Oracle Corp v. Clouding IP LLC

1. Case Identification

• Case #: IPR2013-00271
• Patent #: 5,495,607
• Filed: May 6, 2013
• Petitioner(s): Oracle Corporation
• Patent Owner(s): Clouding IP, LLC
• Challenged Claims: 15

2. Patent Overview

• Title: Centralized file management system and method for managing files stored in plural data storage devices of a network domain
• Brief Description: The ’607 patent describes a centralized file management system for a network domain. The system manages files stored across multiple distributed storage devices by using a central server to periodically scan local catalogs on each device and create a compiled virtual catalog for network-wide administration.

3. Grounds for Unpatentability

Ground 1: Obviousness over Reference Model, Floyd, and ESA - Claim 15 is obvious over Reference Model in view of Floyd and ESA.

• Prior Art Relied Upon: Reference Model (a 1990 IEEE publication on mass storage systems), Floyd (a 1989 technical report on distributed file systems), and ESA (a 1991 publication on system administration).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of these references taught all limitations of claim 15. Reference Model allegedly disclosed a centralized management system (its "bitfile server") with multiple storage servers interconnected by a communication backbone. Petitioner asserted that Reference Model's "map" maintained by its volume manager constituted the claimed "local catalog" on each storage device. Alternatively, if Reference Model was found not to teach local catalogs, Petitioner argued a POSITA would incorporate the explicit teaching of local "property lists" stored with each file from Floyd. For the "scan means," Petitioner mapped this to Reference Model's bitfile Descriptor Manager and Request Processor, which retrieve file descriptors. The "periodically" scanning function was supplied by ESA, which taught using the standard cron script to run automated tasks at scheduled intervals.
  • Motivation to Combine: Petitioner contended a POSITA would be motivated to combine Floyd's explicit local catalog system with Reference Model's architecture to enhance its management capabilities, a predictable improvement. A core goal of Reference Model was its applicability to known hardware and software, providing a reason to integrate known techniques. Adding the cron utility from ESA was argued to be a simple application of a well-known tool to automate the scanning process taught by the primary references.
  • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success because the combination involved applying conventional file system concepts (Floyd) and standard automation tools (ESA) to a known distributed storage architecture (Reference Model) to achieve the predictable result of centralized, automated file management.

Ground 2: Obviousness over Ward, Reference Model, Floyd, and ESA - Claim 15 is obvious over Ward in view of Reference Model, Floyd, and ESA.

• Prior Art Relied Upon: Ward (Patent 5,367,670), Reference Model (a 1990 IEEE publication), Floyd (a 1989 technical report), and ESA (a 1991 publication).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner used Ward as the base system, which taught a centralized network management system with file servers connected via a LAN or WAN backbone. Petitioner argued that while Ward did not explicitly disclose "local catalogs," its use of industry-standard file servers would lead a POSITA to incorporate the local catalog structures taught by Reference Model and Floyd. Similarly, Petitioner mapped the "scan means" to Ward's "system manager," arguing a POSITA would augment it with the descriptor retrieval functions of Reference Model's Descriptor Manager or the polling/scanning capabilities of Floyd. As in the first ground, ESA was cited to provide the periodic nature of the scanning via the cron script.
  • Motivation to Combine: The primary motivation asserted was to satisfy the "increased demand for greater management capabilities" explicitly mentioned as a driving force in Ward. Petitioner argued that augmenting Ward's network management system with the more detailed storage and cataloging features from Reference Model and Floyd was a logical step to improve its functionality. Reference Model itself stated its modules were designed for integration into various systems, providing an express motivation for the combination.
  • Expectation of Success: Petitioner argued that success would be expected because the combination involved augmenting a known network management system (Ward) with known, modular components for data storage and cataloging (Reference Model, Floyd) to achieve the predictable goal of enhanced, centralized file management.

4. Key Claim Construction Positions

Petitioner proposed the following constructions under the broadest reasonable interpretation standard:

• local catalog: Should be interpreted as a listing of a storage device's contents that includes at least the name and location of the files stored on it.
• domain-linking backbone: Should be interpreted broadly to include any conventional network, such as a LAN, WAN, or token ring network, directly contradicting the Patent Owner's narrower arguments during prosecution.
• scan means: Should be treated as a means-plus-function limitation. The function is "periodically scanning the network domain and interrogating the local catalog of each data storage device," and the corresponding structure disclosed in the specification is the "domain-wide status monitor/control program 150.2" and its equivalents.
• coupled: Should be interpreted as "in operative connection with," rather than requiring a direct physical connection, as the "scan means" is software.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claim 15 of Patent 5,495,607 as unpatentable.