Databricks Inc v. Byteweavr LLC

1. Case Identification

• Case #: IPR2025-00715
• Patent #: 7,949,752
• Filed: March 13, 2025
• Petitioner(s): Databricks, Inc.
• Patent Owner(s): Byteweavr, LLC
• Challenged Claims: 24-25

2. Patent Overview

• Title: Extensible Network System
• Brief Description: The ’752 patent describes a network system augmented with a software agent system to make the network extensible by end-users. The invention focuses on invoking a network-based software agent in response to receiving a Uniform Resource Locator (URL) that defines an event type and identifies the agent.

3. Grounds for Unpatentability

Ground 1: Claims 24-25 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 asserted that Chow discloses nearly all limitations of independent claim 24. Chow teaches a software agent system (the “Revision Manager”) for automatically retrieving updated copies of internet documents. A user client invokes the Revision Manager agent by sending an HTTP command containing a URL. Petitioner argued this URL identifies the network-based agent (e.g., SomeRevisionManager.CompanyName.com) and defines a type of event (e.g., an "update" flag within the URL string). Chow’s agent performs an operation (retrieving a document) by using an online service and consuming a service resource (monetary costs, such as server or copyright charges). Petitioner contended that this monetary resource is exhausted upon being consumed because money, once spent, cannot be reused. For dependent claim 25, Petitioner argued that Chow’s HTTPD server process, which listens for requests and creates a child process to handle them, constitutes an "event handler" as it invokes the Revision Manager upon the occurrence of a request event. The primary element Petitioner asserted Chow does not explicitly teach is a “mobile” agent.
  • Motivation to Combine: Petitioner argued that a person of ordinary skill in the art (POSITA) would have recognized that Chow’s Revision Manager uses a "remote procedure calling" architecture. White, which is incorporated by reference in the ’752 patent, explicitly teaches an improved “remote programming” system using mobile agents as a superior alternative to remote procedure calling. White explains its mobile agent system reduces network latency, communication costs, and overcomes the functional limitations of remote procedure calling. Petitioner argued a POSITA would combine White’s mobile agent technology with Chow’s system to achieve these well-documented benefits. This combination was presented as a simple substitution of one known technique (remote procedure calling) for an improved, known alternative (remote programming with mobile agents).
  • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success in this combination. The use of mobile agents for website monitoring and information retrieval was well-known in the art, and the benefits of such a combination were predictable based on the explicit teachings of White.

4. Key Claim Construction Positions

• "agent": Petitioner highlighted that this term was central to a prior, terminated inter partes review (IPR) involving the ’752 patent. In that proceeding, the Board construed "agent" as "a process that occupies a place and that is mobile, i.e., can move from a first place to a second place," based on lexicography from the White patent, which is incorporated by reference in the ’752 patent. Petitioner adopted this construction for its primary arguments. It also noted that in parallel district court litigation, the Patent Owner proposed a broader construction: "a software application, program, or process responsible for performing a task on behalf of a user." Petitioner maintained its unpatentability arguments are successful under either construction.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate under Fintiv, General Plastics, and 35 U.S.C. §325(d).
  • Fintiv: Petitioner asserted that the Fintiv factors strongly favor institution. The parallel district court litigation is in its early stages, a motion to transfer venue is pending which could delay the trial date past the Final Written Decision (FWD), and Petitioner stipulated it will not pursue in court any grounds on which IPR is instituted. Critically, Petitioner emphasized the strong merits of its case, noting that the Board previously instituted an IPR on the same claims and the same prior art combination, finding "a strong case for the obviousness of the challenged claims."
  • General Plastics: Petitioner contended this is not a "follow-on" petition because it has no significant relationship with the petitioners in prior IPRs against the ’752 patent (VMware and HCC Insurance Holdings), which were filed against a different patent owner (Intellectual Ventures).
  • §325(d): Petitioner argued denial is unwarranted because the primary prior art reference, Chow, was never presented to or considered by the examiner during the original prosecution of the ’752 patent.

6. Relief Requested

• Petitioner requests institution of an IPR and cancellation of claims 24 and 25 of the ’752 patent as unpatentable.