PTAB

IPR2017-00985

Facebook Inc v. Sound View Innovations LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Aging Versions of Data in a Main Memory Database
  • Brief Description: The ’371 patent describes a system for managing data in a main memory database to improve efficiency and increase memory capacity. The invention uses a "multi-versioning" technique where update transactions create new versions of data records rather than overwriting old ones, combined with a process for deleting older versions to free up memory.

3. Grounds for Unpatentability

Ground 1: Claims 1-3 and 8-10 are obvious over Bernstein in view of Rubin.

  • Prior Art Relied Upon: Bernstein (a 1987 textbook titled Concurrency Control and Recovery in Database Systems) and Rubin (Patent 5,155,842).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Bernstein, a foundational text on database systems, taught nearly all elements of the challenged claims. Bernstein disclosed a multi-version database system where update transactions create new versions of data, each transaction is assigned a unique timestamp, and old versions are periodically purged to manage storage space, specifically by deleting from oldest to newest. Petitioner contended that the only element not explicitly detailed in Bernstein was the specific mechanism for monitoring memory to trigger this deletion. To supply this element, Petitioner relied on Rubin, which taught a generalized system for monitoring logical events in a computer network—such as a disk "approaching a threshold full level"—and notifying a program to take automated action, such as deleting the oldest versions of files to create more space. Petitioner asserted that combining Rubin's explicit monitoring and notification system with Bernstein's database management system rendered the claimed invention obvious.
    • Motivation to Combine: Petitioner presented several motivations for a person of ordinary skill in the art (POSITA) to combine the references. The primary motivation was to implement a known solution to a known problem. Bernstein identified the need to delete old data versions when storage space runs out but did not specify the mechanism for detecting this condition. A POSITA would look to a known, off-the-shelf solution like Rubin’s event-monitoring system to provide this functionality. Furthermore, Petitioner argued the combination would yield predictable improvements. Bernstein's system acts only when it has run out of space, a condition that can cause critical system errors and require suspending database operations. Rubin’s system allows for proactive memory management by acting when storage approaches a threshold, thereby preventing system failure and improving performance and stability, a particularly attractive benefit for the multi-user concurrent access systems contemplated by Bernstein.
    • Expectation of Success: A POSITA would have a high expectation of success because the combination involved applying a standard event-monitoring technique (Rubin) to a known database management problem (storage control in Bernstein). The functions of each reference were maintained, and their integration to automate memory management was straightforward and predictable.

4. Key Claim Construction Positions

  • "Update Transactions": Petitioner proposed construing this term as “transactions that modify portions of the database,” based on an explicit definition provided in the ’371 patent specification. This construction was central to mapping Bernstein’s “Write” operations, which modify data, to the claimed transactions.
  • "Controller": Petitioner argued that the terms "time stamping controller," "versioning controller," and "aging controller" did not require explicit construction under the broadest reasonable interpretation standard applicable in an inter partes review (IPR). Petitioner asserted the specification made clear these terms refer to hardware, software, or firmware that performs the recited functions. Strategically, Petitioner stated it was not asserting that these were means-plus-function terms for the purpose of the IPR, thereby avoiding the need to identify corresponding structure in the specification.

5. Relief Requested

  • Petitioner requested institution of an IPR and cancellation of claims 1-3 and 8-10 of the ’371 patent as unpatentable under 35 U.S.C. §103.