PTAB

IPR2025-01370

Red Hat Inc v. Competitive Access Systems Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Device and Methods for Multipath Communications
  • Brief Description: The ’343 patent discloses methods and devices, such as a residential communications gateway, for aggregating bandwidth from multiple communication paths. The technology aims to enhance internet connection speeds over existing infrastructure, like Plain Old Telephone Service (POTS) lines, to address the "last mile" bandwidth problem.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over Challener, and Claim 11 is additionally obvious in view of Peirce and Held.

  • Prior Art Relied Upon: Challener (Application # 2004/0001512), Peirce (Patent 5,878,040), and Held (a 2000 textbook on network design).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Challener alone renders claims 1-20 obvious. Challener disclosed a peer-to-peer bandwidth sharing system to solve the same "last mile" problem addressed by the ’343 patent. In Challener's system, a "master" Bandwidth Sharing Device (BSD) aggregates bandwidth by coordinating with one or more "slave" BSDs over separate networks. Petitioner asserted this system directly maps to the limitations of independent claims 1 and 12. For claim 1, the end-user terminal was mapped as the "first device," the master BSD as the "second device," and a slave BSD as the "third device." The connections through these master and slave BSDs, which utilize different "last mile" connections, constituted the claimed first and second networks. Petitioner contended Challener taught concurrent use of these networks, as data packets from a remote source were sent simultaneously to both master and slave BSDs to be reassembled, thereby increasing total bandwidth.
    • Motivation to Combine (for §103 grounds): The argument to combine references was directed at dependent claim 11, which added the limitation of "assigning a session identifier." Petitioner argued that since Challener disclosed that a single slave BSD could share its bandwidth with multiple master BSDs, a person of ordinary skill in the art (POSITA) would have found it obvious to use a session identifier to distinguish between data packets intended for different sessions or master BSDs. A POSITA would combine Challener with Peirce, which explicitly taught using a "bundle mapping update packet" containing a session ID to coordinate data streams in a functionally similar multi-link system. Alternatively, a POSITA would have incorporated the teachings of Held, which described the ubiquity of the TCP/IP protocol. The TCP/IP tuple (source/destination IP address and port number) is an inherent session identifier that would already exist in Challener’s system for internet communications.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success in implementing a session ID, as it involved applying a well-known technique (session management) to a known system (bandwidth aggregation) to achieve the predictable result of correctly routing and reassembling data packets.

Ground 2: Claims 1-20 are obvious over Kotzin, and Claim 11 is additionally obvious in view of Peirce and Held.

  • Prior Art Relied Upon: Kotzin (Application # 2003/0026221), Peirce (Patent 5,878,040), and Held (a 2000 textbook on network design).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kotzin alone also rendered claims 1-20 obvious. Kotzin disclosed a bandwidth aggregation system where a primary wireless unit shared bandwidth from other nearby wireless units to increase its effective connection speed. Critically, Kotzin taught that these participating wireless units could be connected to the internet via completely different Wide Area Network (WAN) systems. Petitioner mapped Kotzin’s primary wireless unit as the "first device," a second wireless unit on a first WAN as the "second device," and a third wireless unit on a second WAN as the "third device." These separate WANs constituted the claimed first and second networks. Petitioner asserted that data from an internet server was split and sent concurrently over these separate WANs to the respective wireless units, which then forwarded the data to the primary unit for aggregation, thus meeting the limitations of independent claims 1 and 12.
    • Motivation to Combine (for §103 grounds): The motivation to add a session identifier (claim 11) to Kotzin’s system mirrored the argument for Challener. Kotzin specified that bandwidth was shared "for a given communication session," which Petitioner argued necessitated a mechanism to identify and manage individual sessions. A POSITA would combine Kotzin with Peirce's explicit teaching of a "bundle ID" to manage parallel data streams. The functional similarity between Kotzin and Peirce—both splitting and reassembling data across multiple links—provided a strong motivation for this combination. Likewise, a POSITA would find it obvious to use the inherent TCP/IP tuple identifier described in Held to manage communications with internet web servers, which Kotzin explicitly disclosed.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success in combining these known elements, as implementing a session identifier is a standard practice in packet-based networks for ensuring data integrity, yielding the predictable result of reliable multi-link communication.

4. Arguments Regarding Discretionary Denial

  • Petitioner asserted its intent to oppose any arguments for discretionary denial that the Patent Owner may raise, pursuant to the bifurcated briefing process established by the PTAB.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’343 patent as unpatentable under 35 U.S.C. §103.