PTAB

IPR2022-00915

Major Data UAB v. Bright Data Ltd

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1. Case Identification

2. Patent Overview

  • Title: Retrieving Web Content Via Proxy Network
  • Brief Description: The ’319 patent describes a method for retrieving web content using a three-part architecture: a "first server" (a web server), a "second server" (a requesting device), and an intermediate "first client device" that acts as a proxy to fetch content from the first server on behalf of the second server.

3. Grounds for Unpatentability

Ground 1: Anticipation by Crowds - Claims 1, 19, and 21-29 are anticipated by Crowds.

  • Prior Art Relied Upon: Crowds (Reiter et al., "Crowds: Anonymity for Web Transactions," a 1998 journal article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Crowds, which discloses a system for anonymizing web requests by routing them through a randomized path of peer computers called "jondos," meets every limitation of claim 1. Petitioner identified a specific data path in Crowds where one jondo acts as the claimed "first client device," a preceding jondo in the path acts as the "second server," and the destination web server acts as the "first server." In this configuration, the first client device receives a content request (the "first content identifier") from the second server, sends a corresponding HTTP request to the first server, receives the content back from the first server, and then sends that content back to the second server, mirroring the claimed method steps.
    • Key Aspects: The argument relies on mapping the functional roles of the claimed devices onto the peer nodes of the Crowds system, consistent with the proposed claim constructions. Dependent claims were also allegedly disclosed, as Crowds describes using TCP/IP, operating systems, and downloadable software for its jondos.

Ground 2: Anticipation by Border - Claims 1, 12, 14, 21-22, 24-25, and 27-29 are anticipated by Border.

  • Prior Art Relied Upon: Border (Patent 6,795,848).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Border, which describes a system for relieving network latency using a chain of proxy servers, anticipates the challenged claims. Petitioner mapped Border's "upstream proxy server" to the claimed "first client device," its "downstream proxy server" to the "second server," and its "web server" to the "first server." This prior art architecture performs the claimed method: the upstream server receives a URL request from the downstream server, sends the request to the web server, receives the content, and forwards the content back to the downstream server.
    • Key Aspects: Border explicitly describes the use of HTTP, TCP, caching (claim 12), and validity checks for cached content (claim 14), allegedly disclosing the limitations of several dependent claims directly. The system components in Border, running on standard computers, were argued to satisfy the functional definitions of the claimed devices.

Ground 3: Anticipation by MorphMix - Claims 1, 17, 19, and 21-29 are anticipated by MorphMix.

  • Prior Art Relied Upon: MorphMix (Rennhard, "MorphMix - A Peer-to-Peer-based System for Anonymous Internet Access," a 2004 doctoral thesis).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that MorphMix, a circuit-based peer-to-peer network for anonymous internet access, also anticipates the claims. In an example data path, the final node before the destination server acts as the "first client device," an intermediate node in the path acts as the "second server," and the target web server is the "first server." The system operates by passing application data (containing the URL) along the path of nodes to the final node, which then requests the content from the web server and sends the received content back along the path in reverse.
    • Key Aspects: This argument, similar to the Crowds ground, relies on the functional behavior of nodes within a peer-to-peer network to meet the claim limitations. Petitioner argued MorphMix's disclosure of nodes communicating to maintain virtual tunnels and handle web requests inherently constitutes the periodic communication required by claim 17.

  • Additional Grounds: Petitioner asserted additional obviousness challenges over Crowds, Border, and MorphMix, each in separate combination with general knowledge and RFC 2616 (the specification for HTTP/1.1). These grounds argued that to the extent any minor feature was not explicitly disclosed, it would have been obvious to a POSITA to implement it using well-known standards.

4. Key Claim Construction Positions

  • Petitioner adopted constructions from a related district court case for key disputed terms, arguing they are consistent with the patent's specification and allow the prior art to be properly mapped.
  • "client device": Construed as "a communication device that is operating in the role of a client." Petitioner argued this functional definition is broad and does not require a specific type of hardware (e.g., a consumer computer).
  • "second server": Construed as "a device that is operating in the role of a server and that is not the first client device."
  • The importance of these functional constructions is central to Petitioner's case, as it allows components like proxy servers (Border) or peer nodes (Crowds, MorphMix) to be mapped to the claimed "client device" and "second server" based on their behavior within their respective systems.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial by stating this petition was filed concurrently with a motion for joinder to IPR2021-01492 ("the NetNut IPR"), an inter partes review against the same ’319 patent that the Board had already instituted.
  • Petitioner asserted that this petition is substantially identical to the one in the instituted NetNut IPR, presenting the same grounds, prior art, and arguments against the same claims, differing only in the identity of the petitioner.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-2, 12, 14-15, 17-19, and 21-29 of the ’319 patent as unpatentable.