PTAB

IPR2024-00078

Dropbox Inc v. Datanet LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Automatic Real-Time File Management Method And Apparatus
  • Brief Description: The ’478 patent relates to a method and apparatus for archiving files. The claimed method involves detecting an instruction to perform an operation on a file, which triggers the creation of a backup copy that is then migrated through a series of storage locations: a temporary location, an intermediate location, and finally a permanent archive location, with a database being updated to track the file’s location at each stage.

3. Grounds for Unpatentability

Ground 1: Claims 1-6 and 8-11 are obvious over Kenley in view of Long.

  • Prior Art Relied Upon: Kenley (Patent 5,276,867) and Long (Patent 5,325,519).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kenley disclosed a file-based, hierarchical storage system with three tiers (primary, secondary, and backing store) and a relational database "system catalog" to track file attributes and locations. However, Kenley’s backup process was a conventional timed or incremental backup. Petitioner asserted that Long disclosed a modification-driven backup technique that creates a copy of data before it is overwritten. In Long’s system, a modification request triggers the backup process, where a "before image" of the data is first stored in a temporary memory buffer, then moved to an "audit buffer" on a local disk (intermediate storage), and finally archived to external removable media (permanent storage). Long also taught using an "audit header" to manage and track the data's location. The combination applies Long's event-driven, multi-stage backup process to Kenley's file-based hierarchical system.
    • Motivation to Combine: A POSITA would combine Long's modification-driven backup with Kenley's file-based system to improve reliability. Kenley’s periodic backups created a risk of data loss for modifications made between backups. Long’s technique of creating a backup upon each modification would solve this problem, providing a more robust and fault-tolerant system, which was a stated goal of both references.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the references were complementary. Both disclosed multi-tier storage architectures (temporary/primary, intermediate/secondary, permanent/archive). Long's "audit header" for tracking data location was analogous to and would naturally integrate into Kenley's "system catalog" database. Applying Long’s data-level backup process to Kenley’s file-based system was a straightforward implementation for a POSITA, as data on hard disks was commonly organized into files.

Ground 2: Claims 1-6 and 8-11 are obvious over Cabrera, Schneider, and Whiting.

  • Prior Art Relied Upon: Cabrera (Patent 5,953,729), Schneider (PCT Publication No. WO 99/12101), and Whiting (Patent 5,778,395).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Cabrera disclosed a system for archiving files from a local area to a remote storage area, using a temporary "staging area" as an intermediate step. The transfer could be triggered by events like the expiration of a timer or the accumulation of a certain amount of data. Petitioner argued that Schneider taught overcoming the shortcomings of such periodic backups by providing a continuously running backup system triggered by intercepting file-manipulation events, such as a write request from the operating system. Schneider taught saving the prior state of data in a disk-based "history buffer" before it is overwritten. Finally, Whiting disclosed using a "global directory database file" to track the location of all backup files across multiple nodes and storage tiers, enabling transparent access and searching.
    • Motivation to Combine: A POSITA would combine these references to create an improved, automated, and robust backup system. A POSITA would have been motivated to replace Cabrera’s less reliable, time-based trigger with Schneider’s more granular, operation-triggered backup to "eliminate the need to pause and make backups" and ensure no data is lost. This modification would create a more reliable, continuously running system. A POSITA would then incorporate Whiting’s global database directory to improve Cabrera's system for tracking file locations as they migrate from local storage, through the staging area, and to remote storage, thereby ensuring archived files could be located and accessed efficiently.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because intercepting file operations (as taught by Schneider) was a known technique. Cabrera itself described monitoring for "changes as they occur," making the integration of Schneider's trigger straightforward. Furthermore, incorporating Whiting’s database to track file locations in Cabrera’s hierarchical storage system was a natural and necessary step for managing migrated files, as a POSITA would have understood the need to track backup copies to facilitate transparent access and recovery.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not discretionarily deny institution. In view of parallel district court litigation, Petitioner stipulated that it would not pursue in court any grounds raised or that reasonably could have been raised in the IPR. In view of an ongoing ex parte reexamination, Petitioner argued that this petition presented entirely different prior art and arguments not cumulative to the reexamination. Petitioner also noted that the challenged claims differ, as this petition uniquely challenges claim 4, and that the petition was filed by different entities than the reexamination requester.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-6 and 8-11 of the ’478 patent as unpatentable.