IPR2014-00136
`
`Oral Argument for Parallel Networks
`(Patent Owner)
`
`U.S. Patent No. 7,188,145
`
`www.mcguirewoods.com
`
`
`
`Oral Argument for Parallel Networks
`(Patent Owner)
`
`U.S. Patent No. 7,188,145
`
`www.mcguirewoods.com
`
`
`
`Inohara does not disclose “allowing a client to
`join [a] cache community.”
`
` “A proper construction of ‘cache community’ is a common identity that
`shares, participates, and forms a fellowship to cache content.” Response to
`Petition, Paper 23 at 2.
` A construction of “allowing as meaning to permit the presence of…is
`consistent with the Specification of the ‘145 patent because it
`describes…that client 404 may be denied entry.” Decision, Paper 15 at 14.
` The cache community of Inohara is the “hierarchical cache that works by
`caching content at server groups forming branches of a hierarchical tree
`structure…” Response to Petition, Paper 23 at 5.
` “Inohara does not teach denying a server membership in…an individual
`server group.” Declaration of Dr. Mitchell A. Thornton, Document 2002,
`Paragraph 43.
`
`McGuireWoods | 2
`CONFIDENTIAL
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`
`
`Claim Construction
`
` Cache Community
` The Board construed “community to mean ‘similarity or identity’ or
`‘sharing, participation and fellowship.’” Decision, Paper 15, Page 13.
` A “‘cache community’ is a common identity that shares, participates, and
`forms a fellowship to cache content.” Response to Petition, Paper 23 at 2.
`
` “Allowing”
` The Board construed “allowing” as “to permit the presence of.” Decision,
`Paper 15 at 14.
` According to the Board, such construction “is consistent with the
`Specification of the ‘145 patent because it describes…that client 404 may
`be denied entry.” Decision, Paper 15 at 14.
`
`McGuireWoods | 3
`CONFIDENTIAL
`
`
`
`The Cache Community of Inohara
`
` “After studying the Inohara reference, I have concluded that Inohara’s
`primary premise of design is that membership in a cache architecture
`should not be limited…Inohara addresses the need for a cache system
`that is suitable for use for the world-wide web (the “Internet”). Inohara
`discussed problems that need to be solved for a cache system to
`function for a network as large as the Internet.” Declaration of Dr.
`Mitchell A. Thornton, Document 2002, Paragraph 28.
` Inohara’s solution is “a multi-cast hierarchy of server operation
`information by virtue of the mutual support of server groups. The
`multi-cast hierarchy includes groups of a tree structure formed by server
`groups.” Inohara at 4:3-6.
`
`McGuireWoods | 4
`CONFIDENTIAL
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`
`
`The Cache Community of Inohara
` “In Inohara, the cache hierarchy is described as being ‘mutually
`supporting,’ and as including “groups of a tree structure formed by
`server groups.’” Response to Petition, Paper 23 at 7.
` A “cooperative cache…cooperate[s] in a single architecture to expand
`the amount of cached content available to users of the cooperative
`cache. In addition to the goal of reducing the delay penalty of object
`retrieval, the goals of such an architecture are to increase the likelihood
`of finding an object within the cache, or the ‘hit rate.’” Declaration of
`Dr. Mitchell A. Thornton, Document 2002, Paragraph 21.
` A “‘wide-area cooperative cache management protocol’ is provided.
`This protocol performs the propagation of a cache directory (a list of
`URLs in caches) using the multi-cast hierarchy formed by the above-
`mentioned server status propagation protocol and a cache control
`(which URL does which server hold in a cache, and when is which
`URL to be transferred from a certain server to another server)…”
`Inohara, 4:23-31.
`
`McGuireWoods | 5
`CONFIDENTIAL
`
`
`
`The Cache Community of Inohara
`
` “[C]onsistent with the Board’s construction of community, the
`‘identity’ within Inohara that ‘shares, participates, and forms a
`fellowship’ in caching content is the identity of the overall hierarchy,
`not the identity of an individual group of server leafs forming one
`branch of such cache hierarchy.” Response to Petition, Paper 23 at 15.
` “To hold that Inohara’s single server group is a cache community or
`community is therefore inconsistent with the Board’s construction of
`community, as Inohara’s central teaching is that a single cache
`hierarchy of multiple server groups forms a cooperative community that
`cooperates to share content in a manner that overcomes the size
`limitations of other caching architectures.” Response to Petition, Paper
`23 at 17.
`
`McGuireWoods | 6
`CONFIDENTIAL
`
`
`
`The Hierarchy Organization Process of Inohara
`
` “Inohara discusses problems that need to be solved for a cache
`system to function for a network as large as the Internet. Col. 1, lines
`7-15. One of such problems discussed is the heavy administrative
`burden in configuring the cache system to establish cooperation
`between servers of cache content.” Declaration of Dr. Mitchell A.
`Thornton, Document 2002, Paragraph 28.
`
` “To reduce such an administrative burden, Inohara describes a
`process to dynamically structure a multi-cast hierarchy that includes
`many groups of servers arranged in a tree structure. Col. 4, lines 1-9.
