IPR2020-00191 Petition
`U.S. Patent 6,513,062
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`———————
`
`UNIFIED PATENTS INC.
`
`Petitioner
`
`v.
`
`ACCELERATED MEMORY TECH, LLC
`
`
`
`
`
`
`
`
`
`
`Patent Owner
`
`———————
`
`IPR2020-00191
`
`U.S. Patent 6,513,062
`
`PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT 6,513,062
`CHALLENGING CLAIMS 1–7
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`
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`I.  MANDATORY NOTICES UNDER 37 C.F.R. § 42.8 ....................................... 1 
`
`A.  Real Party-in-Interest ................................................................................. 1 
`
`B.  Related Matters .......................................................................................... 1 
`
`C.  Lead and Back-up Counsel and Service Information ............................... 1 
`
`II.  CERTIFICATION OF GROUNDS FOR STANDING ....................................... 2 
`
`III. OVERVIEW OF CHALLENGE AND RELIEF REQUESTED ........................ 3 
`
`A.  Prior Art Patents ........................................................................................ 3 
`
`B.  Statutory Grounds for Challenges ............................................................. 4 
`
`IV. U.S. Patent 6,513,062 ........................................................................................... 4 
`
`A.  Summary .................................................................................................... 4 
`
`B.  Level of Ordinary Skill in the Art ............................................................. 6 
`
`C.  Prosecution History ................................................................................... 7 
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`D.  Priority Date .............................................................................................. 8 
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`V.  CLAIM CONSTRUCTION ................................................................................. 8 
`
`A. 
`
`B. 
`
`C. 
`
`D. 
`
`E. 
`
`F. 
`
`“external name” ......................................................................................... 9 
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`“internal name” ........................................................................................ 10 
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`“intermediate state information” ............................................................. 11 
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`“mapping” ................................................................................................ 13 
`
`“a request receiver configured for receiving a first request for a first
`resource” .................................................................................................. 14 
`
`“a request handler configured for deriving intermediate state
`information used in generating a first response to said first request,
`said intermediate state information comprising a result of mapping
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`an external name of the first request for the first resource to an
`internal name associated with the first resource” .................................... 15 
`
`G. 
`
`“a request handler configured for retrieving said intermediate state
`information and further configured for generating a second response
`to said second request using intermediate state information” ................. 16 
`
`VI. CLAIMS 1–7 ARE UNPATENTABLE ............................................................ 17 
`
`A.  Ground 1: Jenkins renders claims 1–7 obvious ....................................... 17 
`
`1.  Overview of Jenkins ........................................................................ 17 
`
`2.  Analysis ........................................................................................... 21 
`
`B.  Ground 2: Claims 1, 4, and 6 are rendered obvious by Huitema in
`view of Mogul .......................................................................................... 50 
`
`1.  Overview of Huitema ...................................................................... 50 
`
`2.  Overview of Mogul ......................................................................... 52 
`
`3.  Analysis ........................................................................................... 52 
`
`VII.  Discretionary institution .................................................................................. 71 
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`VIII. CONCLUSION ................................................................................................ 73 
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`IX. CERTIFICATE OF WORD COUNT ................................................................ 74 
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`
`PETITIONER’S EXHIBIT LIST
`
`EX1001 U.S. Patent 6,513,062 to Jay C. Weber
`EX1002
`Prosecution File History of U.S. Patent 6,513,062 (“’062 PH”)
`EX1003 Declaration of Dr. Narasimha Reddy
`EX1004 U.S. Patent 6,014,667 to Jenkins et al. (“Jenkins”)
`EX1005 U.S. Patent 6,016,512 to Huitema et al. (“Huitema”)
`EX1006
`P. Mockapetris, RFC 1035, Domain Names – Implementation and
`Specification, November 1987 (“Mockapetris”)
`EX1007 Complaint for Patent Infringement, Accelerated Memory Tech, LLC
`v. Citrix Systems, Inc. (N.D. Ga.)
`EX1008 Microsoft Computer Dictionary (4th ed.) (excerpts)
`EX1009 U.S. Patent 6,262,987 to Jeffrey C. Mogul (“Mogul”)
`EX1010 Unified Patents Voluntary Interrogatories
`EX1011 U.S. Patent 5,774,660 to Brendel et al. (“Brendel”)
`EX1012 RPX, “February Sees Assignments to a Crop of New NPEs,” last
`retrieved November 4, 2019.
