PTAB

IPR2025-00299

X Corp v. Sterling Computers Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and System for Managing Data in a Network Environment
  • Brief Description: The ’217 patent discloses a system for automated data management in a networked environment based on predefined policies. The system involves receiving data, determining an applicable policy for that data, and performing a corresponding action, such as storing, migrating, or deleting the data.

3. Grounds for Unpatentability

Ground 1: Obviousness over Anderson in view of Chen - Claims 1-3, 5, and 8 are obvious over Anderson in view of Chen.

  • Prior Art Relied Upon: Anderson (Patent 6,543,210) and Chen (Application # 2005/0123456).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Anderson teaches a complete system for policy-based data management, disclosing all elements of independent claim 1 except for migrating data between different storage tiers based on the policy. Anderson’s system includes receiving data, associating it with a policy, and taking an action. Chen was cited to remedy this deficiency, as it explicitly discloses a system for information lifecycle management (ILM) that automatically migrates data between high-performance (Tier 1) and low-cost archival (Tier 2) storage based on predefined rules, such as access frequency or data age. Petitioner contended that Chen’s migration teachings directly map onto the corresponding limitation in claim 1. Dependent claims 2, 3, 5, and 8 were argued to be obvious as they recite conventional data management features, such as defining policies based on data type or source (disclosed by Anderson) and storing metadata about the data (a fundamental aspect of any data management system, also taught by Chen).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Anderson’s policy engine with Chen’s tiered storage migration to improve the efficiency and reduce the cost of the Anderson system. Petitioner asserted that tiered storage was a well-known solution to balance storage cost and performance, and integrating Chen’s automated migration capabilities into Anderson’s policy framework would have been a predictable and logical improvement.
    • Expectation of Success: A POSITA would have had a high expectation of success because both Anderson and Chen describe systems operating on standard network principles and data objects. Integrating a rule-based migration module (from Chen) into a general policy-based system (from Anderson) involved known software engineering techniques and presented no undue technical hurdles.

Ground 2: Obviousness over Anderson in view of Sato - Claims 1, 4, and 10-14 are obvious over Anderson in view of Sato.

  • Prior Art Relied Upon: Anderson (Patent 6,543,210) and Sato (Patent 6,987,654).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner again relied on Anderson for the baseline policy-based data management system. The challenge to claims 4 and 10-14 centered on the specific policy triggers. Sato was introduced because it discloses a granular data retention system where actions are triggered by specific temporal conditions, such as a "time-since-last-access" or a fixed "expiration date" associated with a data object. Petitioner asserted this directly teaches the "predefined temporal condition" limitation of dependent claim 10. Sato’s disclosure of applying different retention periods based on data classification was argued to render claims 11-14 obvious, as they recite routine variations of applying time-based rules.
    • Motivation to Combine: The motivation to combine Anderson and Sato was to enhance the Anderson system with more sophisticated and automated policy triggers, a common objective in the field of data management. A POSITA would have recognized the benefit of using Sato’s specific time-based triggers to automate data archival and deletion processes within Anderson’s broader framework, thereby reducing manual oversight and ensuring compliance with data retention policies.
    • Expectation of Success: Success was expected because implementing time-based triggers within a software policy engine was a routine task for a POSITA at the time. The concepts were compatible, and the integration was a matter of applying well-understood programming logic.

4. Key Claim Construction Positions

  • "data management policy" (claims 1, 10): Petitioner argued this term should be construed under its plain and ordinary meaning as "a set of rules defining actions to be performed on data, which can be automatically evaluated by a computer." This construction is broad and does not require any specific data structure for the policy itself. Petitioner contended this interpretation is consistent with the specification, which describes policies in functional terms (e.g., "a policy may specify that the data is to be stored"). This broader construction is critical because prior art references like Anderson and Chen disclose functional rules without detailing a specific policy data structure, thereby meeting the claim limitations under this interpretation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-5, 8, and 10-14 of the ’217 patent as unpatentable.