Major Data UAB v. Bright Data Ltd.

1. Case Identification

• Case #: IPR2022-00916
• Patent #: 10,484,510
• Filed: April 21, 2022
• Petitioner(s): MAJOR DATA UAB
• Patent Owner(s): BRIGHT DATA LTD.
• Challenged Claims: 1-2, 6-11, 13, 15-24

2. Patent Overview

• Title: Peer-to-Peer Content Delivery Network
• Brief Description: The ’510 patent describes a system for accelerating web content delivery using a peer-to-peer network. In the system, communication devices can function interchangeably as "clients" (requesting content), "agents" (retrieving content from an origin server or peers), and "peers" (caching and serving content). The method of the independent claims involves a "first client device" (acting as a proxy) establishing a TCP connection with a "second server" (the original content requester) to relay web content.

3. Grounds for Unpatentability

Ground 1: Anticipation over Crowds - Claims 1, 6-7, 15-16, and 18-24 are anticipated by Crowds under 35 U.S.C. §102.

• Prior Art Relied Upon: Crowds (Reiter, M. et al., “Crowds: Anonymity for Web Transactions,” Nov. 1998).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Crowds, a system for anonymizing web traffic, discloses every element of the challenged claims. In Crowds, user computers run processes called "jondos" that form a network ("crowd"). A web request is forwarded along a random path of jondos before reaching the final web server. Petitioner asserted that this maps directly to the claims:
    • A jondo acting as the final intermediary before the web server is the "first client device."
    • A preceding jondo in the path that forwards the request is the "second server."
    • Crowds explicitly discloses using TCP/IP connections between jondos.
    • The "first client device" (final jondo) sends a content identifier (URL) to the "web server," receives the content, and sends it back to the "second server" (prior jondo) over the established TCP connection, thus anticipating the steps of claim 1. Dependent claims reciting features like running a browser, using HTTP, and having a client OS are also allegedly disclosed, as jondos run on standard computers with browsers and operating systems.

Ground 2: Anticipation over Border - Claims 1, 6, 10, 15-20, 23, and 24 are anticipated by Border under §102.

• Prior Art Relied Upon: Border (Patent 6,795,848).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that Border, which describes relieving network latency using proxy servers, anticipates the claims. Border discloses a system with a user station, a downstream proxy server, and an upstream proxy server that communicate to retrieve content from a web server. Petitioner mapped the claim elements as follows:
    • The "first client device" is Border’s upstream proxy server (107).
    • The "second server" is Border’s downstream proxy server (105).
    • The "web server" is Border's web server (109).
    • Border explicitly shows a persistent TCP ("P-TCP") connection between the upstream and downstream servers.
    • The upstream server sends a request (content identifier) to the web server, receives the content, and forwards it to the downstream server over the P-TCP connection, meeting all steps of claim 1. Petitioner argued that dependent claims related to caching, validity checks, and HTTP requests are also expressly taught by Border’s proxy server architecture.

Ground 3: Anticipation over MorphMix - Claims 1, 6-8, 13, 15-16, and 18-24 are anticipated by MorphMix under §102.

• Prior Art Relied Upon: MorphMix (Rennhard, M., “MorphMix – A Peer-to-Peer-based System for Anonymous Internet Access,” 2004).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner asserted that MorphMix, another peer-to-peer anonymity system, anticipates the challenged claims. MorphMix creates an anonymous tunnel by routing traffic through a series of nodes (e.g., node A → node B → node C → web server S). Petitioner mapped the claims to this architecture:
    • The "first client device" is the final node in the tunnel (node C).
    • The "second server" is an intermediate node in the tunnel (node B).
    • MorphMix is based on TCP connections between all nodes.
    • Node C sends the content identifier (application data containing a URL) to the web server S, receives the content, and sends it back to the "second server" (node B) over the established TCP connection. This process allegedly meets all limitations of claim 1. Petitioner further argued that MorphMix discloses that nodes are standard computers capable of running browsers and operating systems, thereby anticipating various dependent claims.

• Additional Grounds: Petitioner asserted additional obviousness challenges over each of the primary references (Crowds, Border, and MorphMix) in view of RFC 2616 (the HTTP/1.1 standard) and the general knowledge of a Person of Ordinary Skill in the Art (POSITA). These grounds argued that to the extent any minor claim feature was not explicitly disclosed, it would have been obvious to a POSITA to implement it using standard internet protocols and known techniques for caching, validation, and peer-to-peer communication.

4. Key Claim Construction Positions

• Petitioner adopted the constructions from a related district court litigation, arguing they are appropriate for the IPR. The key constructions are:
  • 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 emphasized that these constructions are critical because they allow a single device (e.g., a "jondo" in Crowds or a "node" in MorphMix) to be configured to operate in different roles, consistent with the flexible, peer-to-peer nature of the prior art systems. This interpretation prevents a narrow reading that would require specialized, distinct hardware for each role, which Petitioner argued is not supported by the claims or specification.

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under §314(a) by highlighting that the petition was filed with a motion for joinder to an already-instituted IPR: NetNut Ltd. v. [Bright Data Ltd](https://ai-lab.exparte.com/party/bright-data-ltd)., IPR2021-01493.
• Petitioner asserted that the present petition is "substantially identical" to the petition in the instituted NetNut IPR, presenting the same grounds, claims, prior art, and supporting evidence. Filing was only necessary because the current Petitioner is a different entity. This alignment with a previously instituted case was presented as a strong reason for the Board to institute and join this proceeding.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-2, 6-11, 13, and 15-24 of Patent 10,484,510 as unpatentable.