`EX1013 Assignment Records for ’062 Patent
`EX1014
`https://www.bizapedia.com/ga/accelerated-memory-tech-llc.html
`EX1015 U.S. Patent 5,864,852 to Ari Luotonen (“Luotonen”)
`EX1016 WO 99/14652 to Brundrett et al. (“Brundrett”)
`EX1017 WO 98/26353 to Spilo et al. (“Spilo”)
`EX1018 RFC 2068
`EX1019 Reddy, A.L. Narasimha, Evaluation of Caching Strategies for an
`Internet Server
`
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`I. MANDATORY NOTICES UNDER 37 C.F.R. § 42.8
`A. Real Party-in-Interest
`
`Pursuant to 37 C.F.R. § 42.8(b)(1), Unified Patents Inc. (“Unified” or
`
`“Petitioner”) certifies that Unified is the real party-in-interest, and further certifies
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`that no other party exercised control or could exercise control over Unified’s
`
`participation in this proceeding, the filing of this petition, or the conduct of any
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`ensuing trial. In view of Worlds Inc. v. Bungie, Inc., 903 F.3d 1237, 1242–44 (Fed.
`
`Cir. 2018), Unified has submitted voluntary discovery in support of its certification.
`
`See EX1010 (Petitioner’s Voluntary Interrogatory Responses).
`
`B. Related Matters
`
`As of the filing date of this Petition, and to the best knowledge of Petitioner,
`
`the ’062 Patent is or has been involved in the following matters:
`
`Case Caption
`Accelerated Memory Tech, LLC v. Hulu, LLC (D. Del.)
`Accelerated Memory Tech, LLC v. Kemp Technologies, Inc. (D.
`Del.)
`Accelerated Memory Tech, LLC v. F5 Networks, Inc. (W.D. Wa.)
`Accelerated Memory Tech, LLC v. Barracuda Networks, Inc. (N.D.
`Ga.)
`Accelerated Memory Tech, LLC v. Citrix Systems, Inc. (N.D. Ga.)
`
`Number
`1-19-cv-01158
`
`1-19-cv-00939
`
`2-19-cv-00183
`
`2-18-cv-00175
`
`2-18-cv-00052
`
`
`
`
`
`C. Lead and Back-up Counsel and Service Information
`
`1
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`

`

`Lead Counsel
`Raghav Bajaj
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`Back-up Counsel
`Ashraf Fawzy
`Unified Patents Inc.
`1875 Connecticut Ave NW, Floor 10
`Washington, DC 20009
`
`Jonathan Stroud
`Unified Patents Inc.
`1875 Connecticut Ave NW, Floor 10
`Washington, DC 20009
`
`David L. McCombs
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`Angela Oliver
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`
`202-871-0110
`
`
`512-867-8520
`Phone:
`214-200-0853
`Fax:
`
`raghav.bajaj.ipr@haynesboone.com
`USPTO Reg. No. 66,630
`
`Phone:
`
`afawzy@unifiedpatents.com
`USPTO Reg. No. 67,914
`
`Phone:
`
`jonathan@unifiedpatents.com
`USPTO Reg. No. 72,518
`
`Phone:
`
`david.mccombs.ipr@haynesboone.com
`USPTO Reg. No. 32,271
`
`Phone:
`
`angela.oliver.ipr@haynesboone.com
`USPTO Reg. No. 73,271
`
`202-805-8931
`
`214-651-5533
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`202-654-4552
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`Please address all correspondence to lead and back-up counsel. Petitioner
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`consents to electronic service.
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`II. CERTIFICATION OF GROUNDS FOR STANDING
`
`Petitioner certifies pursuant to Rule 42.104(a) that the patent for which review
`
`is sought is available for inter partes review and that Petitioner is not barred or
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`estopped from requesting an inter partes review challenging the patent claims on the
`
`grounds identified in this Petition.
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`III. OVERVIEW OF CHALLENGE AND RELIEF REQUESTED
`
`Pursuant to Rules 42.22(a)(1) and 42.104(b)(1)–(2), Petitioner challenges
`
`claims 1–7 (“Challenged Claims”) of the ’062 Patent.
