throbber
Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`APPENDIX A
`
`
`
`Each Claim as a Whole
`
`Perlman: Discloses all of the elements and all of the functions of each claim
`arranged as they are arranged in the claim. See below. (See generally ’820,
`Abstract, 1:1-9, 3:61-4:4, 8:52-9:2, claims 1, 4-6, 8, 10). E.g.: “The invention
`comprises a mechanism for efficiently synchronizing the contents of databases
`stored on nodes of a computer network to ensure that those contents are consistent.
`Generally, the mechanism comprises a database identifier generated by a node of
`the computer network and distributed to other receiving nodes coupled to the
`network. The database identifier is uniquely representative of the contents of the
`distributing node’s database and the receiving nodes compare this unique identifier
`with their own generated database identifiers to determine if the identifiers, and
`thus their databases, are consistent and synchronized.” (id., 3:61-4:4).
`
`Yohe: Except as otherwise noted, discloses all of the elements and all of the
`functions of each claim arranged as they are arranged in the claim. See below.
`(See generally ’943, 2:41-61, claims 1, 6, 8). E.g.: “The performance gains
`realized by the present invention are derived from the fact that remote clients tend
`to repetitively access the same data by performing file reads. If a copy of the data
`can be stored in the permanent storage memory of the remote client computer and
`
`also verified to be current when it is subsequently retrieved, this will improve
`performance significantly. This is because it requires much less bandwidth to
`verify a block of data than it would to actually transfer a block of data.” (id., 4:32-
`40).
`
`Santos: Except as otherwise noted, discloses all of the elements and all of the
`
`
`
`
`
`
`
`1 2 3 4 5 6 7 8 9
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`10
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`11
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`12
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`13
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`14
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`15
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`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 1 of 19
`
`MICROSOFT
`
`EXHIBIT 1001
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`functions of each claim arranged as they are arranged in the claim. See below.
`(See generally Santos, Figs. 4, 5). Sender/Compressor “sends a packet to the
`decompressor containing the TCP/IP header HdrB and the fingerprint H(X).”
`(Santos § 3.2.1, ¶ 3). Receiver/Decompressor “determines the payload X that is
`indexed by H(X) in its cache.” (Santos § 3.2.1, ¶ 5). If decompressor does not
`find H(X) in its cache, i.e., “if the decompressor receives a fingerprint packet
`{HdrB, H(X)} for which H(X) is not a valid entry in its cache, it sends the entire
`fingerprint packet (including the header) back to the compressor as a rejection
`packet.” (Santos § 3.2.2, ¶ 3). “Compressor sends the complete TCP/IP packet
`{HdrB, X} to the decompressor, which processes the packet as if it were receiving
`a new TCP/IP packet” (Santos § 3.2.2, ¶ 3), i.e., “upon receiving a TCP/IP packet
`forwarded over the channel, the decompressor also computes H(X), and stores X
`in its cache, indexed by H(X).” (Santos § 3.2.1, ¶ 2).
`
`1. A system for data access
`in a packet-switched
`network, comprising:
`
`Perlman: Access to data and transmission of data packets over computer
`networks including packet-switched networks using the OSI seven-layer protocol
`model. (’820, Abstract, 1:1-9, 1:16-23, 1:67-2:3, 7:12-22, 8:52-9:2, Fig. 2).
`
`Yohe: “An apparatus for increased data access in a network” (’943, 2:41-42),
`such as the world wide web (id., 4:23-27) or other wide area network (id., Fig. 2),
`using “packet[s]” (id., 8:24-25). (See id., title, Abstract, 1:12-15, 2:43-46, 2:51,
`2:54-57, 3:8-21, 4:22-24, 5:45-50, 5:59-60, 6:22-23, Fig. 2, claim 1).
`
`
`
`
`
`Santos: A system for transferring data over the Internet or other packet-switched
`network for access to such data at client or server computers. (Santos § 1, ¶ 6, § 6,
`¶ 1, Abstract).
`
`
`
`1 2 3 4 5 6 7 8 9
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`10
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`11
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`12
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`13
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`14
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`15
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`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 2 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`(a)* a sender/computer
`including
`
`{* - reference labels added
`throughout this claim
`listing}
`
` (i) an operating unit,
`
`Perlman: Each computer is capable of sending information over the network.
`The “a” sender/computer includes at least designated router R4. (See ’820, 5:39-
`53, 7:24-30, 8:60-9:2, Fig. 2).
