Bell Communications Research, Inc. v. Vitalink Communications Corporation

55 F.3d 615, 34 U.S.P.Q. 2d (BNA) 1816, 1995 U.S. App. LEXIS 12214, 1995 WL 313759
CourtCourt of Appeals for the Federal Circuit
DecidedMay 23, 1995
Docket94-1516
StatusPublished
Cited by303 cases

This text of 55 F.3d 615 (Bell Communications Research, Inc. v. Vitalink Communications Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals for the Federal Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bell Communications Research, Inc. v. Vitalink Communications Corporation, 55 F.3d 615, 34 U.S.P.Q. 2d (BNA) 1816, 1995 U.S. App. LEXIS 12214, 1995 WL 313759 (Fed. Cir. 1995).

Opinion

MICHEL, Circuit Judge.

Bell Communications Research, Inc. (“Bellcore”) appeals from the August 16, 1994 decision of the United States District Court for the District of New Jersey, No. 92-4104, granting summary judgment in favor of Vitalink Communications Corporation (“Vi-talink”) on the latter’s counterclaim for a declaration of noninfringement and dismissing Bellcore’s infringement suit against Vita-link. Because the trial court partially misconstrued the scope of the asserted claim of U.S. Patent No. 4,706,080 (’080), and consequently erred in granting summary judgment of noninfringement, we vacate and remand.

BACKGROUND

A. The Technology

Local Area Networks (“LANs”) consist of a number of devices, such as computers or telephones, attached to a shared communications medium. The communications medium permits the devices to transmit bundles of data, or “packets,” back and forth to one another. Such packets, which contain fields of information that function as source device and destination device addresses, are broadcast through the communications medium; only the device that recognizes its own address as the destination address receives the broadcast.

The quality of a LAN’s performance degrades in proportion to both the number of devices in the network and the speed at which each device processes information. One can, however, recover some of this lost performance by creating networks of multiple LANs rather than simply adding devices to a single, larger LAN. These multiple LANs are connected by means of “bridges,” each of which are themselves composed of two paired “gateways.” The gateways, each of which have memory capacity, maintain running lists of the source addresses of the packets they have forwarded, allowing the bridges they form gradually to “learn” how to broadcast packets selectively in order to reduce the network’s overall load.

The existence of multiple pathways between a given pair of devices in two different LANs creates the potential for loops and thus thwarts the learning function of memory-capable gateways — a packet that cycles through a complete loop causes its source address to appear on both sides of the relevant gateway pairs, eliminating the advantage of equipping gateways to keep lists of source addresses from the packets they have broadcast. For purposes of describing and solving this looping problem, one can depict a *617 group of interconnected networks as a graph, with lines and vertices used to represent connecting bridges and connected LANs, respectively. In this graphical notation, a “tree” is a graph in which a sequence of one or more lines connects two vertices, while a “spanning tree” is a graph in which all the vertices are connected. Such a spanning tree can be superimposed on the complete graph of the bridged networks and used to determine a set of loop-free spanning tree paths among the vertices. This process of determination can be accomplished either by some oversight mechanism or automatically by the bridges.

While the use of one spanning tree deals with multiple path and looping problems, two problems remain: spanning tree backup paths remain inactive unless bridge failures require that they be used, and the spanning tree’s root may become a performance bottleneck for the system. The use of multiple spanning trees thus represents an improvement over the use of only one spanning tree. But one cannot implement a system for the use of multiple spanning trees without some means of differentiating among the spanning trees, such that a packet is always forwarded over some tree. A system can achieve the required differentiation in one of a number of ways: for example, the system could randomly assign different device addresses to different trees, or, alternatively, the source device could specify a tree by means of a tree identifier when it originates the packet.

B. The Patent in Suit

Bellcore’s ’080 patent, entitled “Interconnection of Broadcast Networks,” discloses a method for interconnecting networks, such as LANs, that uses multiple concurrent spanning trees for packet delivery while preserving loop-free paths. According to the summary of the invention contained in the specification,

[e]ach spanning tree is uniquely identified. Each message packet that traverses the overall system is assigned to a specific spanning tree so the packet travels between nodes [ie., device networks] along edges [ie., bridges] contained in the specified spanning tree. Each gateway, with an expanded store-and-forward protocol [in its memory], parses the packet to determine the assigned spanning tree and forwards the message accordingly. In one embodiment of the present invention, the device originating the packet specifies the spanning tree identifier and conveys it either explicitly or implicitly in the packet.

Col. 2, 11. 14-25. As the. more detailed description explains,

To implement the improvement in the gateway protocol arrangement in accordance with one aspect of the present invention, a set of spanning trees is selected for the cyclic graph according to predetermined guidelines. Each spanning tree is assigned a unique identifier or number and each message traversing the system is assigned to a unique spanning tree via its identifier. Any gateway receiving- this message determines the tree number and then routes the message over the specified spanning tree and drops all packets of other spanning trees. Typically, the device originating the message specifies the spanning tree number, either explicitly or implicitly. For instance, with the explicit approach, a “tree number” field could be added to the packet specifications, say as an extra bit in the header of the packet. With the implicit approach, a spanning tree number could be generated from fields normally occurring in the packet such as the source and destination addresses. An appropriate example function might be
spanning tree number = (source ‘exclusive or’ destination) modulo N,
where N is the number of spanning trees in the network. This has -the benefit that all traffic between a pair of hosts will travel on only one spanning tree, thus minimizing the occupied drop lists across the system.

Col. 5,11. 11-35. Bellcore’s method also preserves the “transparency” of the interconnections among the LANs, according to which the existence of gateways does not require modifications to the networked devices or the packets they broadcast. Col. 1, 11. 29-35.

*618 Claim 6 of the ’080 patent, the only claim asserted by Bellcore, reads as follows:

6. A method for transmitting a packet over a system comprising a plurality of networks interconnected by gateways, said packet originated by a source device connected to one of said networks and destined for a destination device connected to one of said networks, said packet including a source address and a destination address, and said method comprising the steps of
defining an undirected graph representative of the system wherein said networks comprise graph nodes and said gateway[s] comprise graph paths,

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55 F.3d 615, 34 U.S.P.Q. 2d (BNA) 1816, 1995 U.S. App. LEXIS 12214, 1995 WL 313759, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bell-communications-research-inc-v-vitalink-communications-corporation-cafc-1995.