`Each group of servers has a leader, which in turn forms a higher-
`level logical group with other leaders of other high level groups,
`each high level group thereby forming branches of the still higher
`logical level group. Col. 7, lines 51-56.” Declaration of Dr. Mitchell
`A. Thornton, Document 2002, Paragraph 29.
`
`McGuireWoods | 7
`CONFIDENTIAL
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`
`
`The Hierarchy Organization Process of Inohara
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`McGuireWoods | 8
`CONFIDENTIAL
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`
`
`The Hierarchy Organization Process of Inohara
`
` “[T]he reason for imposing a maximum number of servers in any
`particular branch of the cache hierarchy is to limit the communications
`required from a single server to manage caching between the servers on
`any such branch to an acceptable level.” Declaration of Dr. Mitchell A.
`Thornton, Document 2002, Paragraph 32.
`
` “Inohara describes three different scenarios with respect to adding new
`servers to a server group.” Declaration of Dr. Mitchell A. Thornton,
`Document 2002, Paragraph 34.
`
`McGuireWoods | 9
`CONFIDENTIAL
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`
`
`The Hierarchy Organization Process of Inohara
`“In the first scenario, if adding all of the new servers to the server group would
`not cause the group to go above a maximum number, the new servers are
`added to the existing server group without further reorganization.”
`Declaration of Dr. Mitchell A. Thornton, Document 2002, Paragraph 34.
`
`McGuireWoods | 10
`CONFIDENTIAL
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`
`
`The Hierarchy Organization Process of Inohara
`
` “In the second scenario, if adding all of the new servers would cause the group to go
`above a maximum number, then a second determination of whether adding even one
`of the new servers would cause the group to go above the maximum number.”
`Declaration of Dr. Mitchell A. Thornton, Document 2002, Paragraph 35.
`
` “If the answer to the second determination is no, then the first new server is added
`to the existing group to form a first sub-group and the remaining new servers form a
`second sub-group branching off of the first subgroup with the first new server as the
`leader of the second sub-group, such second sub-group thereby becoming a branch
`of the now higher level first sub-group.” Declaration of Dr. Mitchell A. Thornton,
`Document 2002, Paragraph 35.
`
`McGuireWoods | 11
`CONFIDENTIAL
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`
`
`The Hierarchy Organization Process of Inohara
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`McGuireWoods | 12
`CONFIDENTIAL
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`
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`The Hierarchy Organization Process of Inohara
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` In the third scenario, “as a result of the new servers requesting to join the
`original group of servers, the original group is split into three sub-groups
`that cooperate to share cached content (one higher level sub-group and two
`lower level sub-groups forming branches of the higher level group).”
`Declaration of Dr. Mitchell A. Thornton, Document 2002, Paragraph 36.
`
`McGuireWoods | 13
`CONFIDENTIAL
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`
`
`The Hierarchy Organization Process of Inohara
`
` “In all three scenarios, the process described by Inohara results in the
`new servers being added to the same caching tree hierarchy and
`cooperating to share cached content. As illustrated, in all three
`scenarios, new joining servers are placed into the existing group or sub-
`groups with previously existing members of the existing server group
`within a single caching system.” Declaration of Dr. Mitchell A.
`Thornton, Document 2002, Paragraph 40.
`
`McGuireWoods | 14
`CONFIDENTIAL
`
`
`
`The Hierarchy Organization Process of Inohara
`
` “In all of the scenarios described in Inohara where servers seek to be
`added to the hierarchy, all servers requesting membership in the cache
`system are admitted, assigned a position within the caching hierarchy,
`and cooperate to share cached content with the cache hierarchy.”
`Declaration of Dr. Mitchell A. Thornton, Document 2002, Paragraph
`43.
`
` “Even when the cache hierarchy has to go to the extreme of
`restructuring the individual server group that received a join request into
`the described sub-groups, the new server or servers are always accepted
`into the individual server group.” Declaration of Dr. Mitchell A.
`Thornton, Document 2002, Paragraph 43.
`
`McGuireWoods | 15
`CONFIDENTIAL
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`
`
`Inohara Teaches Away from Denial
`
` “All of the goals and issues described in Inohara are means to the ultimate
`end of achieving a cache hierarchy that is infinitely scalable. Inohara
`clearly teaches away from any concept of permission, determination, or
`any limiting or denial of membership.” Declaration of Dr. Mitchell A.
`Thornton, Document 2002, Paragraph 44.
`
` “Adding the possibility of denial of servers into the cache hierarchy of
`Inohara, based on size or otherwise, would render Inohara inoperable for
`its intended purpose of serving as a distributed caching system for the
`entire Internet or other large scale networks.” Declaration of Dr. Mitchell
`A. Thornton, Document 2002, Paragraph 44.
`
`McGuireWoods | 16
`CONFIDENTIAL
`
`
`
`“The overriding principle of Inohara is
`inclusion.”
`
`Declaration of Dr. Mitchell A. Thornton, Document 2002, Paragraph 44.
`
`McGuireWoods | 17
`CONFIDENTIAL
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