PTAB

IPR2025-01088

Cisco Systems Inc v. Quicker Connections LLC

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Device for Fault Protection in a Ring Network
  • Brief Description: The ’859 patent discloses a method for rapid fault protection in bidirectional communication ring networks. The invention uses two sets of bits, a "general mask" representing the operational status of all network segments and a "specific mask" representing the intended path of a particular data flow, to determine if the flow is affected by a network fault and requires rerouting.

3. Grounds for Unpatentability

Ground 1: Claims 1-12 are obvious over Omichi

  • Prior Art Relied Upon: Omichi (Japanese Patent Publication No. JP2001053772A).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Omichi teaches every element of the challenged claims by describing a functionally identical fault protection system. Omichi discloses a bidirectional ring network that uses two data tables represented by bits to manage fault recovery. Petitioner asserted a direct correspondence between Omichi’s system and the ’859 patent’s claimed method:
      • The claimed "general mask," which indicates reachable network segments after a fault, was argued to be directly analogous to Omichi’s "ring link failure table." This table uses a bit-string where each bit corresponds to a network segment (a "ring link"), and a value of '1' indicates a failure on that segment.
      • The claimed "specific mask," which indicates the desired path for a data flow, was argued to correspond to Omichi’s "used ring link table." This table also uses a bit-string to identify the specific ring links that constitute the "working path" for a data flow.
      • The claimed step of "superimposing the general and specific masks" to determine the flow's disposition was argued to be taught by Omichi’s process of comparing the bits of its two tables. Omichi determines if any bit position has a '1' in both the failure table and the used path table. Petitioner contended this comparison is an inherent Boolean AND operation, as explicitly required by dependent claim 2.
    • Key Aspects: The central contention was that the terminology of "general mask" and "specific mask" in the ’859 patent described a known concept for which Omichi provided a clear, enabling disclosure. Petitioner argued that Omichi’s system, by comparing a fault-status bitmask with a path-definition bitmask to decide on rerouting, rendered the method of claims 1-6 and the corresponding device of claims 7-12 obvious to a person of ordinary skill in the art (POSITA). For dependent claims, Petitioner mapped specific outcomes of Omichi's comparison to the claimed results, such as rerouting traffic (claim 3), maintaining the existing path (claim 4), or identifying a correspondence between the combined and general masks (claim 5).

4. Key Claim Construction Positions

  • Petitioner submitted that no terms required express construction but provided explanations for how a POSITA would have understood key terms in the context of the art.
  • "mask": Argued to be understood as a pattern of bits used to logically combine with another data item to control the retention or suppression of portions of that data, consistent with its use in the art for Boolean operations.
  • "null": Argued to mean a value of zero. In the context of the claims, a "combined mask" being "null" would mean the result of the Boolean AND operation is a string of all '0's, indicating no overlap between the data flow's path and a failed segment. This interpretation was central to Petitioner's argument for claim 4.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) would be inappropriate. The petition identified a co-pending district court proceeding, Quicker Connections LLC v. Cisco Systems, Inc., 2-24-cv-01074 (EDTX).
  • To address potential Fintiv concerns, Petitioner made a Sotera stipulation, agreeing not to pursue in the district court litigation any invalidity ground that is raised or could have been reasonably raised in the IPR if the trial is instituted.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-12 of Patent 7,061,859 as unpatentable.