PTAB

IPR2026-00060

FedEx Corp v. Valtrus Innovations Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: COMPATIBILITY ENFORCEMENT IN CLUSTERED COMPUTING SYSTEMS
  • Brief Description: The ’416 patent describes methods and systems for managing compatibility and licensing in clustered computing environments. The technology involves a multi-tiered licensing scheme using "bundle-type" parameters to define cluster characteristics (e.g., size) and node-specific license parameters to ensure compliance when creating and activating a computing cluster.

3. Grounds for Unpatentability

Ground 1: Claims 1-18 are obvious over Sparks in view of Bram.

  • Prior Art Relied Upon: Sparks (Patent 7,590,653) and Bram (Application # 2006/0179058).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Sparks discloses the foundational clustered computing system and Bram provides the specific licensing enforcement features, rendering the claims obvious. Sparks taught a distributed computing system organized into a hierarchy of "tiers" containing nodes, which Petitioner asserted a person of ordinary skill in the art (POSITA) would understand as the claimed "clusters." Sparks's system involved a control node that managed the allocation of computing nodes to these tiers based on defined tier characteristics (e.g., minimum/maximum node counts, CPU type, memory), which Petitioner mapped to the claimed "bundle-type parameters." Petitioner contended that Bram taught the missing licensing elements. Bram disclosed a system for licensing software in a clustered environment, including a license server and license control files specifying parameters like authorized named nodes, concurrent activation limits, and operating system types. These were argued to meet the limitations for "node license parameters."

      The combination allegedly taught all steps of independent claim 1: storing license information (from Bram) in a memory module on a control node (from Sparks), initializing a cluster (Sparks's tier creation), adding nodes (Sparks's node allocation), and activating the cluster when a node count complies with a parameter (Sparks's process of enabling a tier once its minimum node count is met). Petitioner further argued that key dependent claims were also taught. For claim 2, Bram’s license server was described as an "external licensing server." For claim 3, Sparks was shown to explicitly teach defining policies with "a minimum number of nodes a tier requires" and a "maximum number" of nodes. For claim 6, Bram taught initiating a license check while the system is operating, for example, by rechecking the system state periodically via a timer. The system claims (e.g., claim 9) were argued to be obvious for the same reasons, with the control node of Sparks embodying the claimed functional modules configured with Bram's licensing logic.

    • Motivation to Combine (for §103 grounds): Petitioner asserted multiple motivations for a POSITA to combine the references. First, Sparks disclosed a system that already defined and tracked various node and tier requirements, and adding licensing was a well-known, common requirement for managing software resources in such systems. Second, Bram provided a known solution—a robust licensing framework—to the known problem of controlling software access and functionality in the very field of clustered computing addressed by Sparks. Third, a POSITA would be motivated by strong commercial and legal reasons to incorporate licensing, such as preventing the use of unauthorized functionality and avoiding civil penalties associated with software piracy, a widely publicized risk at the time. Applying Bram’s known licensing technique to Sparks’s known system would predictably result in an improved system with necessary license enforcement capabilities.

    • Expectation of Success (for §103 grounds): Petitioner argued that a POSITA would have had a reasonable expectation of success because both Sparks and Bram operated in the same technical field of clustered and distributed computing systems. The integration was presented as a straightforward application of Bram's licensing functionality to the control node of Sparks's system. Because the components were designed for similar environments, they would work together predictably to add licensing control to Sparks's cluster management system without requiring undue experimentation.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-18 of the ’416 patent as unpatentable.