PTAB

IPR2014-01538

Centrify Corp v. Dell Software Inc

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Managing Policies on a Computer
  • Brief Description: The ’744 patent discloses systems for managing computer policies in a heterogeneous network containing different operating systems (e.g., Windows and Unix). The technology centralizes policy management on a computer with a "native" operating system and extends those policies to computers with "foreign" operating systems by translating the policies into a usable format.

3. Grounds for Unpatentability

Ground 1: Claims 1-3 are obvious over Lortz in view of Dennis and Prabakaran.

  • Prior Art Relied Upon: Lortz (Patent 7,428,583), Dennis (Application # 2003/0023587), and Prabakaran (Application # 2003/0009487).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lortz taught the core system of claim 1: a central policy server that maintains a single policy version and transmits it to client computers with different operating systems. These clients, if unable to use the policy in its native format, use a local policy translator to convert it into a required format. The translation can result in a plain text file, such as the XML format disclosed by Lortz. Dennis was asserted to supply the context of the well-known and extensible Windows Group Policy framework, which an artisan would naturally use to implement Lortz’s system. Prabakaran was cited to teach the specific environment of a heterogeneous network containing both Windows and non-Windows (Unix, Linux) computers, confirming the utility of the proposed combination. Dependent claims 2 and 3, relating to application configuration and group management, were argued to be taught by Dennis’s disclosure of applying policies for IP security and other applications, and Lortz’s inherent function of managing a group of computers.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine these references because they address the same technical problem of policy management in diverse network environments. A POSITA seeking to implement Lortz’s general policy distribution architecture would have been motivated to use the specific, commercially prevalent, and extensible Windows Group Policy framework taught by Dennis. Applying this combined system in the mixed Windows/Unix network described by Prabakaran was presented as a natural and predictable application of the technology.
    • Expectation of Success: The combination was asserted to be a simple arrangement of known elements, each performing its known function, leading to a predictable result with a high expectation of success.

Ground 2: Claims 1-3 are obvious over Dennis in view of Lortz and Brown.

  • Prior Art Relied Upon: Dennis (Application # 2003/0023587), Lortz (Patent 7,428,583), and Brown (Application # 2002/0188701).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground used Dennis as the primary reference, arguing it taught a flexible Windows Group Policy system that could be extended to non-Windows environments, as suggested by its disclosure of use with minicomputers and mainframes. To enable this extension, Petitioner argued a POSITA would incorporate the teachings of Lortz, which explicitly detailed performing policy translation on a client computer having a different operating system. Brown was added to teach the direct translation of configuration settings between a Windows platform and a non-Windows platform (e.g., IBM iSeries). Petitioner asserted that Lortz’s disclosure of XML as a translated format satisfied the "plain text file" limitation. The combination was argued to teach all limitations of claim 1, including detecting policy changes and maintaining an association between the original and translated policies, which Dennis taught through its desktop management engine and Lortz taught via timestamps.
    • Motivation to Combine: Petitioner argued a POSITA starting with the extensible Dennis framework would be motivated to apply it to non-Windows systems to create a unified management solution. To achieve this, it would have been obvious to look to known techniques for cross-platform policy implementation. Lortz provided a known solution for client-side translation, and Brown provided a known solution for mapping configuration settings between Windows and non-Windows systems.
    • Expectation of Success: The combination involved applying known translation techniques (Lortz, Brown) to a known extensible policy framework (Dennis), which would have yielded the predictable result of cross-platform policy management.

4. Key Claim Construction Positions

Petitioner proposed constructions for several key terms, arguing they were critical to the invalidity analysis.

  • “maintaining an association between the Windows group policy and the translated group policy”: This term was construed broadly to mean maintaining any relationship, such as a temporal one based on timestamps, that allows for propagating updates when the original policy changes. Petitioner noted that the Board, in a related reexamination, had agreed with this broad construction over Patent Owner’s narrower proposed meaning.
  • “native format”: This was construed to mean a format typically used by the operating system of a specific computer. Petitioner argued this construction does not exclude the presence of additional information, such as translation specifications, from being included with the policy data, contrary to positions allegedly taken by the Patent Owner in related matters.
  • “plain text file”: This term was construed to refer broadly to a file of text characters without binary data, consistent with the patent’s disclosure of ASCII and UNICODE text and a POSITA’s understanding of known character encodings at the time.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 2, and 3 of the ’744 patent as unpatentable under 35 U.S.C. §103.