description: The ’800 patent discloses a method for data processing using a reconfigurable computing system. The system performs a "data driven" calculation where different data dimensions are processed simultaneously by "lines of code" formed as clusters of functional units on a reconfigurable processor.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 18, 21, and 22 by Splash2

• Prior Art Relied Upon: Splash2 (a 1996 book by Buell et al. describing the Splash 2 reconfigurable computing system).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Splash2, a seminal reconfigurable computer system using FPGAs, disclosed every element of the challenged claims. Splash2 described a system with reconfigurable processors (FPGAs) comprising a plurality of functional units, which it called Processing Elements (PEs). The book detailed implementing the "Edit Distance Algorithm" for genetic sequence comparison, which Petitioner asserted was a "data driven calculation" because operations were triggered by the arrival of data. This implementation involved forming PEs by compiling VHDL code and loading the resulting configuration data into FPGAs. These PEs processed different "data dimensions" (time steps of the systolic computation) concurrently in separate computational loops, with computed data passed directly ("seamlessly") between adjacent PEs. Petitioner further argued that the Edit Distance Algorithm as described in Splash2 inherently functioned as a search algorithm for data mining (claim 18), a genetic pattern matching function (claim 21), and was useful for protein folding applications (claim 22).

Ground 2: Claims 1, 18, 21, and 22 are obvious over Splash2 in view of Gaudiot

• Prior Art Relied Upon: Splash2 (a 1996 book by Buell et al.), Gaudiot (a 1987 IEEE publication on data-driven multicomputers).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Splash2 taught nearly all claim limitations, but to the extent its processing was not explicitly "data driven," Gaudiot supplied this teaching. Gaudiot disclosed multiprocessor techniques where operations are scheduled based on the availability of operands, a principle it explicitly termed "data-driven." Applying Gaudiot's data-driven principles to the systolic arrays of Splash2 would result in a system where the PEs perform comparison operations upon the arrival of sequence data, thereby explicitly satisfying the "data driven" limitation of claim 1.
  • Motivation to Combine: A POSITA would combine Splash2 and Gaudiot to solve the common problem of creating more efficient parallel processing systems. Gaudiot's teachings on the advantages of data-driven techniques—including scalability, maximum parallelism, and flexibility—would have motivated a POSITA to apply them to the powerful Splash2 hardware to improve performance in computationally intensive tasks like genetic sequence analysis.
  • Expectation of Success: The combination involved applying a known processing technique (data-driven scheduling from Gaudiot) to a known hardware architecture (systolic arrays on FPGAs from Splash2). This would have yielded the predictable benefits described in Gaudiot with a high expectation of success.

Ground 3: Claims 2-5, 22, and 23 are obvious over Splash2 in view of Roccatano, with or without Gaudiot

• Prior Art Relied Upon: Splash2 (a 1996 book by Buell et al.), Roccatano (a 1998 journal article on parallel molecular dynamics), and optionally Gaudiot.

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner asserted that implementing the algorithm from Roccatano on the Splash2 hardware would render the dependent claims obvious. Roccatano disclosed a systolic loop algorithm for simulating molecular dynamics, a process that inherently involves multiple vectors (e.g., atomic positions, satisfying claim 2), planes (for 2D/3D simulations, satisfying claim 3), time steps (satisfying claim 4), and grid points (atom locations, satisfying claim 5). Furthermore, Roccatano's simulation of the BPTI protein taught a "protein folding function" (claim 22) and an "organic structure interaction function" (claim 23).
  • Motivation to Combine: A POSITA would have been motivated to implement Roccatano's molecular dynamics algorithm on the Splash2 system because Splash2 was explicitly noted for achieving "supercomputer performance" in molecular biology applications. Combining a specific molecular biology algorithm from Roccatano with the high-performance reconfigurable hardware of Splash2 was a logical and predictable path to creating a more efficient simulation system.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in implementing a known systolic algorithm (Roccatano) on a known systolic processing platform (Splash2) to achieve the predictable result of an accelerated molecular dynamics simulation.

• Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 1, 18, 21, and 22 based solely on Splash2, arguing that even if not anticipating, its disclosures rendered the claims obvious.

4. Key Claim Construction Positions

• "functional unit": Petitioner proposed construing this term as "a computational unit configured to perform a specific task." This position was based on disclosures in the ’800 patent and its incorporated references showing these units are dedicated to specific processing tasks in both conventional CPUs and reconfigurable processors like FPGAs.
• "data driven": Petitioner proposed this term means "the scheduling of operations upon the availability of their operands." This construction was derived from an external technical reference cited on the face of the ’800 patent, which Petitioner argued reflected the ordinary meaning to a POSITA at the time.
• "form": Petitioner argued that "form" should be construed as "create, such as by configuring, a particular structure." This argument was based on equating the term with "instantiate," which was used in the parent patent and defined by the patentee during prosecution as creating a specific hardware configuration on a blank reconfigurable processor.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-5, 18, and 21-23 of Patent 7,620,800 as unpatentable.