PTAB

IPR2025-00965

Oracle Corp v. VirtaMove Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Containerization of Application Sets
  • Brief Description: The ’814 patent describes a system for isolating software applications by placing them in "secure containers." These containers include the applications and associated system files, allowing them to run on a server using the server’s native operating system (OS) kernel without interfering with other applications or the host OS, thereby providing an alternative to resource-intensive virtual machines.

3. Grounds for Unpatentability

Ground 1: Obviousness over Schmidt-Tormasov - Claims 1-34 are obvious over Schmidt-479 in view of Tormasov.

  • Prior Art Relied Upon: Schmidt-479 (Application # 20020095479) and Tormasov (Application # 20020124072).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Schmidt-479 discloses "compute capsules" that encapsulate an entire computing environment, including applications and necessary system files, making them portable. Tormasov discloses lightweight "virtual computing environments" (VCEs) that provide users with an environment functionally equivalent to a full OS but share a single underlying hardware and OS kernel, ensuring processes are isolated from each other. The combination of Schmidt-479's portable capsule and Tormasov's isolated VCE was asserted to teach the "secure containers" of claim 1.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine these references to create a portable, isolated, and full-featured computing environment. The goal would be to implement Tormasov's efficient VCEs within Schmidt-479's portable capsules, allowing these self-contained environments to be stored and executed across multiple servers, which was a known desire for enterprise systems.
    • Expectation of Success: Petitioner contended that a POSA would have a reasonable expectation of success because both references describe compatible techniques for virtualization on conventional operating systems like Unix. Both use concepts like unique file systems and namespaces to achieve isolation, making their integration straightforward for a skilled artisan.

Ground 2: Obviousness over Schmidt-Tormasov-Calder - Claims 1-34 are obvious over Schmidt-479 and Tormasov in further view of Calder.

  • Prior Art Relied Upon: Schmidt-479 (Application # 20020095479), Tormasov (Application # 20020124072), and Calder (Application # 20020066022).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on Ground 1 by adding Calder, which teaches modifying an "application package" by adding system libraries that translate system calls native to one OS (e.g., Windows) to work on a non-native OS (e.g., Linux). This addition was argued to render obvious the limitation that containers can operate on servers with differing operating systems, even across different OS families (e.g., Windows and Unix-based systems).
    • Motivation to Combine: A POSA was motivated to make the Schmidt-Tormasov VCE-capsule executable on servers running different OS families to achieve greater interoperability, a well-known goal in large, heterogeneous computing environments. Calder directly addresses this problem by providing a method to make applications cross-platform compatible.
    • Expectation of Success: Success was reasonably expected because Calder's system call translation techniques were designed to work with the same types of conventional operating systems disclosed in Schmidt-479 and Tormasov. Applying Calder's teachings to the system files within the VCE-capsule would be a predictable implementation for a POSA seeking cross-platform portability.

  • Additional Grounds: Petitioner asserted additional obviousness challenges over the combinations of Ground 1 and Ground 2 in further view of Schmidt-629 (Application # 20020138629). Schmidt-629 was primarily used to teach assigning a unique locator, such as an IP address, to each capsule to facilitate communication and mobility between different machines and networks, further supporting limitations related to unique container identities.

4. Key Claim Construction Positions

  • Petitioner stated it construes claim terms according to the standard used in civil actions. It noted that in a co-pending district court litigation, the parties have proposed competing constructions for several terms.
  • The petition was structured to demonstrate unpatentability regardless of which construction is adopted. For example, Petitioner mapped the prior art to the parties' joint construction of "container" as "an aggregate of files required to successfully execute a set of software applications on a computing platform" where each container is "mutually exclusive." This strategy intended to show the claims are invalid even under the Patent Owner's interpretations.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. It noted the concurrent filing of a Motion for Joinder with a petition filed by Google LLC (IPR2025-00488) against the same ’814 patent.
  • If the motion for joinder is granted, Petitioner asserted it would take an "understudy role." This would prevent an impact on the Board's finite resources and weigh against discretionary denial.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-34 of the ’814 patent as unpatentable.