PTAB

IPR2025-00913

Intel Corp v. Advanced Cluster Systems Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Parallel Processing for Mathematical Software on Computer Clusters
  • Brief Description: The ’034 patent describes a system for adding cluster computing functionality to single-computer mathematical software programs, such as Mathematica or MATLAB. The invention enables these programs to run in parallel across multiple interconnected computer nodes using a peer-to-peer architecture and Message-Passing Interfaces (MPIs) for communication.

3. Grounds for Unpatentability

Ground 1: Claims 1-25, 27-28, and 30 are obvious over Menon in view of Trefethen, RS6000, and POEref

  • Prior Art Relied Upon: Menon (a 1997 paper on the MultiMATLAB system), Trefethen (a 1996 technical report on MultiMATLAB), RS6000 (an IBM product manual for the RS/6000 SP system), and POEref (an IBM product manual for IBM's Parallel Operating Environment).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Menon disclosed the core invention by describing "MultiMATLAB," a system that enables the mathematical software MATLAB to run in parallel across multiple nodes of an IBM SP2 computer cluster. Menon taught a peer-to-peer architecture using MPI for communication, where each node runs a MATLAB process (the claimed "single-node kernel") and communicates results with other nodes. Trefethen, a companion paper, provided specific code examples of this system in operation, demonstrating sequential processing and point-to-point communication between nodes as claimed. RS6000 supplied necessary hardware details for the IBM SP2 cluster explicitly used by Menon, while POEref detailed the Parallel Operating Environment (POE) that Menon specified for initializing the MATLAB processes across the cluster.
    • Motivation to Combine: A POSITA would combine Menon and Trefethen because they described the same "MultiMATLAB" project, were authored by the same Cornell research team, and Menon expressly cited Trefethen. Menon’s explicit disclosure of implementing MultiMATLAB on an IBM SP2 system using IBM’s POE would have directly motivated a POSITA to consult the corresponding product manuals, RS6000 and POEref, for specific implementation details.
    • Expectation of Success: Petitioner asserted a high expectation of success, as the references collectively described an already-existing and functioning system. The combination would yield the predictable result of a parallelized MATLAB system, a goal described by Trefethen as "inevitable."

Ground 2: Claims 26 and 29 are obvious over Menon, Trefethen, RS6000, and POEref, further in view of MPIref

  • Prior Art Relied Upon: The combination from Ground 1, further in view of MPIref (the 1994 Message-Passing Interface Standard).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims 26 and 29, which recite specific details of asynchronous communication calls and the creation of data packets. Petitioner argued the base combination established the overall system, and MPIref provided the necessary low-level implementation details. MPIref, as the official MPI standard, explicitly defined the syntax and functionality for asynchronous "point-to-point" commands like MPI_SEND and MPI_RECV. These definitions inherently involve creating a packet containing a payload ("expression to be sent") and a destination ("target node"), as recited in the claims. The standard’s description of send/receive buffers and destination fields directly mapped to the claimed packet creation and forwarding limitations.
    • Motivation to Combine: The motivation was direct and explicit. Menon stated that its MultiMATLAB system used "the MPI communication standard" as its underlying communication layer. A POSITA seeking to implement or understand Menon's system would have been directly compelled to consult MPIref, the definitive standard for MPI, to understand the precise operation of the communication commands.
    • Expectation of Success: Combining a system that uses a standard with the standard itself was presented as a routine and necessary step for implementation. This would predictably result in the functionality described by Menon, with a high expectation of success in achieving the claimed communication protocol.

4. Key Claim Construction Positions

  • The petition proposed a construction for the term "peer-to-peer architecture," which appears in independent claims 1 and 30.
  • Petitioner adopted the construction previously advanced by the Patent Owner in a related proceeding: "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." This construction was critical to the obviousness argument, as Petitioner argued Menon's SPMD/Message Passing paradigm taught precisely this type of direct, non-centralized communication between nodes.

5. Arguments Regarding Discretionary Denial

  • To preempt discretionary denial under 35 U.S.C. §314(a) based on parallel district court litigation (Fintiv factors), Petitioner filed a Sotera stipulation.
  • Petitioner stipulated that, if the IPR is instituted, it will not pursue in the parallel district court litigation any invalidity grounds that were raised or could have reasonably been raised in the IPR petition.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-30 of Patent 11,570,034 as unpatentable under 35 U.S.C. §103.