PTAB

IPR2025-01002

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 relates to systems and methods for executing software applications in isolated environments called "containers." The technology is framed as an advance over virtual machine technology by disclosing containers that share the kernel of a single underlying host operating system, thereby reducing performance overhead.

3. Grounds for Unpatentability

Ground 1: Obviousness over Osman - Claims 3, 5, 7, 11-12, 15, and 31-34 are obvious over Osman.

  • Prior Art Relied Upon: Osman (Steven Osman et al., The Design and Implementation of Zap: A System for Migrating Computing Environments, 2002).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Osman, a 2002 publication describing a system called "Zap," discloses every limitation of the challenged claims. Osman’s "pods" were presented as functionally identical to the ’814 patent’s "containers." The reference teaches a system of migrating application environments (pods) across a plurality of servers, including those with minor operating system differences. Osman’s pods are secure, isolated environments that each contain applications and associated system files, utilize the host server's kernel rather than their own, and possess a unique root file system created using a chroot command. This mapping was asserted to cover the limitations of independent claims 1, 14, and 31, from which the challenged dependent claims depend.
    • Motivation to Combine: This is a single-reference ground under 35 U.S.C. §103.
    • Expectation of Success: Not applicable for a single-reference ground.

Ground 2: Obviousness over Tucker and Bandhole - Claim 16 is obvious over Tucker in view of Bandhole.

  • Prior Art Relied Upon: Tucker (Patent 7,437,556) and Bandhole (Application # 2002/0171678).
  • Core Argument for this Ground:
    • Prior Art Mapping: Tucker described "Solaris Zones," an early containerization technology for isolating applications on a single Solaris server to enhance security and simplify deployment. Bandhole described multi-server architectures, including a system combining a Solaris server with a Linux server to provide web services. Claim 16, which depends from claim 1, adds the limitation of creating a container by "using a skeleton set of system files as a container starting point and installing applications into that set of files." Tucker was argued to teach this by disclosing the creation of zones by laying down a root file system and then installing standard application packages into it.
    • Motivation to Combine: A POSITA would combine Tucker’s well-documented security and deployment benefits for containerized applications with the known multi-server architecture of Bandhole. Specifically, a POSITA would be motivated to run the distinct services described in Bandhole (e.g., application server, database server) in separate, isolated zones as taught by Tucker to improve the overall system's security and manageability.
    • Expectation of Success: Petitioner asserted a high expectation of success. The combination involved applying Tucker's Solaris Zones to a system, like Bandhole's, that explicitly uses a Solaris server, making the technologies directly compatible and the results predictable.

Ground 3: Obviousness over Gélinas - Claim 16 is obvious over Gélinas.

  • Prior Art Relied Upon: Gélinas (Virtual Private Servers and Security Contexts, a 2002 website publication describing Linux VServer).
  • Core Argument for this Ground:
    • Prior Art Mapping: Gélinas described "vservers," another prior art container technology that provides isolated environments on Linux servers. The reference explicitly taught that vservers could run on multiple physical servers and supported different Linux distributions. Crucially for claim 16, Gélinas disclosed a method for creating a new container by copying a skeleton set of standard Linux system directories (e.g., /sbin, /bin, /etc) from the host server and subsequently installing applications using standard packages (RPMs) into those directories. Petitioner argued this directly teaches the creation method recited in claim 16.
    • Motivation to Combine: This is a single-reference ground under 35 U.S.C. §103.
    • Expectation of Success: Not applicable for a single-reference ground.

4. Key Claim Construction Positions

  • Petitioner asserted that no claim terms required explicit construction to resolve the obviousness challenges.
  • It highlighted the term "disparate computing environments" from claim 1, noting that the prior art meets the limitation under any plausible interpretation. Petitioner pointed to related litigation where the Patent Owner argued the term means "independently operable" computers and where the inventor testified it could mean computers with "different network address[es]." Petitioner argued that the prior art references disclose systems with both independently operable servers and servers with distinct network addresses.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted. It noted the concurrent filing of a Motion for Joinder with an earlier-filed IPR against the ’814 patent (IPR2025-00566, filed by Amazon.com, Inc.).
  • Petitioner stated that if the motion for joinder is granted, it would accept an "understudy role," thereby minimizing any impact on the Board's finite resources and promoting efficiency.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 3, 5, 7, 11-12, 15-16, and 31-34 of the ’814 patent as unpatentable.