PTAB

IPR2024-00080

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 ’850 patent describes methods for restoring a file on a computer to a previous version. The technology centers on presenting a user with a list of previous file versions stored remotely, allowing the user to preview a selected version without fully restoring it, and then optionally restoring that version to the local computer.

3. Grounds for Unpatentability

Ground 1: Claims 1-21 are obvious over Schneider.

  • Prior Art Relied Upon: Schneider (PCT Publication No. WO 99/12101).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Schneider, which relates to the backup and recovery of computer data, discloses all limitations of the challenged claims. Schneider teaches a file-level recovery system where a current file version is maintained on a local "internal disk" while historical versions are stored on a separate "external disk" accessible over a network. The system allows a user to view a list of a file’s old versions, preview the contents of a selected version without formally retrieving it (by copying it to a temporary directory that is later purged), and then restore the selected version, which replaces the current version on the local disk. This process directly maps to the claimed steps of presenting information about previous versions from a remote location, previewing a selected version, and restoring it.
    • Motivation to Combine: This is a single-reference ground. Petitioner contended that Schneider teaches all the essential components, and a person of ordinary skill in the art (POSITA) would have found it obvious to implement them in the claimed manner to create a coherent file recovery system.
    • Expectation of Success: A POSITA would have had a high expectation of success because Schneider explicitly describes the compatibility and integration of these features, such as viewing a list of versions, previewing content, and restoring files.

Ground 2: Claims 1-21 are obvious over Schneider in view of Crawford.

  • Prior Art Relied Upon: Schneider (WO 99/12101) and Crawford (Patent 5,771,354).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground supplements Ground 1 by introducing Crawford to explicitly teach the use of the Internet for remote storage. While Petitioner argued Schneider’s networked "external disk" already meets the "remote storage location" limitation, Crawford is presented to preempt any argument that Schneider’s teaching of a Local Area Network (LAN) is insufficient. Crawford discloses an "Internet online backup system" that provides remote storage and allows a customer computer to connect to a remote server over the Internet for file backup and restoration.
    • Motivation to Combine: A POSITA would combine Schneider's file versioning and previewing system with Crawford's Internet-based remote storage to achieve enhanced benefits. These benefits include geographically independent off-site backup for disaster recovery, conserving local storage space, and accessing additional remote computing resources, all of which Crawford explicitly describes. The Internet was a known alternative to a LAN for remote access.
    • Expectation of Success: A POSITA would expect success in this combination because Crawford teaches implementing the Internet connection with conventional technology like modems and standard data packet transmission techniques, making its integration with Schneider’s system straightforward.

Ground 3: Claims 1-8, 10-16, and 18-21 are obvious over Sweat.

  • Prior Art Relied Upon: Sweat (Patent 7,062,532).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Sweat, which discloses a "project hosting service," teaches all elements of the challenged claims. Sweat’s system allows a user to access files via a web browser, with file versions stored on a remote server accessible over the Internet. A "versions tab" in the user interface displays a list of previous file versions. A user can select a version and click a "View in Window" button to preview its contents in a separate window. To restore a version, the user clicks a "Download" button, which copies the selected version from the remote server to the user's local computer, with the option to overwrite the existing current version. This functionality directly corresponds to the claimed method.
    • Motivation to Combine: This is a single-reference ground. Petitioner argued that Sweat alone discloses a complete system that performs the claimed method of presenting, previewing, and restoring file versions from a remote, networked location.
    • Expectation of Success: Not applicable for a single-reference ground.

  • Additional Grounds: Petitioner asserted that claims 9 and 17 are obvious over Sweat in view of Schneider. This combination adds Schneider's teaching of delaying write operations (e.g., performing them as a background activity) to Sweat's backup system to make the file transmission process have a substantially imperceptible impact on system performance from the user's perspective.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise discretionary denial. To avoid denial under Fintiv due to parallel district court litigation, Petitioner stipulated that if the IPR is instituted, it will not pursue in the parallel litigation any grounds that were raised or reasonably could have been raised in the petition.
  • Petitioner also argued against denial under §325(d), stating that the primary prior art references, Schneider and Sweat, provide express teachings on previewing and recovering archived files and were never cited, considered, or discussed by the Examiner during the original prosecution of the ’850 patent.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-21 of the ’850 patent as unpatentable.