PTAB

IPR2025-01490

FedEx Corp v. Hewlett Packard Co

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: STORAGE DEVICE PERFORMANCE MONITOR
  • Brief Description: The ’832 patent describes a system that monitors the performance of a computer storage device. It uses a filter driver to intercept communications (e.g., commands, errors) between a computer system and the storage device, analyzes the communications against performance thresholds, and initiates a response like reallocating data upon detecting a performance decline.

3. Grounds for Unpatentability

Ground 1: Obviousness over Wolf - Claims 1-4, 7-10, and 12-25 are obvious over Wolf.

  • Prior Art Relied Upon: Wolf (Patent 5,287,363).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wolf, which was not considered during prosecution, teaches all limitations of the independent claims. Wolf discloses a "disk-call interceptor" (DCI) that functions like the claimed filter driver to intercept communications between an operating system and a storage device. Wolf's DCI gathers performance data such as data transfer times, logs it, and an analysis program compares this data against a "table of acceptable times" (a threshold) to detect performance degradation. In response to detecting a defective area, Wolf teaches taking "remedial measures," including moving data to a "good area," which maps directly to the claimed "reallocating" of data to enhance continued operation.
    • Key Aspects: Petitioner contended that Wolf squarely teaches the core features added during prosecution to overcome prior art, namely intercepting communications and automatically reallocating data in response to a detected performance decline.

Ground 2: Obviousness over Wolf and Kamiyama - Claims 5-6, 10, and 26 are obvious over Wolf in view of Kamiyama.

  • Prior Art Relied Upon: Wolf (Patent 5,287,363), Kamiyama (Patent 5,584,018).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that Wolf teaches the base monitoring and reallocation system, while Kamiyama teaches the specific analysis claimed in this set of dependent claims. Kamiyama discloses calculating "access frequencies" and "access duration" of data to distinguish between frequently and rarely accessed data for relocation, which directly corresponds to the limitations of claims 5, 6, and 26 related to determining access location, frequency, and duration based on intercepted communications. Claim 10's limitation of reallocating based on "usage patterns" is met by Kamiyama's teaching of relocating data based on access frequency.
    • Motivation to Combine: A POSITA would combine Kamiyama's teachings with Wolf's system to enhance it. Since Wolf already analyzes historical data to make relocation decisions, incorporating Kamiyama's more specific metrics (access frequency and duration) would have been a predictable way to improve the system's effectiveness and to better evaluate how close a storage sector is to failure. Another stated motivation was to use these metrics to equalize wear across the storage media, a known benefit taught by Kamiyama.
    • Expectation of Success: The combination involved applying a known analysis technique from Kamiyama to a known monitoring system from Wolf to achieve the predictable result of improved performance monitoring. Petitioner argued this was well within the skill of a POSITA.

Ground 3: Obviousness over Wolf and Woods - Claims 9 and 11-21 are obvious over Wolf in view of Woods.

  • Prior Art Relied Upon: Wolf (Patent 5,287,363), Woods (Patent 5,881,311).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground argued that while Wolf provides the core monitoring system, Woods supplies the additional remedial actions of "backing-up" data (claim 9) and "defragmenting" the storage device (claim 11). Woods explicitly teaches data storage management systems that integrate both automatic backup and defragmentation algorithms that are triggered in response to performance-hindering conditions, such as fragmentation exceeding a certain percentage. Woods also teaches including a graphical user interface for reporting performance and recommendations to a user, which maps to the limitation of claim 21.
    • Motivation to Combine: A POSITA, seeking to improve the remedial actions available in Wolf's system, would look to prior art like Woods. It would have been obvious to implement the automatic backup and defragmentation taught by Woods as additional, more robust responses to the declining performance detected by Wolf's system. Wolf's broad disclosure of responding to potential failures would have prompted a POSITA to seek such specific, well-known solutions for data protection and performance improvement.
    • Expectation of Success: Petitioner asserted that success was expected because the combination applies known techniques (Woods' automatic backup and defragmentation) to a known system (Wolf's performance monitor) to achieve the predictable benefit of a more comprehensive data protection and performance enhancement system.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-26 of Patent 7,120,832 as unpatentable.