PTAB

IPR2014-01178

Seagate Technology US Holdings Inc v. Enova Technology Corp

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1. Case Identification

2. Patent Overview

  • Title: Cryptographic Serial ATA Apparatus and Method
  • Brief Description: The ’057 patent describes a cryptographic apparatus and method for use with the Serial ATA (SATA) communication protocol. The invention leverages the inherent structure of the SATA standard to selectively encrypt and decrypt user data payloads while allowing control and status information to pass through unaltered, thereby maintaining protocol integrity during high-speed cryptographic processing.

3. Grounds for Unpatentability

Ground 1: Obviousness over Sullivan and the SATA Standard - Claims 1-32 are obvious over Sullivan in view of the SATA Standard.

  • Prior Art Relied Upon: Sullivan (Application # 2004/0054914) and the SATA Standard (Serial ATA: High Speed Serialized AT Attachment, Revision 1.0a).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that the challenged claims represent a predictable implementation of a general encryption concept using a well-defined, public communication protocol. Sullivan taught a cryptographic apparatus for serial channels, explicitly including SATA, that encrypts user data while leaving control information (e.g., commands, status) unaltered. It disclosed an "encryption unit" that separates a packet's data payload from its control header to perform this selective encryption. While Sullivan provided the general framework, the SATA Standard provided the specific, detailed blueprint for implementing it. The SATA Standard defined different types of Frame Information Structures (FISes), such as "Data FISes" for user data and "non-Data FISes" for control information, distinguishing them with a specific "FIS Type" field in the header.

    • Petitioner argued this combination rendered independent claim 1 obvious. Claim 1 requires a controller to cause a SATA protocol stack to send a Data FIS payload to a cryptographic engine based on a "pre-defined category of command set." Sullivan taught filtering data for encryption based on command types (e.g., read, write), and the SATA Standard provided the exact command sets and the corresponding Data FIS structure. Therefore, a POSITA would find it obvious to use the SATA Standard’s command definitions to trigger the encryption/decryption of Data FIS payloads within Sullivan’s apparatus. Similarly, claim 1’s limitation of processing a "Register-Device to Host FIS" (a non-Data FIS containing status information) without decryption was directly taught by Sullivan's core principle of leaving control and status information "substantially unaltered."

    • For the dependent claims, Petitioner argued they added only conventional features explicitly taught by the SATA Standard. For example, claims 2 and 3, which add the Physical, Link, Transport, and Application layers, merely recited the standard communication layers defined in the SATA Standard. Claims 14-17 and 20-27, which add a "FIS type detector," were obvious because the SATA Standard explicitly taught using the "FIS Type" field (the first byte of a FIS header) to differentiate between FIS types, a fundamental and necessary function for any device implementing the protocol.

    • Motivation to Combine: The motivation to combine was explicit and compelling. Sullivan itself stated that its cryptographic apparatus could be implemented using the SATA protocol. Petitioner argued that a person of ordinary skill in the art (POSITA) tasked with creating a SATA-compliant version of Sullivan's device would have been directly motivated to consult the publicly available SATA Standard. This standard was the definitive guide for implementing any device on a SATA interface, making its use not just a matter of choice but a practical necessity. The combination was presented as the application of a specific industry standard to a general system expressly designed for it.

    • Expectation of Success: Petitioner contended that a POSITA would have had a very high expectation of success. The combination involved implementing a general encryption methodology (from Sullivan) using the precise, rule-based framework of an established industry protocol (the SATA Standard). The standard provided all the necessary details, such as FIS structures, command codes, and communication layer functions, ensuring that the integration would be straightforward and yield the predictable result of selective data encryption. The outcome was not an unexpected discovery but the logical product of combining known elements according to their established functions.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-32 of Patent 7,900,057 as unpatentable under 35 U.S.C. §103.