PTAB

IPR2025-00915

Intel Corp v. Advanced Cluster Systems Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Parallelizing Mathematical Software on Computer Clusters
  • Brief Description: The ’621 patent discloses a system for adding cluster computing functionality to standalone mathematical software programs (e.g., MATLAB, Mathematica). The system uses multiple processors ("nodes"), each running a "kernel" (the mathematical software) and a "cluster node module," to execute tasks in parallel across the cluster using a peer-to-peer communication architecture.

3. Grounds for Unpatentability

Ground 1: Obviousness over Menon, Trefethen, RS6000, and MPIref - Claims 1-3, 5-16, and 18-30

  • Prior Art Relied Upon: Menon (a 1997 conference paper), Trefethen (a 1996 technical report), RS6000 (an IBM hardware manual), and MPIref (the 1994 Message Passing Interface standard).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Menon and Trefethen, which describe the "MultiMATLAB" system, disclosed every element of the challenged claims. MultiMATLAB was a system designed to run the mathematical software MATLAB in parallel on a cluster of processors, directly corresponding to the [’621](https://ai-lab.exparte.com/patent/11563621) patent’s architecture. Menon disclosed using a communication layer based on the Message Passing Interface (MPI) standard for peer-to-peer communication between MATLAB processes (the patent's "kernels") running on different nodes. Trefethen provided specific code examples demonstrating point-to-point communication between nodes using send and receive commands. The RS6000 manual described the IBM SP2 hardware that Menon explicitly stated was used for MultiMATLAB, and MPIref provided the technical specification for the MPI standard that Menon explicitly implemented. Collectively, Petitioner asserted this art taught the claimed computer cluster, processors, kernels, and cluster node modules with peer-to-peer communication capabilities.
    • Motivation to Combine: A POSITA would combine these references because Menon and Trefethen were foundational, cross-referenced papers describing the same MultiMATLAB project. To understand and implement this system, a POSITA would be directly led to the official documentation for the specific hardware (RS6000) and communication protocol (MPIref) that Menon explicitly identified as core components of its design.
    • Expectation of Success: Petitioner contended that combining the system's description (Menon and Trefethen) with the standard documentation for its specified components (RS6000 and MPIref) would predictably yield the exact parallel computing system described in the papers, establishing a clear expectation of success.

Ground 2: Obviousness over Menon, Trefethen, RS6000, and MPIref, further in view of POEref - Claims 4 and 17

  • Prior Art Relied Upon: The combination from Ground 1, plus POEref (an IBM product manual for the Parallel Operating Environment).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was asserted to address the limitations in claims 4 and 17 requiring a "cluster configuration module that initializes" the cluster node modules. Petitioner argued that while the primary combination from Ground 1 taught the cluster's core architecture and operation, the addition of POEref taught the specific initialization step. The Menon paper explicitly stated that IBM's Parallel Operating Environment (POE) was used to start the MATLAB processes on the cluster. POEref, the official IBM manual for POE, described how the poe command was used to load programs and initialize the local environment on each remote node of the cluster. Petitioner asserted this combination of Menon’s explicit instruction and POEref’s technical description directly teaches the claimed initialization module.
    • Motivation to Combine: A POSITA seeking to replicate the MultiMATLAB system as described in Menon would have been directly motivated to consult POEref, as it is the official documentation for the POE system that Menon explicitly identified for starting and managing processes.
    • Expectation of Success: Following Menon's explicit instruction to use the POE system (detailed in POEref) to initialize the MultiMATLAB processes would predictably result in a functioning, initialized parallel computing cluster, providing a strong expectation of success.

4. Arguments Regarding Discretionary Denial

  • Petitioners argued against discretionary denial by filing a Sotera stipulation in the parallel district court litigation involving the [’621](https://ai-lab.exparte.com/patent/11563621) patent.
  • The stipulation affirms that if this inter partes review (IPR) proceeding is instituted, Petitioners will not pursue in the district court any invalidity grounds that were raised or could have been reasonably raised in this IPR petition.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-30 of the ’621 patent as unpatentable under 35 U.S.C. §103.