American Airlines Inc v. Intellectual Ventures I LLC

1. Case Identification

• Case #: IPR2025-00785
• Patent #: 7,257,582
• Filed: April 10, 2025
• Petitioner(s): American Airlines, Inc. and Southwest Airlines Co.
• Patent Owner(s): Intellectual Ventures I LLC
• Challenged Claims: 1-14

2. Patent Overview

• Title: Load Balancing and Shared Data
• Brief Description: The ’582 patent relates to a method for load balancing by decomposing a large computational task into smaller subtasks for parallel processing across multiple, potentially heterogeneous computers. The system is designed to split the performance of a task among a plurality of processing units that can access input data and distribute subtask outputs.

3. Grounds for Unpatentability

Ground 1: Claims 1-14 are obvious over Chow in view of Reiffin.

• Prior Art Relied Upon: Chow (6,304,866) and Reiffin (6,330,583).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of Chow and Reiffin teaches every limitation of the challenged claims. Chow was cited for its disclosure of a multiprocessing system that performs an aggregate database processing task by breaking it into smaller units executed by multiple task execution units. Reiffin was cited for its teachings on partitioning a large, compute-intensive task into subtasks distributed among a network of personal computers for parallel execution. Critically, Petitioner asserted that this combination teaches the execution of unprocessed partitions on a "first-come/first-served basis," which was the sole point of novelty argued by the applicant to overcome prior art during prosecution. This limitation was allegedly met by Chow’s “straw model,” where an execution unit takes a new sub-task after finishing its current one, and by Reiffin’s disclosure of using a “queue” to store and assign subtasks.
  • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine Chow's multiprocessing system with Reiffin's distributed networking concepts to achieve increased computational power and the ability to solve larger, more complex problems. This was presented as a predictable combination of known elements for their intended purposes.
  • Expectation of Success: Petitioner argued that a POSITA would have had a reasonable expectation of success in combining the references, as it represented a routine application of known parallel processing techniques to improve system scale and performance.

Ground 2: Claims 1-14 are obvious over Chow in view of Reiffin and further in view of Kurowski.

• Prior Art Relied Upon: Chow (Patent 6,304,866), Reiffin (Patent 6,330,583), and Kurowski (Application # 2002/0019844).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground supplemented the arguments of Ground 1, asserting that to the extent the Board found any limitation un-taught by Chow and Reiffin, Kurowski supplied the disclosure. Kurowski describes a large-scale, internet-based distributed computing system where tasks are broken into thousands of subtasks for distribution to thousands of client computers. Petitioner argued that Kurowski's client-server architecture, where clients request work from a task server, further reinforces the teaching of a "first-come/first-served" processing model. Kurowski was also cited for its disclosure of a system with separate task, file, and application servers for partitioning and distributing work, which Petitioner mapped to limitations requiring a processor for partitioning that is separate from the subtask processors.
  • Motivation to Combine: A POSITA would have been motivated to integrate Kurowski’s internet-based architecture with the system of Chow and Reiffin to further enhance scalability. This would allow the system to expand from a local network to a wide-area network like the Internet, leveraging a vast number of heterogeneous computers to solve even larger computational problems, a well-known objective in the field.
  • Expectation of Success: Petitioner asserted success was expected because using the Internet to interconnect heterogeneous computers for distributed computing was a well-established and understood practice at the time of the invention.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under either 35 U.S.C. §314(a) (considering Fintiv factors) or 35 U.S.C. §325(d) would be inappropriate.
• Regarding Fintiv, Petitioner contended that the factors weigh in favor of institution. The arguments centered on the early stage of the parallel district court litigation, noting that trial dates were either not set or far in the future, and that Petitioner stipulated it would not pursue in court any grounds raised or that could have been reasonably raised in the IPR.
• Regarding §325(d), Petitioner argued that the petition raises new art and arguments not before the Examiner during prosecution. The core contention was that the Examiner committed a material error by allowing the patent based on the applicant's argument of novelty residing in the "first-come/first-served" processing of subtasks. Petitioner asserted that Chow, Reiffin, and Kurowski all directly teach this allegedly novel feature, meaning the prior art presented in the petition is materially different from the art considered by the Examiner and directly addresses the sole basis for patentability.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of Patent 7,257,582 as unpatentable.