PTAB

IPR2025-00714

Databricks Inc v. Byteweavr LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Network System Extensible By Users
  • Brief Description: The ’733 patent describes a method for allowing end-users to program or extend a network system. The invention involves admitting a user to a system where software agents consume service resources to perform tasks, and where the user is allowed to create, modify, or delete these agents.

3. Grounds for Unpatentability

Ground 1: Claims 37-43 are obvious over Chow in view of White

  • Prior Art Relied Upon: Chow (Patent 6,029,175) and White (Patent 5,603,031).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chow discloses a "Revision Manager," which is a software agent that automatically monitors and retrieves changed web documents for a user. This agent operates on a network, consumes resources (e.g., monetary costs for retrieval, cache memory, processing time), and performs tasks for the user. Chow also allegedly discloses user interfaces that allow a user to specify a document to monitor (creating an agent), specify an updated monitoring interval (modifying an agent), and cancel a registration (deleting an agent). Petitioner contended these teachings meet the limitations of independent claim 37 and that Chow's disclosures of agent commands (GET/POST), agent suspension, and template commands map to dependent claims 38-43.
    • Motivation to Combine: Petitioner asserted that Chow’s system uses a "remote procedure calling" model, where a stationary agent repeatedly polls a remote server. White was presented as teaching a superior "remote programming" model using mobile agents that travel to the remote location, reducing network traffic and increasing flexibility. Petitioner argued a POSITA would combine White’s mobile agent architecture with Chow’s system to gain these well-documented and predictable benefits. Chow itself was said to suggest using mobile code to reduce latency, further motivating the combination.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination represented a simple substitution of one known, superior technique (remote programming) for another (remote procedure calling) to achieve predictable improvements.

Ground 2: Claims 37-43 are obvious over Lee in view of White

  • Prior Art Relied Upon: Lee (Patent 6,263,358) and White (Patent 5,603,031).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lee discloses a "Collaborative Agent Building System" (CABS), a toolkit for building and managing software agents. Lee’s agents were described as consuming resources (e.g., network bandwidth, processing capacity) to perform tasks for a user. Lee's CABS platform allegedly includes an "agent template" and user-facing tools, such as an "agent definition editor" and a "Control Monitor Tool," that allow a user to create, modify, suspend, and delete agents and their parameters within the network system. These functionalities were argued to map to all limitations of the challenged claims.
    • Motivation to Combine: Lee was characterized as providing a robust framework for building stationary, collaborative agents while acknowledging the desirability of mobile agent systems. Petitioner argued that a POSITA would have been motivated to improve the communication and interaction between agents in Lee’s system by incorporating the advanced mobile agent paradigm taught by White. This combination would enhance the flexibility and efficiency of Lee's agent-building framework by leveraging White's paradigm-shifting approach to agent mobility.
    • Expectation of Success: A POSITA would have expected success in combining the references because both teach object-oriented systems (Lee specifically suggests Java), making the integration of White’s mobile agent architecture into Lee's agent-building framework technically straightforward and predictable.

4. Key Claim Construction Positions

  • "agent": This term was identified as central to the dispute. Petitioner noted that in a prior IPR on a related patent ('752 patent), the Board construed "agent" based on the incorporated White reference as being inherently mobile: "a process that occupies a place and that is mobile, i.e., can move from a first place to a second place."
  • Petitioner also acknowledged a broader construction proposed by the Patent Owner in co-pending litigation: "a software application, program, or process responsible for performing a task on behalf of a user." Petitioner asserted that its obviousness arguments are meritorious and render the challenged claims unpatentable under either construction.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv would be inappropriate. The core arguments were:
    • The parallel district court litigation is in its early stages, with minimal investment by the parties and court.
    • The scheduled trial date is speculative and likely to be delayed past the statutory deadline for a Final Written Decision in this IPR.
    • Petitioner stipulated that it will not pursue in district court any invalidity ground on which IPR is instituted, mitigating concerns of duplicative efforts.
    • The merits of the petition are exceptionally strong, referencing a Board decision to institute a prior IPR on a related patent based on the same Chow and White references.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 37-43 of the ’733 patent as unpatentable under 35 U.S.C. §103.