PTAB

IPR2025-00862

Advanced Micro Devices Inc v. Advanced Cluster Systems Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Parallel Processing in a Computer Cluster
  • Brief Description: The ’768 patent relates to a system for adding parallel processing functionality to single-computer mathematical software, such as Mathematica or MATLAB. The system utilizes a computer cluster where multiple nodes intercommunicate via a peer-to-peer architecture to execute tasks in parallel.

3. Grounds for Unpatentability

Ground 1: Obviousness over Menon, Trefethen, RS6000, and POEref - Claims 1-25 and 30 are obvious over Menon in view of Trefethen, RS6000, and POEref.

  • Prior Art Relied Upon: Menon (“MultiMATLAB: Integrating MATLAB with High-Performance Parallel Computing,” 1997), Trefethen (“MultiMATLAB: MATLAB on Multiple Processors,” 1996), RS6000 (“RS/6000 SP: Planning Vol. 1,” 2001), and POEref (“Using the Parallel Operating Environment,” 2001).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Menon disclosed the core invention through its “MultiMATLAB” system, which parallelized the MATLAB software on a cluster of processors using a peer-to-peer architecture and a Message Passing Interface (MPI) communication layer. Petitioner asserted that Trefethen, a companion paper on the same system, was critical as it provided a specific code example demonstrating the precise sequential operation that the Board previously found was required by claim 1. This example showed a first node sending data to a second node, which performed a calculation and sent the result to a third node for another calculation, which then communicated its result back to the first node. RS6000 and POEref were presented as standard technical manuals describing the specific hardware (IBM SP2) and software environment (Parallel Operating Environment) that Menon explicitly stated its system was designed for and implemented on.
    • Motivation to Combine: A POSITA would combine the references because Menon expressly cited Trefethen as building upon its work. Furthermore, because Menon explicitly identified the use of an IBM SP2 system running IBM’s POE, a POSITA would have been directly motivated to consult the corresponding technical manuals (RS6000 and POEref) for routine implementation details.
    • Expectation of Success: Petitioner contended that success would have been predictable, as the primary references were not theoretical but described an existing, functional system. Menon itself reported positive results, demonstrating that the MultiMATLAB system was an "effective platform for parallel computing."

Ground 2: Obviousness over Menon, Trefethen, RS6000, POEref, and MPIref - Claims 31-34 are obvious over Menon in view of Trefethen, RS6000, and POEref, further in view of MPIref.

  • Prior Art Relied Upon: The combination from Ground 1, with the addition of MPIref (“MPI: A Message-Passing Interface Standard,” 1994).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground augmented the combination from Ground 1 by adding MPIref, the official MPI industry standard document. Petitioner argued that while Menon disclosed using MPI as its communication substrate, MPIref provided the necessary technical specifications to meet the detailed limitations of dependent claims 31-34. Petitioner mapped MPIref’s detailed disclosures of MPI_SEND and MPI_RECV commands, packet structures (containing payloads and destination info), asynchronous communication, message specifiers, and thread-safe execution directly to the specific claim limitations regarding how nodes exchange information, create and decode packets, and handle asynchronous behavior during parallel computation.
    • Motivation to Combine: A POSITA seeking to implement the system described in Menon, which is explicitly based on MPI, would have been naturally motivated to consult the official MPI standard (MPIref) to understand the technical details, syntax, and capabilities of the communication protocol.
    • Expectation of Success: Success was highly predictable, as MPIref provided a "practical, portable, efficient and flexible standard" for implementing the exact message-passing functions that Menon relied upon for its MultiMATLAB system.

4. Key Claim Construction Positions

  • "peer-to-peer architecture": Petitioner adopted the Patent Owner's proposed construction from a prior IPR proceeding, defining the term as "an architecture in which each node can communicate tasks and data with other nodes without the tasks and data being required to go through a central server or master node."
  • "a mechanism for...": Petitioner argued this term, as used in independent claim 1, should be construed as a means-plus-function limitation under pre-AIA 35 U.S.C. §112, para. 6. Petitioner identified the claimed function as "to communicate results of mathematical expression evaluation with each other using a peer-to-peer architecture" and the corresponding structure disclosed in the ’768 patent's specification as an "MPI module."

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate. Against a potential Fintiv-based denial, Petitioner cited its filing of a Sotera stipulation in the parallel district court case, the distant trial date (November 2026), and minimal litigation investment. Petitioner contended that denial under 35 U.S.C. §325(d) was unwarranted because the asserted prior art was not before the Examiner during prosecution and was materially different from art cited in previous IPRs, particularly as Trefethen addressed the specific operational sequence that formed the basis for a prior institution denial. Finally, Petitioner argued against denial under General Plastic factors, noting that it is a different petitioner than in prior challenges to the ’768 patent.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-25 and 30-34 of Patent 10,333,768 as unpatentable under 35 U.S.C. §103.