Actifio Inc v. Delphix Corp

1. Case Identification

• Case #: IPR2015-00100
• Patent #: 8,566,361
• Filed: October 21, 2014
• Petitioner(s): Actifio, Inc.
• Patent Owner(s): Delphix Corp.
• Challenged Claims: 1-6, 8, 14, 16-19, 24, and 25

2. Patent Overview

• Title: Datacenter Workflow Automation Scenarios Using Virtual Databases
• Brief Description: The ’361 patent discloses methods and systems for creating “virtual databases” to improve the efficiency of datacenter workflows like development, testing, and backup. The invention creates space-efficient, writable copies of a production database by storing point-in-time snapshots and using pointers to reference the underlying data blocks, thereby avoiding the need to create full physical copies.

3. Grounds for Unpatentability

Ground 1: Obviousness over Sanders, Edwards, and Chapman - Claims 1-6, 8, 14, 16-19, 24, and 25 are obvious over Sanders in view of Edwards and Chapman.

• Prior Art Relied Upon: Sanders (a 2006 NetApp technical report on database cloning), Edwards (a 2008 USENIX conference paper on NetApp's file system virtualization), and Chapman (a 2006 NetApp best practices guide for data mirroring).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of Sanders, Edwards, and Chapman taught every limitation of the challenged claims. Sanders described the high-level commercial application of NetApp's product suite—using FlexClone, FlexVol, and SnapMirror technologies to create writable "clone databases" (analogous to the claimed "virtual databases") from snapshots for disaster recovery, QA testing, and data warehousing. This process involved taking a snapshot of a source database, mirroring it to a destination system, and creating a writable clone from the mirrored copy. Edwards provided the underlying technical details, explaining that NetApp's FlexClone technology created writable volumes from read-only snapshots by generating a new file structure root (vol_info block) that inherits pointers to the complete file system image of the original snapshot, thus creating a virtual, pointer-based copy without duplicating data. Chapman provided specific implementation details for NetApp's SnapMirror technology, including the concept of "cascading," which directly taught the claimed step of replicating database blocks from a first storage system to a second storage system. The combination, therefore, taught a complete method for creating and mounting a virtual, writable database on a secondary storage system based on point-in-time copies replicated from a source system.
  • Motivation to Combine: Petitioner asserted a strong motivation to combine these references. All three documents were published by the same company, NetApp, and described different, complementary aspects of the same integrated product suite (Data ONTAP). A person of ordinary skill in the art (POSITA) seeking to implement the database cloning solution described in Sanders would have naturally consulted Edwards for detailed technical explanations of the underlying file system virtualization and Chapman for best practices on deploying the SnapMirror data replication component. The references were not from disparate fields but were designed to work together, addressing the same problem of creating efficient database copies with the same technological solution.
  • Expectation of Success: A POSITA would have had a very high expectation of success. The combination was not a theoretical assembly of components but a description of how an existing, commercially successful NetApp product suite functioned. The references collectively documented a proven, integrated system, ensuring that combining their teachings would yield a predictable and functional result.

4. Key Claim Construction Positions

• "virtual database": Petitioner argued for the construction "a set of database files capable of being read from and written to, created by pointing to already-stored database blocks." This construction was central to the obviousness argument, as it directly equated the claimed "virtual database" with the pointer-based, writable "clone volumes" described in the NetApp prior art, particularly in Edwards. The construction emphasized the core technical mechanism—virtualization via pointers—that Petitioner alleged was well-known.
• "database blocks": Petitioner proposed the construction "a unit of data used by a database." This interpretation was based on the patent's specification and aligned with the disclosure in Edwards, which described the fundamental data blocks (e.g., 4KB blocks in the WAFL file system) used by NetApp storage systems to store database information.
• "mounting": Petitioner proposed construing "mounting" to mean "making accessible [to a database server]." This construction was based on the patent's description of using file-sharing protocols like NFS and was consistent with the final step taught by Sanders, which explicitly described using a mount command to make the cloned database volumes accessible to a database server.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-6, 8, 14, 16-19, 24, and 25 of the ’361 patent as unpatentable.