PTAB
IPR2025-01286
Dell Technologies Inc v. Cloud Byte LLC
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2025-01286
- Patent #: 9,482,632
- Petitioner(s): Dell Technologies Inc. and Dell Inc.
- Patent Owner(s): Cloud Byte LLC
- Challenged Claims: 1-9
2. Patent Overview
- Title: Abnormality Detection Device
- Brief Description: The ’632 patent describes a system for detecting abnormalities, such as clogged dust filters, in Information and Communication Technology (ICT) equipment. The system estimates an expected upper temperature limit based on the equipment’s operational status and intake-air temperature and determines an abnormality is occurring if the actual measured temperature exceeds this limit.
3. Grounds for Unpatentability
Ground 1: Claims 1-9 are obvious over Hira in view of Shiga.
- Prior Art Relied Upon: Hira (Japanese Patent Application Publication No. JP2009277053A) and Shiga (International Publication No. WO2010050080A1).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Hira, which teaches a "dust filter clogging status detection device," discloses nearly every limitation of the challenged claims. Hira's system estimates a "component temperature threshold value" (an upper limit of possible temperatures) based on the system’s operational status (e.g., CPU load, hardware configuration) and ambient temperature (intake-air temperature). An abnormality (a clogged filter) is detected when the actual component temperature exceeds this threshold. Petitioner contended the only limitation Hira does not explicitly disclose is using the operational status and intake-air temperature to also determine the cooling fan's rotation speed. Shiga was introduced to supply this missing element, as it explicitly describes a fan control technique for servers that adjusts fan speed based on CPU utilization and intake-air temperature to optimize cooling and power consumption.
- Motivation to Combine (for §103 grounds): Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Hira and Shiga because both references address thermal management in computer systems. Hira disclosed a system with cooling fans but provided no specific method for controlling their speed. A POSITA implementing Hira’s abnormality detection system would have been motivated to incorporate Shiga’s well-known fan control method, which uses the same inputs already monitored by Hira (CPU load and intake-air temperature), to gain the recognized benefits of improved power efficiency and thermal performance.
- Expectation of Success (for §103 grounds): Petitioner argued a POSITA would have had a reasonable expectation of success because Shiga’s cooling control method is described as a software program ("server program 110") executed on a server’s CPU. Implementing this functionality in Hira’s server system would involve a straightforward modification of software, a predictable task well within the skill of a POSITA.
4. Key Claim Construction Positions
- "-unit" terms (e.g., "estimating unit," "operational status detecting unit," "determining unit"): Petitioner argued these terms should be given their plain and ordinary meaning and are not means-plus-function limitations under 35 U.S.C. §112, ¶6, as they were not treated as such during prosecution and do not use "means for" language. However, should the Board construe them as means-plus-function terms, Petitioner proposed specific functions (recited in the claims) and corresponding structures disclosed in the specification (e.g., for "estimating unit," the structure is a CPU functioning as evaluating unit 163).
- "in a case where a result of detection by the intake-air temperature sensor is equal" (Claim 2): Petitioner contended this phrase refers to situations where the ICT equipment operates under different conditions (e.g., different CPU loads) while the intake-air temperature remains the same. Based on the patent’s disclosure, this construction supports the claim’s requirement that the estimated upper temperature limit is lower when the utilization rate is lower, even if the intake temperature is constant.
5. Relief Requested
- Petitioner requests the institution of an inter partes review and the cancellation of claims 1-9 of the ’632 patent as unpatentable.
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