`
`A. Prior Art Patents
`
`The following references are pertinent to the grounds of unpatentability
`
`explained below:
`
`1. U.S. Patent 6,014,667 to Jenkins et al. (filed October 1, 1997, issued January
`
`11, 2000) (“Jenkins” (EX1004)), which is prior art under at least 35 U.S.C.
`
`§ 102(e).1
`
`2. U.S. Patent 6,016,512 to Christian Huitema (filed August 18, 1998, issued
`
`January 18, 2000) (“Huitema” (EX1005)), which is prior art under at least
`
`35 U.S.C. § 102(e).
`
`3. U.S. Patent 6,262,987 to Jeffrey C. Mogul (filed March 26, 1998, issued July
`
`17, 2001) (“Mogul” (EX1009)), which is prior art under at least 35 U.S.C. §
`
`102(e).
`
`None of the above prior art was cited during prosecution of the ’062 Patent.
`
`
`1 The ’062 Patent issued from an application filed prior to the enactment of the
`
`America Invents Act (“AIA”). Thus, the pre-AIA statutory framework applies.
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`3
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`
`B. Statutory Grounds for Challenges
`
`This Petition, supported by the declaration of Dr. Narasimha Reddy (“Reddy
`
`Declaration” or “Reddy” (EX1003)), requests cancellation of claims 1–7 under the
`
`Grounds listed below:
`
`Ground #1: Claims 1–7 of the ’062 Patent are obvious under 35 U.S.C.
`
`§ 103(a) over Jenkins.
`
`Ground #2: Claims 1, 4, and 6 of the ’062 Patent are obvious under 35 U.S.C.
`
`§ 103(a) over Huitema in view of Mogul.
`
`
`
`IV. U.S. PATENT 6,513,062
`A. Summary
`
`The ’062 Patent is directed to a “system for improving server efficiency by
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`caching intermediate states encountered in generating responses to requests.” ’062
`
`Patent (EX1001), Abstract. The ’062 Patent explains that “conventional servers are
`
`not highly efficient,” because “when a conventional HTTP server [] receives a
`
`request for a uniform resource identifier (‘URI’), it first parses the request, then
`
`parses header lines” and “applies a rewrite mapping process that transforms an
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`external name for the resource (in the URI) to an internal name used for locating the
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`resource and generating the response.” Id. at 1:40–47. According to the ’062 Patent,
`
`this process requires “computational expense,” and this computational expense is
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`repeatedly required if subsequent requests for the same source are later received. Id.
`
`at 1:48–58.
`
`Thus, the ’062 Patent purports to provide “performance improvements based
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`on elimination of repeated processing” by more “efficiently generating responses for
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`repeated resource requests,” which includes “caching [] intermediate state
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`information” that is used in generating responses to requests. Id. at 1:7–11, 2:18–
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`32.
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`Independent claim 1 reads:
`
`1. A computer-implemented method for efficiently generating
`responses for repeated resource requests, said method comprising:
`
`receiving a first request for a first resource;
`
`deriving intermediate state information used in generating a first
`response to said first request, said intermediate state information
`comprising a result of mapping an external name of the first request
`for the first resource to an internal name associated with the first
`resource;
`
`caching said intermediate state information;
`
`receiving a second request for said first resource;
`
`retrieving said intermediate state information; and
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`generating a second response to said second request using said
`intermediate state information.
`
`But prior to the ’062 Patent’s priority date, caching intermediate state
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`information––effectively, caching an internal identifier or location for a resource––
`
`was well known. For example, Jenkins teaches that “[r]equests to access an object
`
`may be serviced by cached information rather than making one or more attempts to
`
`obtain location information from servers.” Jenkins (EX1004), Abstract. Other well-
`
`known technologies laid out in publications prior to the ’062 Patent describe similar
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`concepts; for example, RFC 1035, issued in 1987, describes the domain name system
`
`(a fundamental backbone of the Internet), and includes a description of a common
`
`configuration that caches mappings from external domain names to internal IP
`
`addresses. Mockapetris (EX1006), p. 4. Thus, the ’062 Patent’s concepts and
`
`methods simply restate caching techniques well known to persons of skill in the art
`
`prior to the alleged priority date. Jenkins and the remaining art of the present petition
`
`(as supported by the declaration of Dr. Reddy) disclose or render obvious all
`
`elements of the challenged claims, as discussed below.
