PTAB

IPR2019-00601

NetApp Inc v. KOM Software Inc

Log In

1. Case Identification

2. Patent Overview

  • Title: Method for Managing a File Lifecycle
  • Brief Description: The ’234 patent discloses methods for managing the lifecycle of computer files by associating a set of policies with each file or its storage location. These policies automate actions such as migrating files between different tiers of storage based on access frequency, while providing applications with transparent access to the files regardless of their physical location.

3. Grounds for Unpatentability

Ground 1: Obviousness over Sitka and Cannon - Claims 1-7, 45-57, and 59 are obvious over Sitka in view of Cannon.

  • Prior Art Relied Upon: Sitka (Patent 6,330,572) and Cannon (Patent 6,021,415).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary reference, Sitka, discloses a comprehensive hierarchical storage management (HSM) system that manages the file lifecycle using a broad set of policies. Sitka’s policies include rules for migration (e.g., moving files from a RAID disk to tape based on age or last use), deletion, and security, thereby teaching automated file lifecycle management. Petitioner asserted that Sitka’s system provides transparent access to files and manages data on a storage medium comprising a plurality of media types, meeting several key limitations of the challenged claims. However, Petitioner contended that to the extent Sitka does not explicitly teach associating its numerous policies with individual files on a granular basis, Cannon supplies this teaching. Cannon discloses a hierarchical storage system that uses a database with an "inventory table" to explicitly cross-reference individual user files with specific policy information, such as "data retention time." Petitioner argued that combining Sitka’s robust policy engine with Cannon’s per-file policy association renders the limitations of independent claims 1, 45, and 51 obvious. Specifically, the core limitation of "associating a set of lifecycle policies with a file in a file system" was allegedly met by applying Cannon's per-file database structure to Sitka's disclosed set of lifecycle policies. Further, Petitioner argued that the key feature of providing "transparent access," which the patent’s Examiner previously found lacking in other prior art, was taught by both references, with Cannon expressly teaching that file access is "transparent to the client stations."
    • Motivation to Combine (for §103 grounds): Petitioner argued that a person of ordinary skill in the art (POSITA) would be motivated to combine Sitka and Cannon because both references operate in the same field of hierarchical storage and address the common problem of managing large volumes of data. A POSITA would recognize the clear advantage of integrating Cannon’s technique for per-file policy control into Sitka's more advanced HSM system. This combination would provide more precise and flexible file management—an understood benefit—by allowing different lifecycle rules to be applied to different individual files rather than just to larger groups. Petitioner framed the combination as the simple application of a known technique (Cannon’s per-file policy association) to improve a similar, existing system (Sitka’s) to achieve the predictable result of more granular control.
    • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success in making this combination. Petitioner asserted that Sitka already discloses the necessary infrastructure, including a database server for storing "policy parameters." Implementing Cannon's method of cross-referencing policies to individual files within Sitka’s existing database would have been a straightforward and predictable software-level modification, not an inventive leap requiring new hardware or overcoming technical hurdles.

4. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-7, 45-57, and 59 of the ’234 patent as unpatentable under 35 U.S.C. §103.