UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
`RELOADED GAMES, INC.
`Petitioner
`
`v.
`
`PARALLEL NETWORKS LLC
`Patent Owner
`____________
`
`Case No. IPR2014-00136
`Patent 7,188,145
` ____________
`
`
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS
`
`
`
`
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
`RELOADED GAMES, INC.
`Petitioner
`
`v.
`
`PARALLEL NETWORKS LLC
`Patent Owner
`____________
`
`Case No. IPR2014-00136
`Patent 7,188,145
` ____________
`
`
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS
`
`
`
`
`
`INTER PARTES REVIEW
`U.S. PATENT NO. 7,188,145
`
`O R A L A R G U M E N T, F E B . 1 2 , 2 0 1 5
`
`
`
`Reloaded Games, Inc. v. Parallel Networks, LLC
`Case No. IPR2014-00136
`
`PETITIONERS DX-1
`
`
`
`OVERVIEW OF PRESENTATION
`
`• U.S. Patent No. 6,341,311 (“Smith”)in view of U.S.
`Patent No. 6,256,747 (“Inohara”)
`
` Disputed limitations:
`• “allowing a client to join the cache
`community” (claims 2-4, 6-7, 10, 16-18, 20-21, 24,
`35)
`• “selecting one of the communities to attempt to
`join” (claims 29-34, 36)
`
` •
`
`PETITIONERS DX-2
`
`
`
`‘145 PATENT – CLAIMS 2-4, 6-7, 10, 16-18,
`20-21, 24, 35
`
`‘145 Patent [Ex. 1001] at Claim 1.
`
`PETITIONERS DX-3
`
`(cid:51)(cid:72)(cid:87)(cid:76)(cid:87)(cid:76)(cid:82)(cid:81)(cid:72)(cid:85)(cid:3)(cid:40)(cid:91)(cid:17)(cid:3)(cid:20)(cid:19)(cid:19)(cid:20)(cid:3)(cid:51)(cid:68)(cid:74)(cid:72)(cid:3)(cid:21)(cid:26)
`
`
`
`‘145 PATENT - CLAIMS 2, 16
`
`(cid:51)(cid:72)(cid:87)(cid:76)(cid:87)(cid:76)(cid:82)(cid:81)(cid:72)(cid:85)(cid:3)(cid:40)(cid:91)(cid:17)(cid:3)(cid:20)(cid:19)(cid:19)(cid:20)(cid:3)(cid:51)(cid:68)(cid:74)(cid:72)(cid:3)(cid:21)(cid:26)
`‘145 Patent [Ex. 1001] at Claim 2.
`
`PETITIONER’S DX-4
`
`
`
`CLAIM CONSTRUCTIONS
`
` “allow”/“allowing” = “permit the presence of.”
` Inst. Dec. [Paper 15] at 14.
`
` •
`
`• “community” = “similarity or identity” or “sharing,
`participation, and fellowship.”
` Inst. Dec. [Paper 15] at 13.
`
`
`
`PETITIONERS DX-5
`
`
`
`INOHARA’S “ALLOWING”
`
`‘145 Patent
`“Master 410 may use any suitable
`criteria to determine whether to
`allow client 404 to join community
`402. For example, master 410 may
`consider whether the addition of
`client 404 would exceed the
`maximum number of members 412
`that may be in community 402 […].”
`
`‘145 Patent [Ex. 1001] at 20:51-55.
`
`Inohara
`“In step 506, the judgment is
`made of whether or not the sum
`of the number of old members
`and the number of new members
`is smaller than MAX mentioned
`earlier.”
`
`
`Inohara [Ex. 1007] at 10:60-63.
`
`PETITIONER’S DX-6
`
`
`
`INOHARA’S “ALLOWING”
`
`‘145 Patent
`“If no communities 100 are found
`or found communities 100 do not
`allow cache module 26, then
`cache module 26 may attempt to
`start its own cache community.”
`
`
`‘145 Patent [Ex. 1001] at 13:33-36;
`see also id. at 24:23-40.
`
`Inohara
`“[T]he judgement is made of
`whether or not the addition of 1 to
`the number of old members is
`smaller than MAX (step 512). […] [I]f
`the judgement in step 512 is N
`(517), a new group is formed (step
`518).”
`
`
`Inohara [Ex. 1007], 11:6-19.
`
`PETITIONER’S DX-7
`
`
`
`INOHARA’S “ALLOWING”
`
`• PO: “There is no communication sent in Inohara to
`a new server indicating that entrance to the server
`group has been denied.”
`
`PO Response [Paper 23] at 19.
`
`
`• “If master 410 determines that client 404 should not
`be allowed to join community 402, […] dynamic
`cache application 428 may simply ignore join
`request 452 and allow client 404 to determine that it
`has [sic] rejected from community 402 because no
`response to join request 452 has been received.”
`‘145 Patent [Ex. 1001] at 21:22-27; see also id at 25:10-13.
`
`PETITIONER’S DX-8
`
`
`
`INOHARA’S “COMMUNITY”
`
`• “Each server group of Inohara is a community
`because the members of each server group have
`similarity or identity and each server group is
`established for the purpose of ‘sharing,
`participation, and fellowship.’”
`Petitioner’s Reply [Paper 24] at 4.
`
`
`• PO: “A single server group [of Inohara] is not a
`cache community . . .”
`
`PO Response [Paper 23] at 20.
`
`
`
`PETITIONER’S DX-9
`
`
`
`SIMILARITY OR IDENTITY
`
`• “[E]ach member’s ‘group table’ has the same list of
`a leader server ID and group member ID’s.”
`Petitioner’s Reply [Paper 24] at 3.
