PTAB

IPR2025-00916

Intel Corp v. Advanced Cluster Systems Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Parallelizing Mathematical Software on Computer Clusters
  • Brief Description: The ’582 patent discloses a system for executing mathematical software applications, referred to as "kernels" (e.g., Mathematica), in parallel on a computer cluster. The system uses "cluster node modules" to manage communication and distribute tasks among the kernels running on different processors, enabling the cluster to function as a single computational resource in a peer-to-peer architecture.

3. Grounds for Unpatentability

Ground 1: Obviousness over MultiMATLAB References - Claims 1-3 and 5-19 are obvious over Menon in view of Trefethen, RS6000, and MPIref.

  • 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 IBM SP2 system), 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 fully discloses the MultiMATLAB system, which is a platform for running the mathematical tool MATLAB in parallel across multiple processors. This system is described as a computer cluster operating in a peer-to-peer architecture, where each processor runs a MATLAB process (the claimed "kernel"). Communication and task distribution are handled by a set of components (MEX Routines, interface module, etc.) that collectively function as the claimed "cluster node module." Trefethen provides specific code examples showing sequential processing where one node performs a calculation and passes the result to the next. RS6000 confirms that the IBM SP2 system, for which MultiMATLAB was designed, is a networked hardware cluster. MPIref provides the technical specification for the Message-Passing Interface (MPI) communication protocol that Menon explicitly states MultiMATLAB uses. Together, these references were alleged to teach every element of the challenged claims.
    • Motivation to Combine: A POSITA would combine Menon and Trefethen because they describe the same MultiMATLAB project, were written by the same research team, and were often cited and linked together. Menon’s explicit statement that MultiMATLAB was designed for the IBM SP2 and uses the MPI communication standard would have directly motivated a POSITA to consult the corresponding RS6000 hardware manual and the MPIref standard to fully understand and implement the system.
    • Expectation of Success: The combination would yield the predictable result of a parallel computing system for MATLAB, as successfully demonstrated in both Menon and Trefethen. Petitioner asserted that the goal of parallelizing tools like MATLAB was "inevitable," and the references describe a functioning, implemented system, indicating a high expectation of success.

Ground 2: Obviousness over MultiMATLAB and POEref - Claims 4 and 20 are obvious over Menon, Trefethen, RS6000, and MPIref, further in view of POEref.

  • Prior Art Relied Upon: Menon, Trefethen, RS6000, MPIref, and POEref (an IBM manual for the Parallel Operating Environment).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically targets claims 4 and 20, which add limitations for a "cluster configuration module" that initializes the cluster node modules. Petitioner argued that Menon explicitly teaches using IBM's Parallel Operating Environment (POE) to start or initialize all MATLAB processes in the MultiMATLAB architecture. The POEref manual describes the technical details of POE, including the "poe" command used to load programs and initialize the local environment on each processor node. This combination of Menon’s disclosure of using POE and POEref’s explanation of how POE works was argued to teach the claimed initialization functionality.
    • Motivation to Combine: The motivation is explicit. Menon states that "all MATLAB processes are started via POE, IBM's Parallel Operating Environment." A POSITA seeking to understand how to initialize the MultiMATLAB system would be directly motivated to consult the POEref documentation that Menon references.
    • Expectation of Success: Because Menon describes the successful use of POE to implement the MultiMATLAB system, a POSITA would have had a high expectation of success in combining the teachings of POEref with the primary references to achieve the claimed initialization.

4. Key Claim Construction Positions

  • "peer-to-peer architecture": Petitioner adopted the construction previously proposed by the Patent Owner in a related inter partes review (IPR): "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 argued that the SPMD/Message Passing paradigm described in Menon, which enables direct point-to-point communication between any two processes, meets this construction.

5. Arguments Regarding Discretionary Denial

  • Petitioner filed a Sotera stipulation in the parallel district court litigation. The stipulation states that if the IPR is instituted, Petitioners will not pursue any invalidity grounds in the district court that were raised, or reasonably could have been raised, in the IPR petition. This stipulation was presented to argue against a discretionary denial of institution under 35 U.S.C. §314(a) based on the Fintiv factors.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of Patent 11,811,582 as unpatentable.