PTAB

IPR2026-00039

FedEx Corp v. Sanjay Dahiya

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1. Case Identification

2. Patent Overview

  • Title: System and Method for Hot Deployment/Redeployment in Grid Computing Environment
  • Brief Description: The ’332 patent discloses methods for deploying updated versions of applications in a grid computing environment without shutting down or restarting the application servers (i.e., "hot deployment"). The system uses a repository server for new application versions, a discovery module to identify relevant grid nodes, and client application managers that use protocol-specific plug-ins to manage the deployment.

3. Grounds for Unpatentability

Ground 1: Obviousness over Henseler and Thyagarajan - Claims 1–5, 7–11, 13–16, and 18 are obvious over Henseler in view of Thyagarajan.

  • Prior Art Relied Upon: Henseler (Application # 2007/0168919) and Thyagarajan (Patent 7,721,277).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Henseler teaches a system for managing and deploying applications in a distributed grid computing environment. Henseler’s system includes a central control node that manages application nodes, an image repository for storing application images, and an application governor that handles deployment. However, Henseler only implicitly suggests deployment during execution. Petitioner argued that Thyagarajan explicitly teaches the benefits and methods of "hot deployment" for J2EE applications to reduce system downtime and accelerate development cycles. The combination of Henseler's grid management architecture with Thyagarajan's specific hot deployment techniques allegedly renders the challenged claims obvious. Specifically, Henseler's control node and application governor map to the ’332 patent's discovery and management modules, while Thyagarajan provides the claimed "hot deployment" functionality.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine these references for several reasons. First, Henseler’s disclosure of deploying new application instances "during execution" would motivate a POSITA to seek out well-known methods for such deployment, as detailed in Thyagarajan. Second, because Henseler specifies its system is for J2EE applications, and hot deployment was a known and desirable feature of J2EE environments, the combination would have been a natural step. The predictable benefits of reduced downtime and faster development cycles, as taught by Thyagarajan, would provide strong motivation to apply its methods to Henseler’s grid system.
    • Expectation of Success: Petitioner argued that a POSITA would have a reasonable expectation of success because the combination involves applying a known technique (Thyagarajan's hot deployment) to a known type of system (Henseler's grid environment) to achieve a predictable improvement.

Ground 2: Obviousness over Henseler, Thyagarajan, and Kautzleben - Claims 1-18 are obvious over Henseler, Thyagarajan, and Kautzleben.

  • Prior Art Relied Upon: Henseler (Application # 2007/0168919), Thyagarajan (Patent 7,721,277), and Kautzleben (Patent 7,493,624).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Kautzleben to address claim limitations not explicitly challenged in Ground 1, specifically those requiring registration and notification between system components (claims 6, 12, and 17). Petitioner argued that Kautzleben teaches a management architecture for clustered nodes using Java Management Extensions (JMX) and MBeans to facilitate communication and synchronization. Kautzleben discloses a notification service where components can register as "listeners" to receive notifications from other components (e.g., a "resource MBean" notifying a "monitor MBean" of an event). Petitioner contended this directly teaches the limitations of registering a client application manager with a repository server to accept notification of a new application version.
    • Motivation to Combine: The motivation to add Kautzleben’s teachings stems from Henseler’s own use of JMX and MBean server technology for monitoring and communication. Petitioner asserted that a POSITA, seeking to implement a robust communication and synchronization mechanism between Henseler's application governor (the client manager) and its image repository, would have been motivated to use the well-established JMX-based notification framework taught by Kautzleben. This would be a natural and technically sound extension to ensure the components remain synchronized, particularly when a new application version is added to the repository.
    • Expectation of Success: Petitioner claimed success would be expected because implementing a JMX-based notification system, as taught by Kautzleben, within another JMX-aware environment, like Henseler's, was a straightforward and well-understood practice for a POSITA at the time.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of the ’332 patent as unpatentable.