`
`B. Level of Ordinary Skill in the Art
`
`A person of ordinary skill in the art at and before the priority date for the ’062
`
`Patent (“POSITA”) would have had a bachelor’s degree in computer science,
`
`computer engineering, electrical engineering, or a related subject, and one to two
`
`years of work experience with networking. Less experience may be necessary with
`
`additional education (e.g., a Master’s degree); likewise, less education may be
`
`necessary with additional work experience (e.g., 4–5 years). Reddy (EX1003),
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`
`¶¶ 42–45.
`
`C. Prosecution History
`
`The ’062 Patent issued from U.S. Patent Application Number 09/318,493
`
`(“the ’493 Application”), which was filed May 25, 1999. The ’062 Patent does not
`
`claim priority benefit to any earlier application.
`
`
`
`The claims of the ’493 Application were initially rejected as obvious over U.S.
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`Patent No. 6,185,608 to Hon et al. See EX1002 at 66. In response to the rejection,
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`the applicant alleged that Hon was “devoid of any teaching of deriving intermediate
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`state information used in generating a first response” and instead, Hon “discloses
`
`caching the actual resource and not the intermediate state information used in
`
`efficiently locating that resource in the internal file system of the server.” Id. at 74.2
`
`The applicant did not amend any independent claims in its response, but did amend
`
`dependent claims 3, 7, and 12 to recite that the intermediate state information
`
`comprises “a result of mapping an external name of the first request for the first
`
`resource to an internal name associated with the first resource.” Id. at 77.
`
`
`2 Notably, claim 1 of the ’062 Patent recites “caching said intermediate state
`
`information,” while dependent claim 3 recites that “intermediate state information
`
`comprises said first resource,” suggesting that the examiner was not incorrect in his
`
`mapping of prior art.
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`The Examiner then issued a final office action, rejecting most of the ’493
`
`
`
`Application’s claims over Hon. Id. at 89. The Examiner noted, however, that
`
`dependent claims 3, 7, and 12 would be allowable if incorporated into the
`
`independent claims. Id. at 90. The applicant took the Examiner’s suggestion,
`
`amending the independent claims to incorporate the limitations of the allowable
`
`dependent claims. After a telephone interview and a restriction requirement, the
`
`’493 Application issued as the ’062 Patent.
`
`But as noted above and explained below, prior to the ’062 Patent’s priority
`
`date, Jenkins taught the concept of caching a mapping between an external name
`
`contained in a request to an internal name for the requested resource—thereby
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`disclosing (in prior art not considered by the Office) the very aspects the Applicant
`
`argued the Hon reference did not teach in prosecution. Jenkins, together with the
`
`other prior art cited herein, teach every limitation of the challenged claims—and thus
`
`render the challenged claims unpatentable obvious.
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`D. Priority Date
`
`For purposes of this proceeding, Petitioner assumes a priority date of May 25,
`
`1999 (i.e., the filing of the ’493 Application).
`
`
`
`V. CLAIM CONSTRUCTION
`
`The challenged claims of the ’062 Patent are construed herein “using the same
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`claim construction standard that would be used to construe the claim in a civil action
`
`under 35 U.S.C. § 282(b).” 37 C.F.R. § 42.100(b) (Nov. 13, 2018). The claim terms
`
`below are thus construed “in accordance with the ordinary and customary meaning
`
`of such claim as understood by one of ordinary skill in the art and the prosecution
`
`history pertaining to the patent.” Id. Terms not specifically construed below have
`
`their plain and ordinary meaning.
`
`A. “external name”
`
`This term is recited in challenged independent claims 1, 4, and 6.
`
`The ’062 Patent does not provide an express definition for the term “external
`
`name.” In explaining the prior art, the ’062 Patent states that an HTTP server
`
`“receives a request for a uniform resource identifier (‘URI’)” and “applies a rewrite
`
`mapping process that transforms an external name for the resource (in the URI) to
`
`an internal name….” ’062 Patent (EX1001), 1:40–47. The ’062 Patent also explains
`
`in a summary portion that “an HTTP Request Message (comprising a URI) arrives”
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`and the “server determines if a URI descriptor has already been cached.” Id. at 3:8–
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`11. Thus, an “external name” would be understood by a POSITA to be an identifier
`
`used in requesting a resource or object (e.g., by a user issuing a request for the
`
`resource using its URI or another similar identifier known outside of the server).
