Unified Patents LLC v. AccElErated Memory Tech LLC

1. Case Identification

• Case #: IPR2020-00191
• Patent #: 6,513,062
• Filed: December 3, 2019
• Petitioner(s): Unified Patents Inc.
• Patent Owner(s): Accelerated Memory Tech, LLC
• Challenged Claims: 1-7

2. Patent Overview

• Title: Efficient Generation of Responses for Repeated Resource Requests
• Brief Description: The ’062 patent discloses a system for improving server efficiency by caching intermediate states generated during responses to resource requests. The system avoids the computational expense of repeatedly mapping an "external name" (e.g., a URI) to an "internal name" for a resource by caching the mapping result and using it for subsequent requests for the same resource.

3. Grounds for Unpatentability

Ground 1: Obviousness over Jenkins - Claims 1-7 are obvious over Jenkins

• Prior Art Relied Upon: Jenkins (Patent 6,014,667).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Jenkins, which was not considered during prosecution, discloses every element of the challenged claims. Jenkins describes a method for improving efficiency in a distributed computer system by caching information. In Jenkins, a client receives a first "application request" for an object identified by a "distinguished name" (the claimed "external name"). The client obtains a corresponding "internal identifier" (the claimed "internal name") from a server. This mapping result, which constitutes "intermediate state information," is then stored as a "tuple" in a local cache. For a subsequent request for the same object, the client retrieves the tuple from the cache and uses the internal identifier to efficiently access the object, bypassing the initial lookup steps. Petitioner asserted this process directly maps to the method of independent claim 1 and the apparatus of claim 4.
  • Motivation to Combine (for §103 grounds): As a single-reference ground, the argument was that Jenkins itself provides the motivation for its claimed features. Jenkins explicitly states its purpose is to "improve the speed and efficiency" of a distributed system, which Petitioner argued would have made its application to the problem solved by the ’062 patent obvious to a Person of Ordinary Skill in the Art (POSITA). For dependent claims, Jenkins was alleged to disclose storing a "type" of the resource (e.g., replica flags indicating read-only or read-write status) and caching the resource itself.
  • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success in applying the teachings of Jenkins, as Jenkins describes a functioning system designed to achieve the same efficiency goals as the ’062 patent using the same fundamental caching approach.

Ground 2: Obviousness over Huitema and Mogul - Claims 1, 4, and 6 are obvious over Huitema in view of Mogul

• Prior Art Relied Upon: Huitema (Patent 6,016,512) and Mogul (Patent 6,262,987).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that Huitema discloses the core process of claim 1 through its description of traditional Domain Name System (DNS) processing. In Huitema, a local server receives a first request containing a domain name (the "external name") to access a remote computer (the "resource"). The server performs a lookup process to translate the domain name into an IP address (the "internal name" and "intermediate state information"). Huitema explicitly teaches caching this IP address. Upon receiving a second request for the same domain name, the server retrieves the IP address from its local cache to generate a response, thus improving efficiency.
  • Motivation to Combine (for §103 grounds): Petitioner argued that while Huitema teaches the process, it does not explicitly describe the data structure for its cache. Mogul remedies this by teaching that DNS caches store "name-to-address binding" information in data structures like a "table on a disk." A POSITA would combine Mogul's teaching of using a standard table structure with Huitema's DNS caching system. This combination was presented as a simple, well-known, and predictable implementation detail for efficiently storing and retrieving the DNS records described by Huitema.
  • Expectation of Success (for §103 grounds): A POSITA would have had a clear expectation of success, as combining a known caching process (Huitema) with a standard data storage method for that exact type of data (Mogul) was a common and routine practice in network and system design.

4. Key Claim Construction Positions

• "external name": Petitioner proposed this term be construed as "an identifier used in requesting a resource." This construction was argued to be consistent with the specification's description of a URI as an example and was broad enough to cover the "distinguished name" in Jenkins and the "domain name" in Huitema.
• "internal name": Petitioner proposed this term be construed as "an identifier that can be used to locate a resource." This was based on specification examples like a filesystem location and was crucial for mapping the "internal identifier" of Jenkins and the "IP address" of Huitema to the claim language.
• "intermediate state information": Petitioner argued this term should be construed to comprise, at a minimum, the "internal name" that is the "result of mapping." This construction was supported by the plain language of claim 1 and the prosecution history, where the applicant distinguished prior art by focusing on the caching of this mapping result rather than the resource itself.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise its discretion to deny institution under 35 U.S.C. §§ 314(a) or 325(d). The primary reasons asserted were that none of the cited prior art (Jenkins, Huitema, Mogul) was considered during the original examination, and the petition's arguments do not overlap with those made during prosecution. Furthermore, the petition noted that the ’062 patent had not been challenged in any prior IPR. Petitioner also highlighted that the Patent Owner is a non-practicing entity (NPE) that had filed multiple infringement suits, suggesting that institution would serve the public interest by efficiently addressing the patent's validity.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-7 of the ’062 patent as unpatentable.