PTAB

IPR2013-00089

Oracle v. Clouding IP LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Dynamic Distributed Data System and Method
  • Brief Description: The ’449 patent relates to systems and methods for maintaining cache coherence across a distributed storage network. It discloses using routing tables at each network node to direct data requests to an owner node or a designated "Repository of Last Resort" (RLR) to ensure data consistency and persistence.

3. Grounds for Unpatentability

Ground 1: Claims 1-2 and 5 are obvious over the 1994 Borrill Article in view of Soundararajan.

  • Prior Art Relied Upon: 1994 Borrill Article (an IEEE conference paper co-authored by the patent's inventor), Soundararajan (a 1999 technical report).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the 1994 Borrill Article teaches a distributed system with a "Repository of Last Resort" (RLR) to maintain data consistency, satisfying the preamble of independent claims 1 and 5. Soundararajan teaches a protocol for improving data locality by migrating a "home" node (which Petitioner asserted is analogous to Borrill's RLR) based on monitoring access frequency. The challenged claims require monitoring requests to the RLR and deciding whether to migrate it, which Petitioner contended is taught by the combination.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the references to improve the efficiency of Borrill's system. Because Borrill's RLR is described as an "ultimate owner" and the system already migrates ownership for efficiency, a POSITA would be motivated to apply Soundararajan's dynamic RLR migration strategy to Borrill's protocol as a natural and predictable improvement.
    • Expectation of Success: Petitioner asserted it was entirely expected that applying Soundararajan's established migration monitoring and decision concepts to Borrill's cache coherency system would be successful.

Ground 2: Claims 6-7, 16, 27, 29, and 34 are anticipated by the 1994 Borrill Article.

  • Prior Art Relied Upon: 1994 Borrill Article.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the 1994 Borrill Article, published six years before the patent's priority date and co-authored by the inventor, discloses every limitation of these claims. The article's "Unified Solution" for cache coherence is a system for maintaining storage object consistency among nodes, as claimed. Its disclosure of routing tables, Multicast Controllers (processors), and an "Extended MOESI Cache Structure" with state bits (e.g., shared, owned) and pointers to the RLR was argued to directly read on all elements of the challenged system and method claims.

Ground 3: Claim 28 is obvious over the 1994 Borrill Article in view of Raymond.

  • Prior Art Relied Upon: 1994 Borrill Article, Raymond (a 1989 article on distributed mutual exclusion).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that claim 28, which recites a method for adding a new node to the network, is rendered obvious by the combination. The 1994 Borrill Article expressly states its system must provide "the ability for resources to be added and removed from the network while the system is live." Raymond teaches a specific, well-known algorithm for initializing dynamically added nodes in a spanning tree network by having the new node link to an existing neighbor and configure its routing information.
    • Motivation to Combine: A POSITA implementing Borrill's system, which explicitly requires the capability to add nodes, would be motivated to look to known and standard algorithms like that taught by Raymond to handle the initialization and integration of new nodes into the existing network.
    • Expectation of Success: Petitioner contended that a skilled artisan would have had a high expectation of success in applying Raymond's established method for adding nodes to the network described in the 1994 Borrill Article.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 1-2 and 5 are obvious over the 1994 Borrill Article in view of Baylor (Patent 5,893,922), and that claims 6-7, 16, 27-29, and 34 are obvious over Herlihy (a 1998 conference paper) in view of the 1994 Borrill Article.

4. Key Claim Construction Positions

  • Repository of Last Resort (RLR): Petitioner proposed this term be construed as "a storage mechanism which holds the last remaining copy of a data file which may not be deleted." This construction, focused on ensuring data persistence, was important for mapping the term to prior art that taught analogous "home node" or "ultimate owner" concepts that served a similar purpose.
  • Address Tag and Name Tag: Petitioner argued these terms, used in different parts of the patent, are functionally synonymous. Both were contended to serve as a label to identify a data block or its corresponding entry in a routing table. This interpretation allowed Petitioner to map prior art references that used a single type of identifier onto both claimed terms.

5. Relief Requested

  • Petitioner requests institution of inter partes review (IPR) and cancellation of claims 1-2, 5-7, 16, 27-29, and 34 of the ’449 patent as unpatentable.