PTAB

IPR2025-01201

IBM Corp v. Security First Innovations LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Securely Storing and Retrieving Data
  • Brief Description: The ’194 patent discloses methods and systems for securely storing data by performing a cryptographic operation to split a data set into a plurality of "shares." These shares are stored across multiple storage devices, and data is retrieved by identifying the fastest-responding devices necessary to retrieve a minimum number of shares for reconstruction.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over Dickinson in view of Hardjono.

  • Prior Art Relied Upon: Dickinson (WO 2001/022322) and Hardjono (Patent 6,363,481).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dickinson, which is substantially identical to the ’194 patent’s specification, discloses most claimed features. This includes a cryptographic system that splits sensitive data into undecipherable shares and distributes them across multiple independent storage facilities, with data reconstruction possible from a subset of those shares. However, Petitioner contended Dickinson does not explicitly teach all limitations, which are supplied by Hardjono. Hardjono teaches a secure storage system that uses a threshold scheme to split data and explicitly discloses identifying and retrieving shares from the "most quickly accessible" databases to improve performance. Hardjono also explicitly teaches returning the reconstructed data to the requester and enhancing security by encrypting each data share with a different key.
    • Motivation to Combine: A POSITA would combine Hardjono with Dickinson to gain predictable benefits. First, incorporating Hardjono’s teaching to select storage devices based on the fastest response time would improve the data retrieval speed and efficiency of Dickinson's system. Second, adding Hardjono’s explicit step of returning the re-created data block to the requester would complete the data retrieval workflow in Dickinson, which already performs the reconstruction. Third, applying Hardjono’s technique of using separate encryption keys for each data share would enhance the overall security of Dickinson’s system by mitigating the risk of a single key compromise.
    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success. Both references address the same technical challenge of secure, distributed data storage using compatible, software-based architectures. The combination involved applying known techniques from Hardjono (optimizing retrieval speed, completing the data return process, improving security) to the known system of Dickinson to achieve the predictable results of a faster, more functional, and more secure system.

Ground 2: Claims 2, 8, and 15 are obvious over Dickinson and Hardjono in view of Moulton.

  • Prior Art Relied Upon: Dickinson (WO 2001/022322), Hardjono (Patent 6,363,481), and Moulton (Application # US2001/0034795).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically addresses the limitations in claims 2, 8, and 15 requiring subsets of shares to be stored in physically separate "data centers." The primary combination of Dickinson and Hardjono teaches storing shares in "geographically separated data storage facilities." Petitioner introduced Moulton to explicitly bridge any potential gap between this disclosure and the "data center" limitation. Moulton discloses a distributed network storage system comprising multiple "storage nodes" that can be located in different data centers to provide geographic distribution and scalability.
    • Motivation to Combine: A POSITA would combine Moulton's teachings with the Dickinson/Hardjono system to improve scalability and capacity. Moulton teaches a globally distributed architecture that scales by placing storage nodes in various data centers. To scale the Dickinson/Hardjono system to a larger capacity, a POSITA would have been motivated to implement its "geographically separated independent data storage systems" as storage nodes within different data centers, as taught by Moulton. This combination merely applies a known technique (using data centers for distribution) to a compatible architecture.
    • Expectation of Success: Petitioner argued a POSITA would have reasonably expected success because both the base system (Dickinson/Hardjono) and the supplemental reference (Moulton) are directed to networked, distributed storage systems. Integrating Moulton's teaching would predictably improve the capacity and scalability of the Dickinson/Hardjono framework. A POSITA would have understood that Moulton's storage nodes in data centers would be readily accessible and operable within the Dickinson/Hardjono system, producing the predictable result of using storage devices in data centers.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-20 of the ’194 patent as unpatentable.