`
`
`
`Yohe: Each computer is capable of sending information over the network. The
`“a” sender/computer is, e.g., the “file server computer 18” combined with the
`“cache verifying agent 54” residing on the “cache verifying computer 14” or
`“communication server 16.” (’943, 4:42-44; Fig. 2). Alternatively, it is the cache
`verifying computer integral with the communications server (id., Abstract, 5:33-
`36, claims 1, 7 (“said cache verifying computer has said communications server
`integrally formed therewith”)).
`
`
`Santos: Each computer is capable of sending information over the network. Each
`computer acts as both a sender (compressor) of packets and a receiver
`(decompressor) of packets. (See Santos § 2.5, ¶ 2, § 3.1, ¶ 1, § 3.4, ¶ 1, Abstract, ¶
`2).
`
`Perlman: Sender is a “general-purpose computer[]” (’820, 5:41-43) with an
`“operating system” (id., 5:49) and ability to operate. (See id., 1:11-25, 5:38-53,
`8:57-9:2). The ’717 does not describe anything reasonably called an “operating
`unit” which is not also disclosed in this reference.
`
`Yohe: Sender has an operating system and ability to operate. (See ’943, 2:46-47,
`5:17-18, 5:22-23, claim 1). The ’717 does not describe anything reasonably called
`an “operating unit” which is not also disclosed in this reference.
`
`
`
`
`
`
`
`1 2 3 4 5 6 7 8 9
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`10
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`11
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`12
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`13
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`14
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`15
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`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 3 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
` (ii) a first memory,
`
`Santos: Sender implementation is an “Intel-based PentiumII” computer running
`Linux operating system (Santos § 3.4, ¶ 1) and ability to operate. (Id., §§ 3.4, 4).
`The ’717 does not describe anything reasonably called an “operating unit” which
`is not also disclosed in this reference.
`
`Perlman: Each computer typically is a “general-purpose computer” and includes
`“a memory unit 204” which “may comprise storage locations typically composed
`of random access memory (RAM) devices, which are addressable by the CPU 202
`and network adapter 206.” (’820, 5:41-49, Fig. 2). (See id., ’820, 8:52-9:2).
`
`Yohe: The cache verifying computer includes “a first memory” (’943, 2:47) (e.g.,
`RAM) as does the file server computer. (See id., Abstract, 2:46-47, 5:34-36,
`claims 1, 6, 8).
`
` (iii) a permanent storage
`memory and
`
`Santos: Sender implementation includes 128MB of RAM. (Santos § 3.4, ¶ 1).
`
`Perlman: Each computer typically is a “general-purpose computer” with an
`operating system (only portions of which are resident in RAM), and which
`implements a particular protocol, necessarily using software stored in permanent
`memory. (’820, 3:14-21, 5:41-52, 8:52-9:2, Fig. 2).
`
`Yohe: File server includes “a DD [(disk driver)] 78 and a PSD [(permanent
`storage disk)] 80.” (’943, 5:22-24). (See id., Abstract, 2:47-49, 3:5-7, 3:22-24,
`claims 1, 6, 8). The cache verifying computer also necessarily has a permanent
`memory in order to store its boot-up code, “operating system,” LAN Driver 68,
`Network Transport Layer 66, etc. (Id., 5:14-21, 5:34-36, Fig. 2).
`
`
`
`
`
`
`
`
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`1 2 3 4 5 6 7 8 9
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`10
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`11
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`12
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`13
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`14
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`15
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`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 4 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`
`Santos: E.g., its general-purpose PentiumII PC necessarily has a ROM and a hard
`disk storing, e.g., its Linux operating system and “compressor” and
`“decompressor” code. (Santos § 2.5, ¶ 2). Implementation’s 128MB RAM is
`substantially smaller than the 200MB cache available for each direction of network
`traffic. (See id., § 3.1, ¶ 1).
`
` (iv) a processor and a
`
`Perlman: Each “general-purpose computer” “typically comprises a central
`processing unit (CPU) 202.” (’820, 5:41-44, Fig. 2). (See id., ’820, 8:52-9:2).
`
`Yohe: File server computer includes “a processor” (’943, claim 8) and cache
`verifying computer includes “a processor” (id., 2:47) and cache verifying agent
`could be “a stand alone processor with its own memory and operating system” (id.,
`5:34-36). (See id., Abstract, claim 1).
`
`
`
`
`
`Santos: Sender implementation is an “Intel-based PentiumII” computer running
`Linux operating system. (Santos § 3.4, ¶ 1).
`
`(b) remote
`receiver/computer including
`
`Perlman: Each computer is capable of receiving information over the network.
