PTAB

IPR2017-02148

Unified Patents, Inc. v. Uniloc Luxembourg S.A.

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1. Case Identification

2. Patent Overview

  • Title: Move/Copy Interface with Pause/Resume Feature
  • Brief Description: The ’229 patent discloses a method and system for copying or moving data files that includes a user-operable pause and resume feature. This functionality allows a user to suspend a resource-intensive file transfer, freeing system resources for other tasks, and subsequently resume the transfer from the point of interruption without having to restart the entire process.

3. Grounds for Unpatentability

Ground I: Obviousness over Wiese and Chowdhury - Claims 1, 2, 6, 8-11, 14-16, 18, and 19 are obvious over Wiese in view of Chowdhury.

  • Prior Art Relied Upon: Wiese (Patent 6,108,707) and Chowdhury (Patent 6,026,439).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wiese disclosed the core elements of a file transfer method (reading from a source, writing to a destination) that could be automatically suspended to yield CPU resources for other concurrent user-initiated tasks, and then resumed. However, Wiese's suspension is triggered by the system detecting another task, not a direct user command to pause. Petitioner asserted that Chowdhury remedied this by disclosing an explicit, user-initiated PAUSE and PLAY (resume) functionality for a data stream (e.g., a video file) via an API, which a user could invoke through a user interface. The combination, therefore, taught a file copy method with a user-requested pause and resume feature that makes the system available for other operations, meeting the limitations of independent claim 1.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the references to improve Wiese's system. Wiese’s goal was to improve system responsiveness during file transfers. Adding Chowdhury's explicit PAUSE/PLAY functions would make the transfer more responsive to direct user input, providing greater control and fulfilling Wiese’s objective in a more intuitive way than relying on automatic task detection.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success, as combining a known user interface element (a pause button) with a background file transfer process was a finite and predictable solution to a known problem. The result—a file transfer responsive to a user's pause/resume requests—would have been a predictable outcome.

Ground II: Obviousness over Wiese, Chowdhury, Miller, and Day - Claims 3-5, 12, 13, and 17 are obvious over Wiese in view of Chowdhury, Miller, and Day.

  • Prior Art Relied Upon: Wiese (Patent 6,108,707), Chowdhury (Patent 6,026,439), Miller (Patent 5,553,083), and Day ("A Proposed File Access Protocol Specification," RFC 520, June 1973).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground I to address claims requiring the writing and reading of an index upon pause and resume. Petitioner contended that while Wiese and Chowdhury provided the foundational pause/resume functionality, Miller and Day supplied the necessary implementation details for tracking the transfer's state. Miller disclosed using a "frame data structure" that tracks non-transferred blocks of a file for later retransmission. Day disclosed a "file pointer" that represents an index or address within a file. Petitioner argued these references taught creating a pointer or index to the next data portion to be transferred and storing it, as required by claims 3, 12, and 17.
    • Motivation to Combine: A POSITA implementing the pause/resume feature from Wiese and Chowdhury would naturally look for a way to track the resumption point. Miller and Day provided known methods for this exact purpose. Combining Miller's data structure and Day's file pointer concept with the Wiese/Chowdhury system was an obvious design choice to ensure the file transfer could be resumed accurately and efficiently from the correct location.

Ground IV: Obviousness over Romrell and Chowdhury - Claim 1 is obvious over Romrell in view of Chowdhury.

  • Prior Art Relied Upon: Romrell (Patent 6,396,805) and Chowdhury (Patent 6,026,439).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented this as an alternative to Ground I. Romrell was argued to disclose a method for transparently recovering from data transmission disruptions. This included a user-selectable "deferred continuation option" that allowed a user to checkpoint (i.e., pause) a download at any time, store the partially-downloaded data, and resume it later from an offset. This process allowed the user to browse elsewhere or disconnect during the pause. Petitioner argued that Romrell alone taught all the steps of claim 1, but to the extent it was not explicit enough, Chowdhury's PAUSE/PLAY API functions supplied the missing element of a direct user pause request.
    • Motivation to Combine: A POSITA would be motivated to integrate Chowdhury's clear and explicit "pause" and "play" terminology into Romrell's system. Replacing Romrell's more ambiguous "deferred continuation option" with Chowdhury's industry-standard UI functions would reduce user confusion and provide a more direct, intuitive interface for achieving the same goal of pausing and resuming a file transfer, which both references address.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 7 (Ground III) based on Wiese and Chowdhury in view of Raucci ("A Windows NTTM Guide to the Web," 1997), which taught using a progress bar to display the amount of data written to a target file.

4. Key Claim Construction Positions

  • "computer system is available for other processing operations": Petitioner proposed this term should be construed to mean that "at least a substantial portion of one or more resources of the computer system, such as a processor, memory, or network resources, that are being used by the copy operation are freed from the copy operation to be used to carry out a task other than the copy operation." This construction was critical to arguing that Wiese's disclosure of yielding the CPU to other tasks met this limitation.
  • Means-Plus-Function Limitations: Petitioner contended that numerous limitations in claims 10-19 were means-plus-function limitations under pre-AIA §112, ¶6. For each, Petitioner identified specific corresponding structures from the ’229 patent's specification. For example, for "means for pausing" and "means for resuming," Petitioner identified the algorithms shown in the flowcharts of Figures 6 and 7, as executed by the general-purpose computer system of Figure 8, as the corresponding structure. This detailed structural analysis was foundational to mapping the prior art onto the claims.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-19 of Patent 6,564,229 as unpatentable.