PTAB

IPR2025-01364

Ciena Corp v. KMizra LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Application Wire
  • Brief Description: The ’320 patent describes a system for managing Quality of Service (QoS) in a Multi-Protocol Label Switching (MPLS) network. The technology involves identifying "application flows" based on packet header data and mapping these flows to one or more "pseudowires" (virtual circuits) that traverse the network.

3. Grounds for Unpatentability

Ground 1: Obviousness over Murphy and Taguchi - Claims 1-5, 7-12, and 14-20 are obvious over Murphy in view of Taguchi.

  • Prior Art Relied Upon: Murphy (Patent 7,477,657) and Taguchi (Japanese Application # JP 2003-258857).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Murphy taught nearly all elements of the challenged claims. Murphy disclosed a system for providing application-specific QoS in an MPLS network by mapping application flows (termed "packet flows") to pseudowires (termed Label Switched Paths or "LSPs"). Murphy's edge routers identified flows based on packet header information (e.g., protocol, port numbers) and mapped them using one-to-one or aggregated schemes. However, Petitioner asserted Murphy did not explicitly teach distributing a single application flow across multiple pseudowires simultaneously. Taguchi allegedly supplied this missing element by teaching a system that determines whether a single stream (e.g., a voice stream) should be routed over a single LSP or distributed across a plurality of LSPs to meet bandwidth requirements and manage network load.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Taguchi’s distributed mapping technique with Murphy’s QoS system to handle larger packet flows more efficiently. This combination would allow the system to provide QoS by distributing a flow across existing LSPs without needing to establish a new, larger LSP, thereby improving load balancing and network resource utilization—well-known goals in MPLS networking. Taguchi's express teaching of transferring a stream along multiple LSPs based on bandwidth availability provided a direct motivation to apply this technique to Murphy's similar system.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because combining the references involved applying a known technique (distributed mapping) to a similar system (MPLS QoS) to achieve a predictable result (improved bandwidth management). The integration would require only routine software modifications to Murphy's edge routers, as both systems operate on similar principles of mapping flows to LSPs in an MPLS environment.

Ground 2: Obviousness over Murphy, Taguchi, and Booth - Claims 6 and 13 are obvious over Murphy in view of Taguchi and Booth.

  • Prior Art Relied Upon: Murphy (Patent 7,477,657), Taguchi (Japanese Application # JP 2003-258857), and Booth (Application # 2006/0285500).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Murphy and Taguchi from Ground 1 to address the additional limitations of claims 6 and 13, which required assigning sequence numbers to ingress data packets. Petitioner argued that while the base combination established a system for distributing an application flow across multiple pseudowires, it was Booth that explicitly taught the use of sequence numbers for packets traversing pseudowires. Booth described that conventional sequence numbers existed on pseudowire frames in MPLS-based technologies "to ensure in-order delivery of packets" and could be used to track packet loss and misordered packets.
    • Motivation to Combine: A POSITA, having combined Murphy and Taguchi to distribute a single application flow across multiple paths, would be immediately motivated to implement a sequencing mechanism. Distributing packets makes them susceptible to arriving out of order, and ensuring correct ordering is a fundamental requirement for data integrity and QoS, which was the primary goal of the base system. Booth provided an express and conventional solution for this exact problem in the same technical context (MPLS pseudowires). Therefore, a POSITA would add Booth's sequencing to the Murphy/Taguchi system to ensure the distributed packets could be correctly reassembled.
    • Expectation of Success: Adding sequence numbers to packets is a fundamental, well-understood technique in packet-switched networks. A POSITA would have a high expectation of success in implementing Booth’s conventional sequencing in the combined Murphy/Taguchi system, as it represented a routine and necessary step to ensure the proper functioning of a distributed traffic system.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-20 of Patent 10,735,320 as unpatentable.