PTAB

IPR2025-00863

Advanced Micro Devices Inc v. Advanced Cluster Systems Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Parallel Computing Architecture
  • Brief Description: The ’768 patent describes a system for adding parallel computing functionality to mathematical software applications (e.g., Mathematica, MATLAB) that traditionally run on a single computer. The invention enables these applications to run across a cluster of computer nodes that communicate in a peer-to-peer architecture using a message-passing interface (MPI).

3. Grounds for Unpatentability

Ground 1: Obviousness over Menon, Trefethen, RS6000, and POEref - Claims 26, 29, 35-36, and 39 are obvious over Menon in view of Trefethen, RS6000, and POEref.

  • Prior Art Relied Upon: Menon (a 1997 conference paper on "MultiMATLAB"), Trefethen (a 1996 technical report on MultiMATLAB), RS6000 (an IBM product manual), and POEref (an IBM product manual for Parallel Operating Environment).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Menon and Trefethen, two papers by the same Cornell research team on the same MultiMATLAB project, discloses all key limitations of the independent claims. Menon taught the core architecture: a system to run MATLAB in parallel across multiple processors (nodes) on an IBM SP2 cluster, using MPI for peer-to-peer communication. Trefethen provided a specific implementation example with sample code that, according to Petitioner, discloses the precise sequential processing recited in the claims, where a result is passed from a first node to a second, which performs a calculation and passes its result to a third. RS6000 and POEref were cited as product manuals for the hardware and software environment that Menon explicitly states was used for MultiMATLAB, confirming details like the presence of multiple processor nodes and the use of an initialization process.
    • Motivation to Combine: A POSITA would combine Menon and Trefethen because they describe the same project, were authored by the same team, and Menon expressly cites Trefethen as a foundational document. A POSITA would be motivated to consult the RS6000 and POEref manuals because Menon explicitly identifies the IBM SP2 system and IBM's Parallel Operating Environment (POE) as the platform for which MultiMATLAB was designed.
    • Expectation of Success: The combination would yield predictable results, as the prior art described a functioning system (MultiMATLAB) developed to solve the exact problem of parallelizing mathematical software, a goal described in Trefethen as "inevitable."

Ground 2: Obviousness over Menon, Trefethen, RS6000, POEref, and MPIref - Claims 27-28 and 37-38 are obvious over Menon in view of Trefethen, RS6000, and POEref, further in view of MPIref.

  • Prior Art Relied Upon: Menon, Trefethen, RS6000, POEref, and MPIref (the 1994 MPI standard specification).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address dependent claims reciting specifics of the asynchronous communication calls. Petitioner asserted that Menon taught using MPI as the communication layer for its peer-to-peer system. MPIref, as the official standard for MPI, was argued to inherently disclose the technical details of such communications. Specifically, MPIref detailed the structure of standard send and receive commands, including the use of a payload (the data being sent), a destination/target node identifier, a source node identifier, and the storage of incoming data in a receive buffer or queue. This combination allegedly rendered obvious the claims' requirements for creating packets with expressions as payloads and target node information.
    • Motivation to Combine: A POSITA implementing the MultiMATLAB system described in Menon, which explicitly used MPI, would have been directly motivated to consult the official MPI standard (MPIref) to understand the syntax and function of the communication calls necessary for implementation.
    • Expectation of Success: Success was expected because MPIref provided a "practical, portable, efficient and flexible standard" for the exact type of message passing that Menon's system required.

4. Key Claim Construction Positions

  • "peer-to-peer architecture": Petitioner adopted the construction from a prior IPR on the ’768 patent, defining it 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 is a means-plus-function limitation under pre-AIA 35 U.S.C. §112, sixth paragraph. The petition identified the corresponding structure disclosed in the specification as an "MPI module," including basic MPI calls that send data and expressions.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued discretionary denial would be inappropriate under Fintiv, Advanced Bionics, and General Plastic.
    • Fintiv: Petitioner asserted the factors weigh against denial, highlighting a filed Sotera stipulation agreeing not to pursue in district court any invalidity grounds that were raised or could have been reasonably raised in the IPR. The petition also noted the parallel trial date is scheduled for after the IPR's Final Written Decision deadline.
    • Advanced Bionics: Petitioner argued the examiner did not consider the asserted prior art during prosecution and that the art, particularly Trefethen's disclosure of the specific operational sequence, is materially different from art cited in previously denied IPRs against the ’768 patent.
    • General Plastic: Petitioner argued that as a different petitioner from prior challenges, it should not be penalized, and that its grounds are substantively different.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 26-29 and 35-39 of the ’768 patent as unpatentable.