PTAB

IPR2020-01031

Microsoft Corp v. Synkloud Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Wireless Device Access to External Storage
  • Brief Description: The ’254 patent describes systems and methods for a wireless device to interact with a remote storage server. The technology focuses on transferring data objects from a remote site to an allocated storage space on a server, where the transfer is controlled by the wireless device.

3. Grounds for Unpatentability

Ground 1: Claims 1-5, 8, and 16-18 are obvious over McCown in view of Dutta.

  • Prior Art Relied Upon: McCown (WO 01/67233) and Dutta (Application # 2002/0078102).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that McCown taught the core system of a wireless device (a "user site") that accesses a remote storage space and initiates the download of files from a second, remote server to that storage space. McCown disclosed that its user site employs a web browser, which Petitioner’s expert contended would have been understood by a Person of Ordinary Skill in the Art (POSITA) to include a cache. To remove any doubt, Petitioner combined McCown with Dutta, which explicitly disclosed a "browser cache" in local storage for faster retrieval of web content. Petitioner contended the combination taught the "cache storage" limitation of independent claims 1 and 16. The limitation of "utilizing information for the file cached" was met because a POSITA would find it obvious to cache the URLs for the files to be downloaded (the "information"), allowing the user site to generate a data request more quickly.
    • Motivation to Combine: A POSITA would combine Dutta’s browser cache with McCown’s remote storage system to improve performance. The references were in the analogous art of remote data storage and addressed the problem of limited storage on wireless devices. Caching URLs and other web data was a well-known technique to provide faster and more convenient data access, reduce latency, and avoid having to re-fetch information from a remote server.
    • Expectation of Success: Petitioner asserted a POSITA would have a high expectation of success because using a browser cache to improve performance was a common, well-understood, and routine practice at the time of the invention. The combination represented a predictable arrangement of old elements.

Ground 2: Claims 6, 7, 19, and 20 are obvious over McCown in view of Dutta, in further view of Coates.

  • Prior Art Relied Upon: McCown (WO 01/67233), Dutta (Application # 2002/0078102), and Coates (Patent 7,266,555).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the McCown and Dutta combination to address limitations in dependent claims related to file and folder management. Specifically, claims 6 and 19 require "creating a folder, or a layered folder or directory structure," and claims 7 and 20 require operations like "moving, copying, deleting, or renaming a data object." Petitioner argued that while McCown and Dutta established the remote storage system with caching, Coates explicitly taught a network storage system with a hierarchical file system, including methods to create, update, move, and delete folders and files.
    • Motivation to Combine: A POSITA would be motivated to add the file manipulation techniques of Coates to the McCown/Dutta system to improve usability. It was a logical and obvious improvement to provide users of a remote storage system with the ability to organize their data by creating folders and managing files. Coates’s teachings on managing remote files directly addressed a functional gap in a basic remote storage system.
    • Expectation of Success: Petitioner argued there was a high expectation of success, as combining a storage system with file management capabilities was a standard and necessary feature for any practical storage solution. Implementing Coates's known file management functions within the existing software framework of McCown was presented as a straightforward task for a POSITA.

4. Key Claim Construction Positions

  • "cache storage": Petitioner proposed this term should be construed as "storage for data received from the Internet that is more readily accessible by the user or user application than the original Internet storage location." This construction was argued to be consistent with the patent’s limited use of the term and the general understanding in the art, avoiding a narrow interpretation tied to specific memory hardware. This broader meaning was critical for arguing that McCown’s browser inherently had a cache or that Dutta’s general local storage for caching met the limitation.
  • "utilizing information for the file cached in [the/a] cache storage": Petitioner argued this phrase was broad enough to cover using information, such as URLs, stored in the cache to download a file from a remote server. This interpretation was central to mapping McCown’s process—where a user selects files from a list of URLs and those URLs are used to generate a download request—onto the claim language.
  • "folder or directory structure": Petitioner proposed this term means "an arrangement of folders and subfolders (or directories and subdirectories) for holding files." This construction aligns with the common meaning and was used to map the hierarchical file system taught by Coates onto the limitations of claims 6, 7, 19, and 20.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-8 and 16-20 of the ’254 patent as unpatentable.