`
`Although the only “external name” described in the specification is a URI, the claims
`
`should not be limited to this embodiment, as the ’062 Patent specification made clear
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`that “embodiments of the invention could work with other communication protocols
`
`and the particular protocol is not fundamental” (i.e., the use of HTTP Request
`
`Messages with URIs is not critical). Id. at 4:51–54. Similarly, the ’062 Patent does
`
`not contain any “clear and unmistakable” disclaimer to limit the claims to the sole
`
`example of the specification, see Continental Circuits LLC v. Intel Corp., 915 F.3d
`
`788, 797 (Fed. Cir. 2019). The patentee was able to draft or amend the claims to
`
`recite a URI, and did not.
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`Based on this disclosure, a POSITA would have understood the claim term
`
`“external name” to mean an “identifier used in requesting a resource.” Reddy
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`(EX1003), ¶¶ 50–54.
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`B. “internal name”
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`This term is recited in challenged independent claims 1, 4, and 6.
`
`The ’062 Patent does not provide an express definition for the term “internal
`
`name.” However, the ’062 Patent states that “[t]ypically the internal name is a
`
`location in the filesystem of the hardware running the server process” but can also
`
`be “debugging information, a directory listing, or one of several default internal
`
`names of the server process.” ’062 Patent (EX1001), 5:10–16. Additionally, in the
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`Background section, the ’062 Patent explains that an “internal name” is one that is
`
`“used for locating the resource and generating the response.” Id. at 1:44–46.
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`Based on this disclosure, a POSITA would have understood the claim term
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`“internal name” to mean an “identifier that can be used to locate a resource.” Reddy
`
`(EX1003), ¶¶ 55–59.
`
`C. “intermediate state information”
`
`This term is recited in challenged independent claims 1, 4, and 6.
`
`In context, the claim term is recited as follows: “intermediate state
`
`information comprising a result of mapping an external name of the first request for
`
`the first resource to an internal name associated with the first resource.” ’062 Patent
`
`(EX1001), 9:2–6.
`
`The ’062 Patent explains that “[i]llustrative examples of what the
`
`intermediate state
`
`information may comprise
`
`include: an
`
`internal name
`
`corresponding to the first resource and a type of the first resource; the first resource;
`
`or a plurality of response header lines for the first resource.” See ’062 Patent
`
`(EX1001), 2:28–32. Thus, the a POSITA would have understood that “intermediate
`
`state information” at least encompasses any of the above-enumerated and non-
`
`exhaustive examples, i.e., an internal name corresponding to the first resource and a
`
`type of the first resource, the first resource, a plurality of response header lines for
`
`the first resource, or other similar information.
`
`Within the context of claim 1, “intermediate state information” comprises at
`
`least the internal name associated with the first resource, as the “result of mapping
`
`an external name of the first request for the first resource” is at least the “internal
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`name associated with the first resource.” This is supported by the intrinsic record.
`
`For example, claim 2 depends from independent claim 1, and further limits the
`
`“intermediate state information” in claim 1 by requiring that “said intermediate state
`
`information comprises: an internal name corresponding to said first resource; and a
`
`type of said first resource….” ’062 Patent (EX1001), 9:13–15. As a “claim in
`
`dependent form shall…specify a further limitation of the subject matter claimed,”
`
`(35 U.S.C. § 112 ¶ 4), independent claim 1 must be broader than dependent claim 2,
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`and thus one example of the “intermediate state information” in claim 1 is just the
`
`“internal name corresponding to said first resource.” Reddy (EX1003), ¶ 65. In
`
`other words,
`
`the
`
`intrinsic record supports construing “intermediate state
`
`information” at a minimum as including the “internal name,” because of the non-
`
`exhaustive open-ended examples in the specification and claim 2’s additional
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`limitation to the intermediate state information of further requiring the “type of said
`
`first resource” in addition to the “internal name.” Id.