`
`
`
`Inohara [Ex. 1007] at Fig. 2.
`
`PETITIONER’S DX-10
`
`
`
`SHARING, PARTICIPATION, AND
`FELLOWSHIP
`
`
`
`Inohara [Ex. 1007] at 15:19-21.
`
`PETITIONER’S DX-11
`
`
`
`OPERABILITY OF SMITH IN VIEW OF
`INOHARA
`• PO Argues: “Such a holding would also render
`Inohara inoperative for its central teaching of
`achieving a cache community that is scalable in
`size beyond the constraints of a single server
`group.”
`
`PO Response [Paper 23] at 24.
`
`PETITIONER’S DX-12
`
`
`
`OPERABILITY OF SMITH IN VIEW OF
`INOHARA
`• “It is the community of Smith that is being modified in the
`proposed combination, not the community of Inohara.”
`Petitioner’s Reply [Paper 24] at 12.
`
`• Inohara expressly teaches restricting admission to a server
`group based on a MAX group size.
`
`Inohara [Ex. 1007], 11:6-19.
`
`• Smith’s distributed caching system would have benefited from
`the addition of such software capabilities, and such addition
`was well within the capabilities of one of skill in the art.
`Petitioner’s Reply [Paper 24] at 12 (citing Ex. 1002, Danzig
`Declaration, at ¶ 17).
`
`PETITIONERS DX-13
`
`
`
`‘145 PATENT - CLAIMS 29-34, 36
`’145 PATENT - CLAIMS 29-34, 36
`
`29. A method for dynamic distributed data cachingLcom-
`
`o
`o
`o
`o
`o
`o
`commumcatmg a community request to an administration
`module;
`receiving a community list from the administration mod-
`Ex. 1001 (‘262 Patent) at claim 19
`ule in response to the community request, the commu-
`nity list including a list of communities;
`selecting one of the communities to attempt to join;
`generating a join request to attempt to join the selected
`one of the communities;
`
`‘145 Patent [Ex. 1001] at Claim 29
`‘I45 Patent [Ex. 1001] at Claim 29
`
`(cid:51)(cid:72)(cid:87)(cid:76)(cid:87)(cid:76)(cid:82)(cid:81)(cid:72)(cid:85)(cid:3)(cid:40)(cid:91)(cid:17)(cid:3)(cid:20)(cid:19)(cid:19)(cid:20)(cid:3)(cid:51)(cid:68)(cid:74)(cid:72)(cid:3)(cid:21)(cid:27)
`
`PETITIONERS DX-14
`PETITIONERS DX—l 4
`
`
`
`community or cache community of the ‘145 Patent. As noted above, however, the
`
`groups discussed by Inohara are merely sub-groups of a multi-cast hierarchical
`caching system, and Inohara describes a single community rather than a plurality
`PO RESPONSE
`of communities. See Ex. 2002, ¶¶ 42-44, and discussion of Inohara, supra at 4-12.
`
`Since Inohara describes a way to implement a single cache community using
`
`a hierarchical tree structure, the reference cannot be read to disclose selecting
`
`between multiple cache communities. Inohara simply does not disclose multiple
`
`cache communities to select from. Ex. 2002, ¶¶ 42-44.
`
`PO Response [Paper 23] at 27
`For the foregoing reasons, the transfer of a group table (as asserted on pages
`
`40-41 of the Petition) cannot be interpreted to teach or suggest “receiving a
`
`community list from the administration module in response to the community
`
`request, the community list including a list of communities” or “selecting one of the
`PETITIONERS DX-15
`communities to attempt to join.” Put simply, no list of communities is disclosed by
`
`a table that lists only subsets of a single community and the selection of a
`
`
`
`“SELECTING”
`
`‘145 Patent
`“The latency between two network
`locations may be used to
`determine the network distance
`between the two network
`locations.”
`
`
`‘145 Patent [Ex. 1001] at 19:66-20:2.
`
`
`“For example, dynamic cache
`application 428 may select a
`community 402 which has the
`lowest latency from client 404.”
`
`
`‘145 Patent [Ex. 1001] at 20:33-35.
`
`Inohara
`“In step 412, a group participation
`message 300 is transmitted to the
`most proximate server in a group of
`servers stored in the server status
`table (for example, a server having
`the maximum value as the value of
`division of throughput 222 by
`latency 223).”
`
`
`Inohara [Ex. 1007] at 10:13-17
`
`PETITIONER’S DX-16
`
`
`
`CERTIFICATE OF SERVICE ON PATENT OWNER
`UNDER 37 C.F.R. § 42.105(a)
`
`IPR2014-00136
`U.S. Patent No. 7,188,145
`
`
`
`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies that
`on February 10, 2015, a complete and entire copy of Petitioner’s Demonstrative
`Exhibits were served on Counsel for Patent Owner by filing the document through the
`Patent Review Processing System as well as sending a copy via e-mail to the
`addresses identified below:
`
`Darren Collins
`Robert Hilton
`Aaron Pickell
`McGuire Woods
`2000 McKinney Ave., Suite 1400
`Dallas, TX 75201
`dwcollins@mcguirewoods.com
`rhilton@mcguirewoods.com
`apickell@mcguirewoods.com
`
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`Respectfully submitted,
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`BY:
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`ERISE IP, P.A.
`
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`
`
` /Eric A. Buresh/
`Eric A. Buresh, Reg. No. 50,394
`Mark C. Lang, Reg. No. 55,356
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`P: (913) 777-5600
`F: (913) 777-5601
`eric.buresh@eriseip.com
`mark.lang@eriseip.com
`
`ATTORNEYS FOR PETITIONER
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