Microsoft Corp v. Synkloud TechnoLogices LLC

1. Case Identification

• Case #: IPR2020-01032
• Patent #: 10,015,254
• Filed: June 4, 2020
• Petitioner(s): Microsoft Corporation and HP Inc.
• Patent Owner(s): Synkloud Technologies, LLC
• Challenged Claims: 9-15

2. Patent Overview

• Title: System and Method for Wireless Device Access to External Storage
• Brief Description: The ’254 patent describes a system allowing a wireless device to interact with a remote storage server for storing and managing data. The system facilitates the transfer of data objects from a remote source to an allocated space on the server, controlled by the wireless device, and enables users to perform file management operations via a web browser.

3. Grounds for Unpatentability

Ground 1: Claims 9-13 and 15 are obvious over McCown in view of Dutta.

• Prior Art Relied Upon: McCown (International Publication No. WO 01/67233) and Dutta (Application # 2002/0078102).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that McCown taught the core elements of independent claim 9, including a server for delivering a storage service, a plurality of storage spaces, and program instructions for a wireless device to remotely access a storage space and initiate a file download from a remote site into that storage space. However, McCown did not explicitly disclose using a "cache storage" on the wireless device for the download information (e.g., URLs). Petitioner contended that Dutta supplied this missing element by teaching a client device with a browser that maintains local storage, including a "browser cache," for storing web page content for faster retrieval.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the well-known browser caching technique from Dutta with the remote storage system of McCown to improve system performance and efficiency. Caching information like URLs locally, as suggested by Dutta, would allow the user-site application in McCown to generate data requests more quickly without needing to re-access the remote site over the network. Petitioner asserted this was a predictable combination of known elements from analogous arts (remote data storage) to achieve a known benefit.
  • Expectation of Success: A POSITA would have a high expectation of success because browser caching was a common and well-understood practice for improving the speed of web-based interactions. Integrating a standard browser cache into McCown's browser-based system would have been a straightforward and predictable implementation.

Ground 2: Claims 9-15 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 incorporated the combination of McCown and Dutta from Ground 1 to teach the primary system of remote storage with local caching. Petitioner further argued that Coates taught the specific file and folder manipulation functionalities recited in dependent claims, particularly claim 14. Coates disclosed a remote network storage system where a user can perform directory operations such as creating, deleting, moving, copying, or renaming files and folders remotely from a client device. These operations directly corresponded to the limitations of claim 14 concerning "remotely creating a folder" or "remotely deleting, moving copying or renaming a data object."
  • Motivation to Combine: A POSITA would be motivated to add the remote file manipulation capabilities of Coates to the base system of McCown and Dutta to provide essential usability. A remote storage service would have limited utility without the ability for users to manage and organize their stored files. Coates addressed this exact need within the same technical field, making its teachings a logical and desirable addition to enhance the functionality of the McCown/Dutta system.
  • Expectation of Success: Success would have been highly expected. Implementing standard file system operations on a remote server, as detailed in Coates, was a known and predictable extension for any remote storage service. The combination simply added conventional file management features to a remote storage platform, resulting in a system where each element performed its expected function.

4. Key Claim Construction Positions

• "cache storage": Petitioner proposed this term 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 central to the argument, as it allowed Petitioner to map the well-known "browser cache" taught by Dutta onto the claim language, even though the ’254 patent specification only mentioned the word "cache" once.
• "updating the storage space": Petitioner argued this phrase should be interpreted broadly to mean program instructions for the server to update a storage space according to a user's requested operation. This construction was argued to encompass not only downloading new files, as taught by McCown, but also the file management operations (e.g., deleting, moving, renaming) taught by Coates.
• "web console": Petitioner contended this term should mean "a control unit through which a user communicates with the computer to access interlinked documents in a hypertext system, such as the World Wide Web." This construction supported mapping a standard web browser, as disclosed in the prior art, to the "web console" limitation in claim 13.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 9-15 of Patent 10,015,254 as unpatentable.