PTAB

IPR2014-01425

Unified Patents Inc v. PanTaurus LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Computer Architecture for Secure Data Storage
  • Brief Description: The ’533 patent describes a computer architecture designed to selectively disable the alteration of data on a storage device for security purposes. The system utilizes a dual-bus architecture with two corresponding processors and a switch that can enable or disable specific operating modes, such as writing to the storage device, to maintain data integrity.

3. Grounds for Unpatentability

Ground 1: Obviousness over Holtey II and Holtey I - Claims 29, 31-34, 38, 39, 42, and 43 are obvious over Holtey II in view of Holtey I.

  • Prior Art Relied Upon: Holtey II (Patent 5,491,827) and Holtey I (Patent 5,442,704).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Holtey II discloses the core architecture of the challenged claims, including a dual-bus system, a first processor (host microprocessor) on a first bus, a second processor (application microprocessor) on a second bus, and a shared storage device (flash memory). Holtey II's "access discrimination logic unit" was asserted to be the claimed "switch" that controls access to the storage device in different operating modes (e.g., read, write, execute). To further bolster the teaching of various operating modes, Petitioner relied on Holtey I, which explicitly describes the same flash memory technology as Holtey II and details its operation, including a "write-only" mode. For dependent claims, Petitioner argued that the flash memory described in the references is a form of non-volatile memory (claim 38) and EEPROM (claim 39), and that the processors disclosed inherently include the memory structures required by claim 42.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would have been motivated to combine the teachings of Holtey II and Holtey I for several compelling reasons. Holtey II expressly cross-references Holtey I in its "RELATED APPLICATIONS" section and states its secure card is intended to operate with the host system of Holtey I. Furthermore, both patents share the same inventor, were filed on the same day by the same assignee, and are directed to the identical problem of maintaining data security in a portable digital environment. This overlap indicates the references describe different aspects of the same system.
    • Expectation of Success: A POSITA would have had a high expectation of success in combining the references, as they describe a single, integrated security system. The combination merely involves applying the detailed operational teachings of Holtey I to the broader system architecture disclosed in Holtey II.

Ground 2: Obviousness over Holtey II, Holtey I, and Shafe - Claims 35 and 36 are obvious over Holtey II and Holtey I in view of Shafe.

  • Prior Art Relied Upon: Holtey II (Patent 5,491,827), Holtey I (Patent 5,442,704), and Shafe (Patent 6,035,429).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically addresses claims 35 and 36, which require the data storage device to be a "magnetic media" and a "disk drive," respectively. Petitioner asserted that the combination of Holtey II and Holtey I teaches all elements of the base claims but discloses the use of flash memory. The Shafe patent was introduced to supply the missing element, as it discloses a miniature hard disk drive (magnetic media) embodied in a PCMCIA-compatible card—the same form factor used by the secure application card in Holtey II.
    • Motivation to Combine: Petitioner argued that a POSITA would have been motivated to substitute the flash memory in the Holtey system with the hard disk from Shafe as an obvious design choice. At the time of the invention, hard disks offered significantly greater storage capacity at a lower cost per megabyte than solid-state memory. Shafe explicitly teaches these advantages and addresses the need to replace limited solid-state memory with component disk drives in portable, card-based electronics like PCMCIA cards. The recognized fungibility of these storage types and the shared PCMCIA interface would have made the substitution straightforward to implement for applications requiring larger data storage.
    • Expectation of Success: A POSITA would have reasonably expected success in this combination, as it involved the simple substitution of one known type of memory component (flash memory) with another (a compact hard disk) to achieve the predictable benefit of increased storage capacity.

4. Key Claim Construction Positions

  • Data storage device: Petitioner proposed the construction "any device that retains information." This broad interpretation was supported by the ’533 patent's specification, which provides a wide range of examples including magnetic media, disk drives, non-volatile electronic memory like EEPROM, and optical storage devices.
  • Operating modes: Petitioner proposed the construction "any state of operation of a device." It was argued that while the patent discusses read and write modes, the specification's language suggests the term is broader and not limited to just those two functions, also encompassing concepts like printing capabilities.
  • Switch: Petitioner proposed the construction "a control mechanism." Based on the doctrine of claim differentiation, Petitioner argued that independent claim 29, which uses the term "switch," should be construed more broadly than a dependent claim that specifically recites a "manually operated switch." Thus, the term should encompass both manual and automatic switches, implemented in either hardware or software.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 29, 31-36, 38, 39, 42, and 43 of the ’533 patent as unpatentable under 35 U.S.C. §103.