PTAB

IPR2014-00683

Seagate Technology US Holdings Inc v. Enova Technology Corp

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Cryptographic Device
  • Brief Description: The ’995 patent discloses a hardware-based cryptographic device positioned between a data generating device (e.g., a computer) and a data storage device (e.g., a hard drive). The device intercepts a data stream and, based on command signals, transparently encrypts, decrypts, or passes through the data without using the resources of the host computer or storage device.

3. Grounds for Unpatentability

Ground 1: Obviousness over Nolan and SCSI-2 Specification - Claims 1-13 are obvious over Nolan in view of the SCSI-2 Specification.

  • Prior Art Relied Upon: Nolan (GB Patent App. No. 2,264,373) and the SCSI-2 Specification (American National Standards Institute, 1994).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Nolan disclosed a cryptographic apparatus for encrypting computer data before storage that contained all elements of the challenged claims. Specifically, Nolan's SCSI Interface 15 was identified as the claimed "data stream interceptor" and "data generating controller." Nolan’s Microprocessor 17 met the "main controller" limitation by receiving commands and determining whether to encrypt data. Nolan's second SCSI Interface 16 functioned as the "data storage controller," and its Encryption Block 20 was the claimed "cipher engine." Dependent claims adding input/output buffers were allegedly met by Nolan’s memory buffers 18 and 19, which operate on either side of the encryption block.
    • Motivation to Combine: Petitioner asserted that Nolan explicitly taught its device was designed to transfer data using the Small Computer System Interface (SCSI) protocol and specifically mentioned compatibility with SCSI-1 and SCSI-2 commands. A person of ordinary skill in the art (POSITA), upon reading Nolan's disclosure, would have been directly motivated to consult the prevailing and widely used ANSI standard SCSI-2 Specification for implementation details, such as how to distinguish between command and data signals on the bus.
    • Expectation of Success: A POSITA would have had a high expectation of success because implementing Nolan's known cryptographic architecture using the well-defined, standardized protocols of the SCSI-2 Specification was a predictable integration of known technologies for their intended purposes.

Ground 2: Obviousness over Nolan/SCSI-2 with or without Hamlin - Claim 14 is obvious over Nolan and the SCSI-2 Specification, optionally in view of Hamlin.

  • Prior Art Relied Upon: Nolan, the SCSI-2 Specification, and Hamlin (Patent 6,735,693).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed the preamble limitation of claim 14, which required the cryptographic device to be "integrated within a data storage device." Petitioner first argued this was an obvious design choice over the base combination of Nolan and SCSI-2. Nolan itself suggested its invention could be used to protect a SCSI bus, and integrating the device within the storage drive's housing was a predictable way to enhance physical security by limiting access to the connecting bus.
    • Motivation to Combine: Alternatively, Petitioner argued that Hamlin provided an explicit motivation. Hamlin addressed the need for a tamper-resistant cryptosystem in a disk drive and explicitly taught housing encryption circuitry within the data storage device to enhance security against physical attacks. A POSITA seeking to improve the security of Nolan's external device would combine its functionality with Hamlin's teaching of physical integration to achieve the predictable benefit of enhanced security.
    • Expectation of Success: The combination was argued to be a predictable variation, as housing an electronic component (Nolan’s device) within the chassis of a related component (a storage drive) to improve security was a common design practice.

Ground 3: Obviousness over Nolan/SCSI-2 with or without Detrick - Claim 15 is obvious over Nolan and the SCSI-2 Specification, optionally in view of Detrick.

  • Prior Art Relied Upon: Nolan, the SCSI-2 Specification, and Detrick (Patent 7,278,016).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targeted the preamble of claim 15, which required the device to be "integrated within a data generating device." Similar to Ground 2, Petitioner asserted this would have been an obvious modification to Nolan's device to enhance physical security by protecting one end of the SCSI bus within the computer's housing.
    • Motivation to Combine: As an alternative, Detrick was introduced as providing a clear motivation for this integration. Detrick disclosed an encryption system where the hardware was embedded within the computer's drive controller to ensure that data encrypted by the computer could not be decrypted without access to that same computer. A POSITA looking to secure the data pathway in Nolan's system would have been motivated to adopt Detrick's approach of integrating the encryption hardware into the data generating device (the computer) for improved security.
    • Expectation of Success: A POSITA would have expected success in integrating Nolan's cryptographic functions into a host computer, as taught by Detrick, because it involved applying a known security technique (physical integration) to a known system to achieve a predictable result (enhanced security).

4. Key Claim Construction Positions

  • "data stream interceptor that distinguishes between command/control and data signal transfers": Petitioner proposed this term be construed as "one or more components adapted to intercept at least one data stream and distinguish the command or control signals in the data stream from the data signals." This construction was central to the primary ground, as Petitioner argued that the SCSI-2 Specification explicitly taught how a SCSI interface distinguishes between command/control signals and data signals based on the voltage on a dedicated "Control/Data" wire in the bus, directly mapping onto this key claim limitation.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-15 of Patent 7,136,995 as unpatentable.