PTAB

IPR2025-00914

Intel Corp v. Advanced Cluster Systems Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Computer Cluster for Parallel Processing
  • Brief Description: The ’679 patent describes a system for enabling a mathematical software tool, designed to run on a single computer (e.g., Mathematica), to execute tasks in parallel across multiple nodes of a computer cluster using a peer-to-peer architecture.

3. Grounds for Unpatentability

Ground 1: Claims 1-19 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, Hardware and Physical Environment,” 2001)
    • POEref (“Operation and Use, Volume 1, Using the Parallel Operating Environment,” 2001)
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of references taught every limitation of the challenged claims. Menon, the primary reference, disclosed the “MultiMATLAB” system, a platform that enables the mathematical software MATLAB to operate in parallel on multiple processor nodes. Menon taught a computer cluster with a plurality of nodes, each running a MATLAB process and communicating via a communication layer using Message Passing Interface (MPI). Critically, Menon described a peer-to-peer communication architecture using a Single Program, Multiple Data (SPMD)/Message Passing paradigm with "point to point" commands like Send() and Recv(), directly corresponding to the "peer-to-peer architecture" of independent claim 1.

    • Trefethen, authored by the same Cornell research team as Menon, was presented as a companion paper describing the implementation of MultiMATLAB. It provided a specific code example demonstrating sequential processing where one node performs a calculation and sends the result directly to the next node in a sequence, which receives it, performs another calculation, and passes it on. This example explicitly taught the claimed functionality of a second node receiving calls from a first node, executing matrix operations, and communicating the result to a third node.

    • RS6000 and POEref were IBM product manuals that Petitioner asserted a person of ordinary skill in the art (POSITA) would consult for implementation details, as Menon explicitly stated MultiMATLAB was designed for the "IBM SP2" system and used IBM's "Parallel Operating Environment (POE)." RS6000 described the hardware of the IBM SP2 system, teaching that each processor node is a hardware processor and that the system forms a networked cluster with communication adapters like Ethernet. POEref described the software environment, teaching that the "poe" command is used to initialize processes on the remote nodes and automatically load the necessary communication subsystems, which established the claimed cluster initialization process.

    • Motivation to Combine: Petitioner argued a POSITA would combine Menon and Trefethen because they described the same MultiMATLAB project, were authored by the same research group, and were often linked together on the project's website. The motivation to combine these with RS6000 and POEref was explicit, as Menon stated that MultiMATLAB was specifically designed for the IBM hardware (IBM SP2) and software (POE) described in those manuals. A POSITA implementing Menon's system would have been directly led to the RS6000 and POEref documents for details on the underlying platform.

    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success because the goal of parallelizing MATLAB was considered "inevitable" at the time. More importantly, the Menon and Trefethen papers described a system that was already successfully built and tested, demonstrating its effectiveness and providing a clear path for a POSITA to achieve the claimed invention with predictable results.

4. Key Claim Construction Positions

  • "peer-to-peer architecture": Petitioner proposed construing this term, which appears in independent claim 1, 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." Petitioner noted this construction was previously advanced by the Patent Owner in a related IPR concerning the parent patent and adopted it for this proceeding. This construction was central to the argument that Menon's SPMD/Message Passing paradigm, which used direct point-to-point commands, met the limitation.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under Fintiv by filing a *Sotera* stipulation in the parallel district court litigation involving the ’679 patent. The stipulation stated that if the Board institutes this IPR, Petitioners will not pursue in the district court any invalidity ground that was raised or reasonably could have been raised in the IPR petition. This was intended to mitigate concerns about parallel proceedings and weigh against a Fintiv-based denial.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-19 of the ’679 patent as unpatentable.