PTAB

IPR2025-01362

Ciena Corp v. KMizra LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: NETWORK MANAGEMENT SYSTEM
  • Brief Description: The ’282 patent discloses a distributed Network Management System (NMS) architecture designed for improved scalability and robustness. The system utilizes communication adapters that are distributed from the application servers to manage network elements and communicate information to an Operations Support System (OSS).

3. Grounds for Unpatentability

Ground 1: Claims 1-22 are obvious over Secer in view of Dinker.

  • Prior Art Relied Upon: Secer (Patent 7,209,968) and Dinker (Application # 2003/0177411).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Secer taught a distributed NMS with a nearly identical architecture to the ’282 patent. Secer disclosed a central management system (MS 202), which Petitioner equated to the claimed first application server instance, that receives processed information from distributed "gateways" that function as the claimed first adapter. These gateways collect event information from network elements and translate various communication protocols. Secer also disclosed gateways that communicate with an OSS, which function as the claimed gateway device and second adapter.

      Petitioner asserted that while Secer disclosed the core NMS architecture, it only expressly taught load balancing and failover for its gateways, not for its single application server. To supply these missing elements, Petitioner relied on Dinker, which taught using a cluster of application servers (a plurality of application server instances) to improve scalability, reliability, and fault tolerance. Dinker explicitly disclosed using a load balancer to distribute client requests among the server cluster and detailed various failover mechanisms where a secondary server takes over for a primary server that becomes unavailable.

      Petitioner contended that combining these references renders all limitations of independent claims 1 and 3 obvious. The combination taught receiving information at a first application server selected from a plurality of such servers via a load balancing process. Critically, the combination also taught the key "failover" feature of limitation [1d], which was added during prosecution to secure allowance of the ’282 patent. This limitation requires establishing an association with a second application server in response to the first becoming disabled, a process Petitioner argued was explicitly detailed in Dinker for application server clusters.

    • Motivation to Combine (for §103 grounds): Petitioner argued a person of ordinary skill in the art (POSITA) would combine Secer and Dinker to improve the scalability, performance, and fault-tolerance of Secer’s NMS, which were well-known goals in the field. Secer itself suggested its failover techniques could be applied to "devices other than gateways" in any client/server environment, and its MS 202 qualified as such a device. Dinker taught that its load-balanced, fault-tolerant server clusters could be used in various systems, making Secer’s NMS a suitable candidate for this known and beneficial modification.

    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because the combination involved applying well-known, predictable solutions (server clustering, load balancing, failover) to a known system (Secer’s NMS) to achieve expected benefits. The use of server clusters was a widely implemented and routine practice for providing redundancy and additional capacity in NMS applications.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-22 of Patent 8,782,282 as unpatentable.