PTAB

IPR2015-01678

Delphix Corp v. Actifio Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Creating Deduplicated Copies of Data Storing Non-Lossy Encodings of Data Directly in a Content Addressable Store
  • Brief Description: The ’944 patent describes a data storage system that improves efficiency in a deduplicated, content-addressable store. The system determines if a small data segment can be represented by a non-lossy encoding that is smaller than a standard hash signature, and if so, stores the encoding itself directly in the hash field of a pointer structure instead of storing a hash that points to the data.

3. Grounds for Unpatentability

Ground 1: Claims 1, 3, and 4 are obvious over Patterson in view of Terao

  • Prior Art Relied Upon: Patterson (Patent 7,143,251, which incorporates Zhu, Patent 6,928,526) and Terao (Application # 2004/0199570).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Patterson taught the foundational elements of a hash-based deduplication system, including segmenting a data stream, storing only unique segments, and using a "reconstruction list" of unique identifiers (which could be hash values) to reassemble the original data. Patterson also disclosed that a unique identifier could be the data segment itself. Terao was argued to explicitly teach the core inventive concept: comparing the size of a data fragment to its hash value and storing the fragment itself as the identifier if it is smaller, thereby not storing the data fragment elsewhere. The combination, therefore, rendered claim 1 obvious. For claim 3, Petitioner asserted that Terao explicitly suggests SHA-1 as a suitable cryptographic hash function, making its use in the Patterson system obvious. For claim 4, Petitioner contended that both Patterson and Zhu taught reconstituting data from stored segments and identifiers, and it would be obvious that any encoded content stored directly as an identifier would need to be decoded for reconstitution.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to improve the storage efficiency of the system taught in Patterson. Because Patterson already suggested using data segments themselves as identifiers and was explicitly focused on reducing storage space, a POSITA would have looked to related art like Terao, which provided an explicit and advantageous method for doing so by comparing the size of the data segment to its hash.
    • Expectation of Success: The combination involved applying known data storage and compression principles to existing deduplication architectures. A POSITA would have had a reasonable expectation of success in implementing Terao’s size-comparison logic into Patterson's system to achieve predictable gains in storage efficiency.

Ground 2: Claim 2 is obvious over Patterson in view of Terao and Li

  • Prior Art Relied Upon: Patterson (Patent 7,143,251, incorporating Zhu), Terao (Application # 2004/0199570), and Li (Patent 7,689,633).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Patterson and Terao from Ground 1 to address the specific limitation of claim 2, which requires the non-lossy encoding to be a "run-length encoding" (RLE). Petitioner argued that Li, which described a deduplication system built upon the work of Patterson and Zhu, explicitly disclosed a variety of non-lossy compression schemes that could be used, including RLE.
    • Motivation to Combine: A POSITA seeking to implement the non-lossy encoding technique suggested by the combination of Patterson and Terao would naturally consult references disclosing specific, suitable compression algorithms. Li was an obvious choice, as it shared the same assignee and an inventor with Patterson and Zhu, and expressly cited both as "exemplary methods" for its own system. Therefore, a POSITA would be motivated to use the RLE technique from Li as the specific non-lossy encoding method in the combined Patterson/Terao system.
    • Expectation of Success: Applying a well-known compression algorithm like RLE, as taught by Li, to the data segments in the Patterson/Terao system was a straightforward implementation detail with predictable results.

4. Key Claim Construction Positions

Petitioner argued for the following constructions under the Broadest Reasonable Interpretation standard:

  • "Data Object": Proposed to mean "a unit of data stored in memory." This construction was based on disclosures in the ’944 patent and was used to map the "data stream" from the prior art to the claimed "data object."
  • "Hash Structure": Proposed to mean "a structure for holding a value generated via a hash function." Petitioner asserted this term corresponds to what the specification calls a "handle" and what the prior art refers to as an entry in a "reconstruction list" or "ID sequence."
  • "Hash Signature": Proposed to mean "a value generated via a hash function." This construction clarified that the field within the "hash structure" was intended to hold a hash value itself.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4 of the ’944 patent as unpatentable.