PTAB

IPR2022-00687

Metacluster LT UAB v. Bright Data Ltd

Key Events

Petition

petition Intelligence

Title: Method and system for fetching content
Brief Description: The ’622 patent describes a method for fetching web content where a "first server" acts as a proxy. The server receives a URL from a client device, selects an IP address from a stored group of IP addresses in response, and then uses that selected IP address to forward the request for content to a web server.

Prior Art Relied Upon: Kocherlakota (Patent 6,785,705).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Kocherlakota discloses a system of chained web proxies that performs the claimed method. In Kocherlakota, a client computer (the claimed "first client device") sends URL requests to a first proxy, proxy 17 (the claimed "first server"). Proxy 17 stores the IP addresses of downstream proxies 19 and 21 (the claimed "group of IP addresses"). Based on pre-configured rules that analyze the received URL, proxy 17 selects the IP address of either proxy 19 or proxy 21 and forwards the URL request onward through the proxy chain to the destination web server. This process, Petitioner contended, meets all limitations of independent claim 1.
- Motivation to Combine (for §103 grounds): As this is a single-reference ground, the argument was that a person of ordinary skill in the art (POSITA) would find it obvious to implement the system described, as Kocherlakota explicitly teaches the claimed configuration.
- Expectation of Success (for §103 grounds): A POSITA would have an expectation of success as Kocherlakota describes an operable system for routing web requests through a configurable proxy chain.

Prior Art Relied Upon: Kocherlakota (Patent 6,785,705) and RFC 1122 (Internet Engineering Task Force, Requirements for Internet Hosts – Communication Layers, Oct. 1989).
Core Argument for this Ground:
- Prior Art Mapping: This ground built upon Ground 1 to address dependent claims related to connection maintenance. RFC 1122 teaches a standard TCP "keep-alive" mechanism to verify that an idle connection is still active by sending periodic probes. Petitioner argued that this mechanism, when applied to the TCP sessions between proxies in Kocherlakota, would meet limitations requiring the receipt of a 'keep alive' message (claim 8), determining if a device is "currently online" (claim 9), and sending 'keep alive' messages (claim 11).
- Motivation to Combine (for §103 grounds): A POSITA would combine RFC 1122's standard keep-alive functionality with Kocherlakota’s proxy system to improve network stability and efficiency. This would prevent server applications from consuming resources on connections that have been dropped due to a client crash or network failure.
- Expectation of Success (for §103 grounds): Success would be expected because implementing a standard, well-documented TCP feature like keep-alive into a TCP-based proxy system was a routine network programming task.

Prior Art Relied Upon: Cohen (Patent 6,389,462).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Cohen discloses a system for transparently intercepting and redirecting web requests that teaches the claimed method. In Cohen, a client device (101-1) sends a web request. A proxy redirector (104), acting as the claimed "first server," intercepts this request. The proxy redirector stores a group of IP addresses for available proxy caches and selects one based on criteria like server load or the origin server's IP address. It then forwards the request to the selected proxy cache by translating the destination IP address of the request packet to the selected cache's IP address, thereby meeting the limitations of claim 1.
- Motivation to Combine (for §103 grounds): This is a single-reference ground. Petitioner argued that Cohen describes a complete system for proxy redirection that renders the challenged claims obvious.
- Expectation of Success (for §103 grounds): A POSITA would have an expectation of success as Cohen describes a fully functional system for transparently redirecting web traffic to improve latency and reduce network load.

"Client Device" and "First Server": Petitioner adopted constructions from related district court litigation, arguing that these terms are defined by the role a device performs in a given transaction, not by its hardware. A "client device" is a device "operating in the role of a client," and a "first server" is a device "operating in the role of a server" that is not the same device as the client device or the ultimate web server.
"sending ... to the ... web server": Petitioner argued this phrase should be construed to include sending to intermediaries for eventual forwarding to the web server, consistent with the court's construction in related litigation and the language of dependent claims 3 and 4.
"source address": For claim 27, which requires using the selected IP address as a "source address," Petitioner argued the claim is obvious under both the Patent Owner's proposed construction ("the IP address of the sender") and the court's construction ("the address of the source of content, which in Claim 1 is the web server").

Petitioner argued against discretionary denial, asserting the grounds were not cumulative of the art considered during prosecution of the ’622 patent. It was noted that the asserted references (Kocherlakota, Cohen, and RFC 1122) were submitted in an IDS but were never substantively analyzed or used in a rejection by the Examiner, whose only rejection was for double-patenting.

Petitioner requests institution of inter partes review and cancellation of claims 1-14, 16-17, 20-24, and 26-32 of the ’622 patent as unpatentable.