PTAB

IPR2015-00034

Actifio Inc v. Delphix Corp

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Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Virtual Database System
  • Brief Description: The ’808 patent describes a system and method for creating "virtual databases," which are space-efficient, read/writable copies of a production database. The technology aims to reduce storage and overhead costs associated with creating full physical database copies for development and testing by creating virtual copies from point-in-time snapshots.

3. Grounds for Unpatentability

Petitioner asserted a single, comprehensive ground of obviousness for all challenged claims based on one combination of prior art.

Ground 1: Obviousness over Edwards, Patterson, and SnapManager Guide - Claims 1, 7-14, 17-19, 22-23, 28, 40-41, and 47-49 are obvious over Edwards in view of Patterson and SnapManager Guide.

  • Prior Art Relied Upon: Edwards (a 2008 USENIX conference paper), Patterson (a 2002 USENIX conference paper), and SnapManager Guide (a 2008 NetApp Inc. product guide).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these three related NetApp references taught every limitation of the challenged claims.
      • Edwards was argued to teach the core technology for creating a virtual database. It described NetApp's FlexClone feature, which creates writable, virtual volumes from read-only, point-in-time snapshots. Edwards explained that these clones are "virtual" because they are created by pointing to the data blocks of the original snapshot rather than physically duplicating them, achieving space efficiency. Edwards also introduced NetApp's SnapMirror feature for replicating snapshots to a remote destination storage system.
      • Patterson, which Edwards expressly referenced for more detail on SnapMirror, allegedly supplied teachings related to storing multiple point-in-time copies. Patterson disclosed that a SnapMirror destination system receives and stores a plurality of snapshots from a source volume over time and that these multiple snapshots can share common data blocks. This was argued to teach the claim limitation that stored database blocks are associated with multiple point-in-time copies.
      • SnapManager Guide was asserted to supply the final elements for the system. While Edwards taught creating virtual clones, the petition argued SnapManager Guide explicitly taught the claimed step of mounting the cloned database onto a database server (e.g., a Microsoft SQL Server) to make it accessible for read/write operations. Furthermore, the Guide was used to map numerous dependent claim limitations, such as associating the database with a predetermined policy for managing point-in-time copies (e.g., scheduling backups, specifying retention periods, and purging old copies based on time or available space).
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would have been strongly motivated to combine these references because they all originated from the same company (NetApp) and described different aspects of the same commercially integrated product suite. Edwards explicitly referenced Patterson for more detail on SnapMirror, and the SnapManager Guide provided practical, user-level instructions for implementing the storage virtualization techniques described in Edwards and Patterson. The references documented a natural technological evolution, solved the same problems, and were not incompatible.
    • Expectation of Success: A POSITA would have had a high expectation of success because the combination involved integrating components of an existing, commercially successful product line designed to work together. The SnapManager Guide itself was presented as evidence that the technologies described in Edwards and Patterson were already successfully combined in a commercial product.

4. Key Claim Construction Positions

  • Petitioner argued for several constructions, with the term "virtual database" being central to its invalidity contentions.
  • "virtual database": Petitioner proposed construing this term as "a set of database files capable of being read from and written to, created by pointing to already-stored database blocks." This construction was crucial because it directly aligned with the pointer-based, non-duplicative file system creation method taught by NetApp's FlexClone technology in the Edwards reference. By defining the "virtual" nature of the database by its method of creation (pointing), Petitioner could map Edwards's disclosure directly onto the claims.
  • "mount[ing]": Petitioner proposed construing this term to mean "making accessible." This broad construction allowed Petitioner to argue that the SnapManager Guide's instructions for making a cloned database available to a SQL server met the claim limitation.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1, 7-14, 17-19, 22-23, 28, 40-41, and 47-49 of the ’808 patent as unpatentable under 35 U.S.C. §103.