PTAB

IPR2025-01373

Red Hat Inc v. Competitive Access Systems Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Residential communications gateway (RCG) for broadband communications over a plurality of standard pots lines, with dynamic allocation of said bandwidth, that requires no additional equipment or modifications to the associated class 5 offices or the PSTN at large
  • Brief Description: The ’156 patent discloses a method for aggregating, sharing, and dynamically allocating bandwidth from multiple geographically dispersed residential communications gateways (RCGs). The system provides aggregated bandwidth to a user on-demand by leveraging unused capacity from nearby RCGs to overcome "last mile" bandwidth limitations.

3. Grounds for Unpatentability

Ground 1: Claims 1-4 are obvious over Challener in view of Ades.

  • Prior Art Relied Upon: Challener (Application # 2004/0001512) and Ades (Application # 2002/0042274).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Challener discloses the core method of the ’156 patent. Challener teaches a system with "bandwidth sharing devices" (BSDs), equivalent to the claimed RCGs, that aggregate unused bandwidth from nearby peers to increase effective bandwidth for a single user, thereby solving the "last mile" problem. Challener’s “master” BSD initiates requests, determines available bandwidth from “slave” BSDs, aggregates the shared bandwidth, and reassembles data packets, allegedly meeting most limitations of independent claim 1. To the extent Challener does not explicitly disclose a "network table," Petitioner asserted that Ades teaches this element. Ades describes improving bandwidth by using network tables to store information about the "best routes" based on metrics including traffic capacity (bandwidth) and the number of hops (location).
    • Motivation to Combine (for §103 grounds): Petitioner contended that Challener and Ades are in the same field and address the same problem of improving bandwidth. A person of ordinary skill in the art (POSITA) would combine Ades’s established technique of using network tables for route optimization with Challener’s bandwidth aggregation system to improve the management and efficiency of selecting peer devices, yielding predictable results.
    • Expectation of Success (for §103 grounds): Petitioner asserted a high expectation of success, as implementing a network table as taught by Ades into Challener's system would involve routine modifications to a known device to achieve a predictable improvement in network management.

Ground 2: Claims 1-4 are obvious over Kotzin in view of Ades.

  • Prior Art Relied Upon: Kotzin (Application # 2003/0026221) and Ades (Application # 2002/0042274).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Kotzin, like Challener, teaches a bandwidth aggregation system where a group of proximal wireless units can share their resources to enhance throughput for a destination unit communicating with a wide area network. Kotzin’s system involves a requesting unit sending query messages to nearby units to determine their availability and bandwidth capacity, selecting units based on this information, and aggregating data portions received from them. This process was argued to disclose the primary steps of claim 1. As in Ground 1, Petitioner relied on Ades to supply the explicit teaching of using a network table to organize, store, and update the information gathered from nearby units (e.g., location, bandwidth capabilities) to facilitate optimal routing.
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to incorporate Ades’s network table teachings into Kotzin’s system for the same reasons as with Challener. Both Kotzin and Ades seek to improve bandwidth, and using a network table is a known technique to improve the operation of such systems by ensuring efficient network routes are chosen for bandwidth sharing.
    • Expectation of Success (for §103 grounds): Petitioner argued that combining the well-known concept of network tables from Ades with Kotzin's wireless resource-sharing system would have required only routine software implementation with a high likelihood of success.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for claims 3-5 based on combinations including Xin (a 2000 IEEE paper). Xin was used to teach prioritizing bandwidth based on local demand, dynamically reallocating bandwidth when devices opt out, and scheduling data transfers for a future time to handle network congestion. Petitioner argued a POSITA would have been motivated to integrate Xin’s QoS and scheduling methods to further improve the bandwidth allocation systems of Challener or Kotzin.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-5 of the ’156 patent as unpatentable.