PTAB

IPR2022-00916

Major Data UAB v. Bright Data Ltd

Title: Content Delivery Networking
Brief Description: The ’510 patent discloses a system for content delivery using a peer-to-peer network where communication devices can act as clients, agents, or peers. The claimed method involves an intermediate "first client device" that receives a content request from a "second server," retrieves the requested content from a web server, and forwards that content to the second server over an established Transmission Control Protocol (TCP) connection.

Prior Art Relied Upon: Reiter et al., “Crowds: Anonymity for Web Transactions” (Nov. 1998) (“Crowds”).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Crowds, which discloses an anonymous web browsing system, anticipates the challenged claims. In Crowds, user computers called "jondos" form random paths to forward requests to a web server. Petitioner mapped the claimed "first client device" to the final jondo in a path before the destination web server, and the "second server" to the jondo immediately preceding it. Crowds disclosed that these jondos communicate over a static path comprising TCP/IP connections. In Petitioner’s mapping, the final jondo (first client device) receives a request from the preceding jondo (second server), sends the request to the web server, receives the content, and then sends the content back to the preceding jondo over the established TCP connection, thereby disclosing every element of claim 1.
- Key Aspects: The argument relied on the interchangeable client-server roles of jondos within the communication path, where one jondo acts as a server to its successor on the path.

Prior Art Relied Upon: Crowds, Fielding et al., “Hypertext Transfer Protocol – HTTP/1.1,” RFC 2616 (June 1999) (“RFC 2616”), and general knowledge of a POSITA.
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that to the extent Crowds was not found to anticipate the claims, they would have been obvious. Crowds disclosed a system for improving web communications that inherently uses TCP and HTTP protocols. RFC 2616, the definitive specification for HTTP/1.1 at the time, disclosed standard techniques for features recited in the dependent claims. For example, RFC 2616 taught using “keep-alive” messages to maintain persistent connections (relevant to claims 8-9) and using “Cache-Control” headers to determine the validity of retrieved content (relevant to claims 10-11).
- Motivation to Combine: A POSITA implementing the web proxy system of Crowds would combine its teachings with well-known Internet standards documented in RFC 2616. The motivation was to use standard, efficient, and reliable methods for handling common web tasks like connection management and content validation, which was the exact purpose of protocols defined in RFC 2616.
- Expectation of Success: Combining the system in Crowds with the standard, universally adopted HTTP/1.1 protocols from RFC 2616 would have been a straightforward implementation with a high expectation of success, as these were established and proven techniques for web communication.

Prior Art Relied Upon: Border (Patent 6,795,848).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Border, which teaches a system for relieving network latency using proxy servers, anticipates the challenged claims. Border explicitly disclosed a system with an upstream proxy server (107), a downstream proxy server (105), and a web server (109). Petitioner mapped the "first client device" to the upstream server and the "second server" to the downstream server. Border expressly teaches establishing a persistent TCP (“P-TCP”) connection between these two proxy servers. In operation, the upstream server receives a request from the downstream server, retrieves content from the web server, and forwards the content to the downstream server over the established TCP connection, directly anticipating claim 1. Dependent claims related to caching and HTTP requests were also disclosed.
Additional Grounds: Petitioner asserted additional challenges, including anticipation of claims 1, 6-8, 13, 15-16, and 18-24 by MorphMix (a doctoral thesis on a peer-to-peer anonymous access system). Obviousness challenges over Border in view of RFC 2616 and over MorphMix in view of RFC 2616 were also asserted, relying on similar motivations to combine foundational web standards with the primary prior art references.

Petitioner adopted claim constructions from a related district court litigation. The central constructions were role-based and not tied to specific hardware.
"client device": "communication device that is operating in the role of a client."
"second server": "a device that is operating in the role of a server and that is not the first client device."
Petitioner argued these constructions were critical because they allow a single device in the prior art (e.g., a "jondo" in Crowds or a proxy server in Border) to satisfy the role of a "server" relative to one device and a "client" relative to another within the same system. This flexibility was essential to mapping the peer-to-peer and proxy chain architectures of the prior art onto the claim language.

Petitioner filed the petition concurrently with a motion for joinder with an already-instituted IPR (IPR2021-01493) against the same ’510 patent.
Petitioner argued that discretionary denial under §314(a) would be inappropriate because this petition is "substantially identical" to the petition in the instituted IPR, asserting the same grounds, claims, prior art, and supporting evidence. Joinder would promote efficiency and avoid inconsistent results without placing undue burden on the Patent Owner or the Board.

Petitioner requests institution of an inter partes review and cancellation of claims 1-2, 6-11, 13, and 15-24 of the ’510 patent as unpatentable.