PTAB

IPR2025-01362

Ciena Corporation v. K.Mizra LLC

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1. Case Identification

2. Patent Overview

  • Title: NETWORK MANAGEMENT SYSTEM
  • Brief Description: The ’282 patent relates to a distributed network management system (NMS) designed for improved scalability and robustness. The system architecture separates communication adapters from a cluster of application servers, which are managed by a load balancer, and includes a failover mechanism to re-establish network associations if an application server becomes disabled.

3. Grounds for Unpatentability

Ground 1: Obviousness over Secer and Dinker - 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 discloses a distributed NMS architecture that meets most limitations of the challenged claims. Secer’s system included a central management system (MS), analogous to the claimed first application server instance, and distributed "gateways," which function as the claimed first adapters, that receive and process event information from network elements. Secer also disclosed gateways that communicate with an Operations Support System (OSS), analogous to the claimed gateway device and second adapter. However, Secer’s MS was a single server. Petitioner asserted that Dinker remedies this deficiency by teaching the use of an application server cluster (a plurality of application server instances), a load balancer to distribute requests among them, and failover procedures for when a primary server in the cluster fails. By combining Dinker’s teachings on server clustering, load balancing, and failover with Secer’s foundational NMS architecture, Petitioner contended all limitations of independent claims 1 and 3 are met. For instance, the combination teaches receiving information at a first application server instance selected from a plurality based on a load balancing process, and in response to a server failure, establishing an association between the adapters and a second application server instance.
    • Motivation to Combine (for §103 grounds): Petitioner presented several motivations for a person of ordinary skill in the art (POSITA) to combine the references. First, Secer and Dinker are analogous arts, both addressing network and server management, fault tolerance, and scalability. Second, Secer itself suggested its failover and recovery techniques, detailed for gateways, could be applied to other client/server components, such as its own MS. A POSITA would have recognized that applying Dinker’s well-known server clustering and load-balancing techniques to Secer’s MS was a natural extension to achieve predictable benefits. The primary motivations were to improve scalability, performance, and fault tolerance—benefits expressly taught by Dinker and widely understood in the art at the time.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success because the combination involved implementing known features (server clustering, load balancing, failover) that were already established in the NMS context. Petitioner argued that modifying Secer's NMS with Dinker's teachings required only routine skill to achieve the well-understood advantages of a distributed, fault-tolerant system.
    • Key Aspects: Petitioner emphasized that the key "failover" limitation of claim 1 was added during prosecution to secure allowance of the ’282 patent. The core of this petition is that this exact failover functionality for application server clusters was well-known, explicitly taught by Dinker, and obvious to implement in the context of Secer’s system.

4. Relief Requested

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