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`The Specification also states: “the flexible mapping from the URI to an
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`internal name
`
`involves relatively computationally expensive parsing and
`
`extraction. Appreciable efficiencies may be obtained by caching the results of this
`
`mapping so that it need not be repeated for succeeding requests for the same
`
`resource.” ’062 Patent (EX1001), 5:19–21. That is, an external name is mapped to
`
`a resultant internal name, and the resultant internal name is cached. Because claim
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`1 recites “caching said intermediate state information,” (id. at 9:8) and the
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`Specification describes “caching the results of this mapping” (i.e., the internal name,
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`id. at 5:22–24), construing “intermediate state information” as including the
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`“internal name” (i.e., the information that is cached, or the result of the mapping) is
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`supported by the intrinsic record for this additional reason.
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`The prosecution history also supports this construction. As detailed above,
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`the claim term “internal name” means “an identifier that can be used to locate a
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`resource.” During prosecution, the applicant argued that “[i]ntermediate state
`
`information is used to locate a requested resource,” which supports construing
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`“intermediate state information” as including an “internal name.” See ’062 PH
`
`(EX1002), 74.
`
`Thus, based on the ’062 Patent, the claim term “intermediate state
`
`information” of claim 1 should be construed to include at least the “internal name.”
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`Reddy (EX1003), ¶¶ 60–68. The “intermediate state information” may also include
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`additional data, e.g., the intermediate state information may also include a type of
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`the first resource, the first resource itself, or a plurality of response header lines for
`
`the first resource, but the independent claims do not require such additional data.
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`D. “mapping”
`
`This term is recited in claims 1, 4, and 6.
`
`The ’062 Patent provides examples of what is meant by “mapping.” For
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`example, in the Background section, the ’062 Patent describes an “HTTP server”
`
`applying a “rewrite mapping process that transforms an external name for the
`
`resource (in the URI) to an internal name used for locating the resource and
`
`generating the response. Conventional modules for performing the rewrite mapping
`
`are powerful and flexible….” ’062 Patent (EX1001), 1:40–47. The ’062 Patent also
`
`describes that “‘URI rewrite mapping’ process 2050 performs a translation from the
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`URI to an internal name for the resource associated with the URI….” Id. at 5:10–
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`12. The description of “mapping” as including a translation is consistent with the
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`Microsoft Computer Dictionary’s definition of “map” as “to translate one value into
`
`another.” Microsoft Computer Dictionary (EX1008), p. 281. Accordingly,
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`“mapping” should be construed as “translating one value into another.” Reddy
`
`(EX1003), ¶¶ 69–72.
`
`E. “a request receiver configured for receiving a first request for a
`first resource”
`
`This term is recited in claim 4. Although not explicitly drafted in “means-
`
`plus-function” format, to the extent the Board considers the presumption overcome3
`
`and considers this term to be governed by 35 U.S.C. § 112 ¶ 6, Petitioner provides
`
`
`3 Williamson v. Citrix Online, LLC, 792 F.3d 1339, 1348 (Fed. Cir. 2015) (“[F]ailure
`
`to use the word ‘means’ [] creates a rebuttable presumption…that § 112 ¶ 6 does not
`
`apply.”)
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`the following identification of the portions of the specification that describe the
`
`structure, material, or acts corresponding to the claimed function of “receiving a first
`
`request for a first resource.”
`
`Structure: processor 3010 programmed to perform the steps disclosed in the
`
`Specification’s description of request 2020 (see e.g., ’062 Patent (EX1001), Figure
`
`2, 4:47–62), and equivalents thereof. Reddy (EX1003), ¶¶ 73–74.
`
`F. “a request handler configured for deriving intermediate state
`information used in generating a first response to said first request,
`said intermediate state information comprising a result of mapping
`an external name of the first request for the first resource to an
`internal name associated with the first resource”
`
`This term is recited in claim 4. Although not explicitly drafted in “means-
`
`plus-function” format, to the extent the Board considers this term to be governed by
`
`35 U.S.C. § 112 ¶ 6, Petitioner provides the following identification of the portions
`
`of the specification that describe the structure, material, or acts corresponding to the
`
`claimed function of “deriving intermediate state information used in generating a
`
`first response to said first request.”
`
`Structure: processor 3010 programmed to perform the steps disclosed in the
`
`Specification’s description of at least steps 2050 and 2060 (see e.g., ’062 Patent
`
`(EX1001), Figure 2, 5:10–35), and equivalents thereof. Reddy (EX1003), ¶¶ 75–76.
