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 discloses a network management system featuring a “domain administrating server” (DAS). This DAS creates and maintains a “domain wide-virtual catalog” by compiling file-identifying information from local catalogs stored on multiple, distributed file-servers across a network domain, and also performs monitoring functions for the network.

3. Grounds for Unpatentability

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

  • Prior Art Relied Upon: Mass Storage System Reference Model: Version 4 (“Reference Model”) (published in 1990) and Transparency in Distributed File Systems by Floyd (“Floyd”) (published in 1989).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Reference Model discloses a distributed storage system with all the core architectural elements of claim 1, including multiple file servers (storage servers), a network backbone (communication service), and a central server (bitfile server) that functions as the claimed DAS. The bitfile server's "descriptor table" was asserted to be the claimed "domain-wide virtual catalog." However, Reference Model did not explicitly disclose storing the local catalog on each respective data storage device. Petitioner asserted that Floyd remedies this by teaching a Local File Server that stores a property list (a local catalog) with each file it manages on its host.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would have been motivated to incorporate Floyd’s approach for storing local catalog information into the Reference Model system. This combination would be a predictable and advantageous modification to improve the management and monitoring capabilities of the overall network system, which was a stated goal of the Reference Model.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination because Reference Model was explicitly designed as a flexible, broadly applicable model for conventional hardware and software, and Floyd addressed a well-known problem in distributed file systems.

Ground 2: Anticipation by Farrand - Claims 9-12 are anticipated by Farrand.

  • Prior Art Relied Upon: Farrand (Patent 5,559,958).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Farrand discloses every element of claims 9-12. Farrand describes a management system for networked file servers connected via a backbone (e.g., LAN, WAN, Internet). Each file server has its own infrastructure, including a "server manager board" that acts as a local monitoring and reporting agent. A central "manager console" functions as the claimed DAS, administering the devices on the network. The system uses SNMP for monitoring communications and detecting/collecting alert reports, which corresponds to the claimed "backbone monitoring means." Farrand also explicitly describes monitoring power and temperature, anticipating the "power supply means" and "local temperature control means" of dependent claims 11 and 12.

Ground 3: Obviousness in View of Ward - Claims 9-12 are obvious over Ward.

  • Prior Art Relied Upon: Ward (Patent 5,367,670).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Ward teaches a computer network system with multiple file servers, a "local network manager console" that functions as the DAS, and a "system manager" on each file server that acts as the local monitoring and reporting agent. Ward’s system manager monitors infrastructure (e.g., power, temperature via a sensor) and generates alerts transmitted over the network backbone. The network management agent on the console collects these alerts, mapping directly to the limitations of claims 9-12.
    • Motivation to Combine: Although presented as an obviousness challenge, the argument functions like an anticipation ground, asserting that Ward discloses all claimed elements. The motivation for a POSITA was inherent in Ward's own disclosure, which aimed to provide a comprehensive system for real-time monitoring and alert management in a distributed network.

  • Additional Grounds: Petitioner asserted that claims 1, 9-12, and 18-20 are also rendered obvious by Ward in combination with Farrand, Reference Model, and Floyd. This combination augmented Ward’s monitoring system with the internet-based implementation of Farrand and the system-wide virtual catalog architecture taught by combining Reference Model and Floyd.

4. Key Claim Construction Positions

  • "domain administrating server (DAS)": Petitioner argued this term should be given its plain and ordinary meaning, corresponding to a server that administers a domain. This construction is broad enough to read on structures like Reference Model’s "bitfile server" and Ward's "local network manager console." Petitioner contended that the Patent Owner's attempt during prosecution to define the DAS more narrowly as requiring a "domain-wide virtual catalog" and "oversight means" was improper lexicography.
  • "network-linking backbone": Petitioner asserted that under the Broadest Reasonable Interpretation (BRI), this term should include any conventional LAN, WAN, or token area network, based on explicit language in the ’607 patent’s specification. This construction allows prior art networks to satisfy the limitation.
  • Means-Plus-Function Terms (e.g., "oversight means," "backbone monitoring means"): For several means-plus-function terms, Petitioner identified the corresponding structure in the specification as generic programs (e.g., "task scheduler") or protocols (e.g., SNMP protocol). Petitioner argued these terms are indefinite under §112 for failing to disclose sufficient structure (i.e., a specific algorithm), but proceeded with its unpatentability analysis by mapping the prior art's corresponding systems (like SNMP in Farrand and Ward) to the claimed functions.

5. Relief Requested

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