PTAB

IPR2013-00098

Oracle Corp v. Clouding IP LLC

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1. Case Identification

2. Patent Overview

  • Title: Dynamic Distributed Data System and Method
  • Brief Description: The ’014 patent describes a system and method for maintaining cache coherence for a storage object across a distributed network of connected nodes. The technology relies on each node maintaining a routing table that stores a path to a central coherency hub, termed the Repository of Last Resort (RLR), which holds the last or only copy of a data replica and manages data access through "publish" and "subscribe" processes.

3. Grounds for Unpatentability

Ground 1: Anticipation over Borrill - Claims 1, 3-4, 8-10, 18, and 24-26 are anticipated by the 1994 Borrill Article under 35 U.S.C. §102.

  • Prior Art Relied Upon: 1994 Borrill Article (“Borrill”), an article co-authored by the inventor of the ’014 patent six years before the patent's earliest priority date.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Borrill discloses every limitation of the challenged independent claims. Borrill describes a "Unified Solution" for cache coherency in a system of interconnected nodes (termed "clusters"). Each cluster maintains a routing table (the "RLR Routing Table") that stores the forward routing path to a "repository of last resort" (RLR) for a given data object ("active memory block"). Borrill’s system uses a "Publish" process where the RLR announces the availability of a resource to its neighbor nodes, which in turn create entries in their routing tables pointing toward the RLR, directly corresponding to the method claimed in the ’014 patent.

Ground 2: Obviousness over Borrill in view of Herlihy - Claims 6 and 22 are obvious over Borrill in view of Herlihy under 35 U.S.C. §103.

  • Prior Art Relied Upon: Borrill (the 1994 Borrill Article) and Herlihy (a 1998 paper titled "The Arrow Distributed Directory Protocol").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Borrill teaches all elements of the base claims, but describes the storage object as a "data block." Claims 6 and 22 further require the storage object to be a "file." Herlihy was cited for its explicit teaching that mobile objects in distributed directory systems, like the one it describes, could be a "file, a process, or any other data structure."
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these teachings to improve the versatility of the Borrill system. Since files are a common data structure in distributed systems, a POSITA would have been motivated to apply Borrill's efficient cache coherency scheme to files as taught by Herlihy to manage a wider and more practical range of data types.
    • Expectation of Success: The combination was presented as predictable, as it involved applying a known cache management technique to a common and explicitly suggested type of data object (a file) for which the technique was well-suited.

Ground 3: Obviousness over Herlihy in view of Raymond - Claims 1, 3-4, 6, 9, 18, 22, and 25 are obvious over Herlihy in view of Raymond under §103.

  • Prior Art Relied Upon: Herlihy (the 1998 protocol paper) and Raymond (a 1989 paper titled "A Tree-Based Algorithm for Distributed Mutual Exclusion").
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented an alternative invalidity theory. Petitioner argued that Herlihy discloses a distributed cache coherency system using a directory tree, where nodes maintain links pointing in the direction of a mobile object. However, Herlihy's mechanism for establishing the directory tree is general. Raymond was introduced for its specific, tree-based algorithm where a privileged node holding a resource sends an "Initialize" message to its neighbors, which then set a "HOLDER" variable to point toward the source, thereby creating the directional routing paths.
    • Motivation to Combine: A POSITA would combine Raymond's specific algorithm with Herlihy's general protocol to create a concrete and efficient implementation. Raymond’s algorithm provided a well-understood method for initializing the directory tree structure required by Herlihy's protocol, making it a natural choice for implementation.
    • Expectation of Success: A POSITA would have reasonably expected success in using Raymond's established algorithm to implement the initialization phase of Herlihy’s directory system, as both references operate in the same technical field of distributed systems and address the common problem of locating resources.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining the 1994 Borrill Article with Hennessy (a 1996 computer architecture textbook) to teach using a TCP/IP network for the claimed messaging, and various three-reference combinations of Borrill, Herlihy, Raymond, and Hennessy to address other claim limitations.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1, 3-4, 6, 8-11, 18, 22, and 24-27 of Patent 6,918,014 as unpatentable.