PTAB

IPR2013-00090

Oracle v. Clouding IP LLC

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1. Case Identification

2. Patent Overview

  • Title: Network Management System Having Virtual Catalog Overview of Files Distributively Stored Across Network Domain
  • Brief Description: The ’607 patent describes a network management system featuring a central "domain administrating server" (DAS). The DAS creates and maintains a "domain-wide virtual catalog" by compiling information from local catalogs of multiple, distributed file servers. The patent also discloses monitoring the infrastructure of these file servers and reporting system alerts.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1 and 18-20 over Reference Model in view of Floyd

  • Prior Art Relied Upon: Reference Model (IEEE Mass Storage System Reference Model: Version 4, 1990) and Floyd (a 1989 University of Rochester Technical Report).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Reference Model disclosed the core architecture of the claimed network system, including a central "bitfile server" (the DAS) that manages multiple "storage servers" (the file servers) connected via a network backbone. The bitfile server maintained a central "descriptor table" (the virtual catalog) with information about files stored on the storage servers. While Reference Model did not explicitly teach storing local catalogs within each storage device, Petitioner contended Floyd remedied this by teaching a system where a Local File Server stores a property list (a local catalog) with each file.
    • Motivation to Combine: A POSITA would combine Floyd's local catalog approach with Reference Model's distributed architecture to improve the system's management and monitoring capabilities. Reference Model was intended to be broadly applicable to conventional hardware, making the integration of Floyd's known file property storage method a predictable improvement.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining these references, as it involved applying a known data organization technique (Floyd) to a standard distributed storage model (Reference Model) to achieve the predictable benefit of enhanced file management.

Ground 2: Anticipation of Claims 9-12 by Farrand

  • Prior Art Relied Upon: Farrand (Patent 5,559,958).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Farrand disclosed every element of claims 9-12. Farrand taught a network management system with a manager console (the DAS) connected to a plurality of networked file servers over a network backbone. Each file server included local infrastructure (e.g., power supply, temperature sensors) and a "server manager board" that served as a monitoring and reporting agent. This agent monitored the local infrastructure and issued alert reports via SNMP onto the backbone, which were then detected and collected by the manager console. Farrand also disclosed means for detecting, flagging, and forwarding immediate-response alerts to a human administrator, thus meeting the limitations of dependent claims 10-12.

Ground 3: Obviousness of Claims 1, 9-12, and 18-20 over Ward, Farrand, Reference Model, and Floyd

  • Prior Art Relied Upon: Ward (Patent 5,367,670), Farrand (Patent 5,559,958), Reference Model, and Floyd.

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground combined the teachings of all references to argue that the entire challenged claim set was obvious. Petitioner argued that Ward provided a base network management system with a local network manager console (DAS) and file servers with local monitoring agents that issue alerts. This base system could be augmented with the specific teachings of the other references. Farrand taught using the Internet as the network backbone for wider accessibility. Reference Model, as modified by Floyd, taught the addition of a system-wide virtual catalog managed by the DAS for centralized file overview and management, including file migration.
    • Motivation to Combine: A POSITA would be motivated to combine these known elements to create a more robust and functional network management system. The motivation to use an internet-based network (from Farrand) was to achieve world-wide accessibility. The motivation to add a virtual catalog and migration manager (from Reference Model/Floyd) to Ward's monitoring system was to increase management capacity and add file-level administrative functions to an existing infrastructure-level monitoring system.
    • Expectation of Success: Combining these modular, well-understood technologies would have been predictable. Each reference addressed a distinct aspect of network management (monitoring, file cataloging, network architecture), and their integration would have resulted in the predictable sum of their respective functions.

  • Additional Grounds: Petitioner asserted a separate obviousness challenge against claims 9-12 over Ward alone, relying on similar arguments regarding Ward's disclosure of a network manager console monitoring file server alerts.

4. Key Claim Construction Positions

  • "Domain Administrating Server (DAS)": Petitioner argued this term should be given its plain and ordinary meaning of a server that administers a domain. Petitioner contended that Patent Owner, during prosecution, attempted to narrowly define the term to require a "domain-wide virtual catalog" and "oversight means," but that the specification did not provide a clear and unmistakable lexicographical definition to support such a narrow construction.
  • "Oversight Means": For this means-plus-function term in claim 1, Petitioner argued that the specification failed to disclose a specific algorithm for the recited functions ("overseeing and managing" and "consulting"), rendering the claim indefinite under §112. For the purpose of the IPR, however, Petitioner identified the corresponding structure as the "task scheduler" and "domain-wide status-monitor and control program" disclosed in the specification.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1, 9-12, and 18-20 of the ’607 patent as unpatentable.