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`G. “a request handler configured for retrieving said intermediate state
`information and further configured for generating a second
`response to said second request using
`intermediate state
`information”
`
`This term is recited in claim 4. Although not explicitly drafted in “means-
`
`plus-function” format, to the extent the Board considers this term to be governed by
`
`35 U.S.C. § 112 ¶ 6, Petitioner provides the following identification of the portions
`
`of the specification that describe the structure, material, or acts corresponding to the
`
`claimed functions of “retrieving said intermediate state information” and
`
`“generating a second response to said second request using intermediate state
`
`information.”
`
`Structure: processor 3010 programmed to perform the steps disclosed in the
`
`Specification’s description of at least step 2220 and 2110 (see e.g., ’062 Patent
`
`(EX1001), Figure 2, 7:59–67 and 6:48–52), and equivalents thereof. Reddy
`
`(EX1003), ¶¶ 77–78.
`
`
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`
`VI. CLAIMS 1–7 ARE UNPATENTABLE4
`A. Ground 1: Jenkins renders claims 1–7 obvious
`1. Overview of Jenkins
`
`Jenkins, which has a priority date of October 1, 1997, and was not of record
`
`during prosecution, is directed to “caching information in a distributed computer
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`system.” Jenkins (EX1004), Abstract. Jenkins, like the ’062 Patent, notes that it
`
`would “be an advancement in the art to provide a method and system for improving
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`the speed and efficiency with which references are used in a distributed system.” Id.
`
`at 3:18–20. Jenkins provides such an advancement by “placing at least one tuple”
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`(e.g., a database entry) “in a cache,” where each tuple contains “a component
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`identifier, such as a distinguished name” as well as “a location identifier…which
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`identifies a location at which the cache-enabled component resides.” Id. at 3:28–37.
`
`To elaborate, Jenkins describes, with reference to Figure 3, “an initial event
`
`sequence which processes an application request that seeks access to a particular
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`object” and with reference to Figure 4, “a flow diagram illustrating an event
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`sequence occurring after the sequence in FIG. 3, in which the system uses cached
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`information to process later application requests that seek access to the same object
`
`
`4 Unless otherwise specified, all bold emphasis below has been added. Text in italics
`
`is used to signify claim language, while reference names are also italicized.
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`sought in FIG. 3.” Id. at 4:50–58.
`
`external name
`
`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`
`internal name
`
`caching intermediate state
`information
`
`Jenkins (EX1004), Figure 3
`(annotated to reflect teachings of certain claim terms)
`With reference to Figure 3 (and corresponding events that are described in
`
`Figure 1), Jenkins explains that an “application request 100” is received by a client
`
`
`
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`102 that “identifies the object in question by a distinguished name 104.” Id. at 2:1–
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`23. In order to formulate a response, the client 102 sends the distinguished name to
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`a server A 106, and if server A “has a copy, it sends an internal identifier 108 back
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`to the client 102.” Id. at 2:25–37. According to Jenkins, the “internal identifier
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`108…corresponds to an instance of the object identified by the distinguished name.”
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`Id. at 2:37–40. Jenkins explains that “[a]fter the internal identifier 108 is obtained,
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`the client 102 creates a tuple 300 which is placed in a local cache 302 for ready
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`access.” Id. at 6:25–30. Jenkins notes that “in one embodiment the tuple associates
`
`the distinguished name 104 of the object being sought with the internal object
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`identifier 108 provided by the server 114 that has an available copy of the object.”
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`Id. at 6:36–42.
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`19
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`IPR2020-00191 Petition
`U.S. Patent 6,513,062
`
`retrieving intermediate state
`information from cache
`
`
`
`Jenkins (EX1004), Figure 4
`(annotated to reflect teachings of certain claim terms)
`Turning to Figure 4, Jenkins explains that “when the client 102 receives a
`
`subsequent request 100, the client 102 checks the cache 302… client 102 determines
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`whether an available copy of the object sought has already been located by searching
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`the cache 302 for a tuple 300 involving the internal identifier 108…. This check
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`may be initiated by sending the distinguished name(s) 104 in the request 100 to a
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`cache manager….” Id. at 6:63–7:5.
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`In other words, Jenkins describes a process by which, for a first request for an
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`object identified by a distinguished name, a client obtains an internal identifier
`
`corresponding to the distinguished name, and stores in a cache a tuple that associates
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`the distinguished name and internal identifier.