PTAB

IPR2022-00915

Major Data UAB v. Bright Data Ltd.

Title: Retrieving Content Through a Proxy
Brief Description: The ’319 patent describes a method for retrieving web content using an intermediate proxy device. The system involves a "second server" (a requesting device) that sends a request to a "first client device" (the proxy), which in turn retrieves the content from a "first server" (the target web server) and returns it along the same path.

Prior Art Relied Upon: Crowds (a 1998 article by Reiter and Rubin titled "Anonymity for Web Transactions").
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that the Crowds system for anonymizing web traffic anticipates the claimed method. Crowds describes a network of nodes ("jondos") that forward requests through a randomized path. Petitioner mapped the claim elements to a specific path in Crowds (e.g., jondo 4 -> jondo 6 -> web server), where jondo 6 is the "first client device" (proxy), jondo 4 is the "second server" (requesting node), and the web server is the "first server." In this configuration, jondo 6 receives a request from jondo 4, sends it to the web server, receives the content back, and sends the content to jondo 4, thereby meeting all steps of independent claim 1.
- Key Aspects: The argument relies on the functional roles of the jondos in the path, asserting that Crowds's client-server terminology for successive nodes on a path supports this mapping.

Prior Art Relied Upon: Border (Patent 6,795,848).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Border, which discloses using proxy servers to reduce network latency, teaches the claimed invention. The system in Border includes a user station -> downstream proxy server -> upstream proxy server -> web server. Petitioner mapped the "first client device" to Border’s upstream proxy server (107), the "second server" to the downstream proxy server (105), and the "first server" to the web server (109). The upstream proxy (107) receives a request from the downstream proxy (105), forwards it to the web server (109), receives the content, and returns the content to the downstream proxy (105), satisfying the limitations of claim 1.

Prior Art Relied Upon: MorphMix (a 2004 doctoral thesis by Marc Rennhard on anonymous internet access).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that MorphMix, a peer-to-peer system for anonymous web browsing, discloses the claimed method. MorphMix creates an anonymous tunnel through a series of nodes (e.g., node a -> node b -> node c -> server s). Petitioner mapped the "first client device" to the final node in the tunnel (node c), the "second server" to the intermediate node before it (node b), and the "first server" to the target web server (s). In this path, node c receives application data (the content identifier) from node b, sends a request to the server, receives the content, and sends it back to node b, directly mapping to the steps of claim 1.
Additional Grounds: Petitioner asserted corresponding obviousness challenges for all challenged claims based on Crowds, Border, or MorphMix in view of RFC 2616 and the general knowledge of a POSITA. These grounds argued that even if the primary references did not explicitly disclose every element (e.g., specific HTTP headers for validity checks or keep-alive messages), combining them with standard internet protocols like RFC 2616 would have been obvious.

"client device" / "second server": Petitioner argued that the central issue in the case is the patent's unconventional labeling of standard proxy architecture components. Petitioner adopted prior district court constructions where "client device" is a "communication device that is operating in the role of a client" and "second server" is "a device that is operating in the role of a server and that is not the first client device." Petitioner contended that these terms should not be limited to specific hardware (e.g., a "consumer computer"), as such limitations are not in the claims and would exclude embodiments from the specification. This broad, functional construction is critical to Petitioner's argument that the prior art proxy servers and nodes meet these limitations.

Relabeling of Standard Proxy Architecture: The petition's central technical contention was that the ’319 patent does not invent a new architecture but merely describes a conventional proxy data flow while assigning non-standard labels to the components. Petitioner argued that what the patent calls the "first client device" is functionally a proxy server, and what it calls the "second server" is functionally a client of that proxy. This alleged relabeling was presented as an attempt to create patentable distinction where none exists, a point central to all invalidity grounds.

Petitioner argued that discretionary denial would be inappropriate. The petition was filed concurrently with a motion for joinder with an already-instituted IPR (NetNut Ltd. v. Bright Data Ltd., IPR2021-01492), which challenges the same claims on the same grounds. Petitioner asserted that this petition is substantially identical to the one in the instituted NetNut IPR. Further, while a previous petition on the ’319 patent was denied on discretionary grounds, Petitioner distinguished the present case by noting it is not a party to any co-pending litigation involving the patent, altering the discretionary analysis.

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