Unified Patents LLC v. III Holdings 12 LLC

1. Case Identification

• Case #: IPR2022-00136
• Patent #: 8,271,980
• Filed: November 29, 2021
• Petitioner(s): Unified Patents, LLC
• Patent Owner(s): III Holdings 12, LLC
• Challenged Claims: 1-5, 14-15

2. Patent Overview

• Title: System and Method of Providing System Jobs Within a Compute Environment
• Brief Description: The ’980 patent relates to a method for managing resources in a multi-node distributed computing environment. It discloses using administrative "system jobs" to monitor and manage user-submitted "compute jobs," distinguishing itself from the prior art through negative limitations specifying that these system jobs are not used for establishing resource reservations or for directly dispatching and executing the compute jobs.

3. Grounds for Unpatentability

Ground 1: Anticipation/Obviousness over Shawver - Claims 1-5 and 14-15 are anticipated by or obvious over Shawver.

• Prior Art Relied Upon: Shawver (Patent 8,726,278).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Shawver discloses all limitations of the challenged claims. Shawver describes a distributed computing environment where a server manages multiple workstations (“nodes”) to process complex projects, referred to as a “Job” (“compute job”). Shawver’s system uses various “functions” (claimed “system jobs”), such as setup, notification, and cleanup routines, to manage these Jobs. For independent claims 1 and 14, Petitioner asserted that Shawver’s “callback function” is a system job “associated” with a compute job when it is registered with the Job Manager. This compute job is “scheduled according to a reservation” when the server assigns its constituent tasks to specific workstation nodes. Critically, Petitioner argued that Shawver’s administrative functions (like sending a notification or deleting temporary files) are separate from and do not perform the actions carved out by the ’980 patent’s negative limitations—they do not establish resource reservations or directly execute the compute job.
  • Motivation to Combine (for §103 grounds): In the alternative, Petitioner contended that if Shawver's "functions" were considered to be executed on the central server rather than the individual nodes, a person of ordinary skill in the art (POSITA) would find it obvious to modify Shawver to execute them on the nodes. The motivation would be to improve efficiency and create a more robust system where nodes could locally manage cleanup and status reporting.
  • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success in making such a modification, as it involved applying known software engineering principles to distribute administrative tasks in a distributed system for predictable benefits.

Ground 2: Obviousness over Shawver in view of Nguyen - Claims 1-5 and 14-15 are obvious over Shawver in view of Nguyen.

• Prior Art Relied Upon: Shawver (Patent 8,726,278) and Nguyen (European Patent Publication EP 0 859 314 A2).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was presented to address any potential argument that Shawver’s "associating" step (registering a callback function) occurs before its "scheduling" step (assigning tasks to nodes). Nguyen discloses a distributed system for compiling source code using a “dmake process” (“compute job”). A central “Remote Execution Monitor” (RXM) process on a host machine initiates “Remote Execution Server” (RXS) processes (“system jobs”) on remote nodes to manage the compilation. Petitioner argued Nguyen explicitly teaches initiating these management processes after the corresponding compute job has been assigned to a remote node.
  • Motivation to Combine: A POSITA would combine Nguyen’s RXS functionality with Shawver's workstations to enhance local control and monitoring. This modification would simplify communication by allowing Shawver’s server to interact with a single, standardized RXS component on each node rather than multiple disparate functions. It would also create a safeguard, allowing individual nodes to monitor task completion and report errors independently of the central server.
  • Expectation of Success: Combining these known prior art elements would yield predictable results. The integration of Nguyen's established remote management process into Shawver's distributed computing framework was a straightforward application of known techniques to improve system robustness.

Ground 3: Obviousness over Nagato in view of Tran - Claims 1-5 and 14-15 are obvious over Nagato in view of Tran.

• Prior Art Relied Upon: Nagato (Application # 2002/0032716) and Tran (Patent 7,685,602).

• Core Argument for this Ground:

  • Prior Art Mapping: Nagato discloses a CPU time distribution system where a managing server assigns a user-submitted “program” (“compute job”) to available computers (“nodes”). The server also uploads a “post-processing program” (“system job”) to the node, which monitors the compute job’s execution and automatically sends results back upon completion. Petitioner argued this discloses the core limitations of associating a system job with a scheduled compute job. Tran was introduced to address any argument that Nagato’s system jobs are not executed by the node’s own resources. Tran describes a multi-node system where a "Remote Server Service" on each node includes a "Monitor Process" that locally tracks the execution of database queries (“compute jobs”).
  • Motivation to Combine: A POSITA would be motivated to incorporate Tran’s local monitoring and management capabilities into Nagato’s system to address the challenges of controlling processes in a distributed environment, a problem explicitly identified by Tran. This would provide Nagato’s managing server with a reliable mechanism to ensure jobs were executed correctly and to receive alerts if a process failed, improving overall system reliability.
  • Expectation of Success: A POSITA would have reasonably expected success in adding Tran's monitoring software to Nagato's nodes. This involved using a known remote service to improve a similar distributed system, a modification that required only routine engineering efforts to ensure software compatibility.

• Additional Grounds: Petitioner asserted additional challenges, including that claims 1-2, 4-5, and 14-15 are anticipated by Nagato, and that all challenged claims are obvious over Nagato in view of the knowledge of a POSITA.

4. Relief Requested

• Petitioner requests institution of an IPR and cancellation of claims 1-5 and 14-15 of the ’980 patent as unpatentable.