`Remote nodes on a computer network receive data from other network nodes, e.g.,
`routers R1-R3 and R5-R6. (’820, 5:39-43, 7:24-30, 8:60-9:2, Fig. 2).
`
`Yohe: Each computer is capable of receiving information over the network. “A
`network computer system 10 having at least one remote client computer 12.”
`(’943, 4:42-43). (See id., Abstract, Fig. 2, claims 1, 8).
`
`
`
`
`
`
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`1 2 3 4 5 6 7 8 9
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`10
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`11
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`12
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`13
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`15
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`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 5 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
` (i) an operating unit,
`
` (ii) a first memory,
`
` (iii) a permanent storage
`memory and
`
`Santos: Each computer is capable of receiving information over the network.
`(E.g., Figs. 3-5).
`
`Perlman: Receiver is a “general-purpose computer[]” (’820, 5:41-43) with an
`“operating system” (id., 5:49) and is able to operate. (See id., 1:11-25, 5:38-53,
`8:57-9:2).
`
`
`
`Yohe: Remote client computer includes “an operating system” and is able to
`operate. (’943, 2:51-52). (See id., Abstract, 4:58-59, claims 1, 8).
`
`
`Santos: Receiver implementation is an “Intel-based PentiumII” computer running
`Linux operating system (Santos § 3.4, ¶ 1) and is able to operate. (Id., §§ 3.4, 4).
`
`Perlman: Each computer typically is a “general-purpose computer” with “a
`memory unit 204” which “may comprise storage locations typically composed of
`random access memory (RAM) devices, which are addressable by the CPU 202
`and network adapter 206.” (’820, 5:41-49, Fig. 2). (See id., 8:52-9:2).
`
`
`
`Yohe: Remote client computer includes “a first memory.” (’943, 2:52). (See id.,
`4:61-62, Abstract, claims 1, 8).
`
`
`Santos: Receiver implementation includes 128MB of RAM. (Santos § 3.4, ¶ 1).
`
`Perlman: Each computer typically is a “general-purpose computer” with an
`operating system (only portions of which are resident in RAM), and which
`implements a particular protocol, necessarily using software stored in permanent
`memory. (’820, 3:14-21, 5:41-52, 8:52-9:2, Fig. 2).
`
`
`
`1 2 3 4 5 6 7 8 9
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`10
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`11
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`12
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`13
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`14
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`15
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`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 6 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`
`
`Yohe: Receiver includes a “disk driver (DD) 32 and permanent storage disk
`(PSD) 34.” (’943, 4:62-63). (See id., 4:34-38, claim 6).
`
`
`Santos: E.g., its general-purpose PentiumII PC necessarily has a ROM and a hard
`disk storing, e.g., its Linux operating system and “compressor” and
`“decompressor” code. (Santos § 2.5, ¶ 2). Implementation’s 128MB RAM is
`substantially smaller than the 200MB cache available for each direction of network
`traffic. (See id., § 3.1, ¶ 1).
`
` (iv) a processor,
`
`Perlman: Each “general-purpose computer” “typically comprises a central
`processing unit (CPU) 202.” (’820, 5:41-44, Fig. 2). (See id., ’820, 8:52-9:2).
`
`(c) said sender/computer
`and said receiver/computer
`communicating through said
`network;
`
`
`
`Yohe: Remote client computer includes “a processor.” (’943, 2:51-52). (See id.,
`Abstract, claims 1, 8).
`
`
`Santos: Receiver implementation is an “Intel-based PentiumII” computer running
`Linux operating system. (Santos § 3.4, ¶ 1).
`
`Perlman: Routers or other network nodes communicate over the network, e.g.,
`using an OSI protocol model. (’820, 1:1-9, 1:16-23, 1:67-2:3, 5:38-61, 7:12-22,
`8:52-9:2, Fig. 2).
`
`Yohe: Server-side computer(s) communicate with the remote client computer
`through the network. (’943, 2:54-57, 4:51-52).
`
`
`
`
`
`
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`1 2 3 4 5 6 7 8 9
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`11
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`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 7 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`(d) said sender/computer
`further including means for
`creating digital digests on
`data;
`
`Santos: Each node communicates packets over the Internet or other packet-
`switched network. (Santos § 1, ¶ 6, § 3.1, ¶ 1, § 3.2.2, ¶ 3, § 3.4, ¶ 1, § 6, ¶ 1,
`Figs. 3, 7).
`
`Perlman: Each network computer calculates a “unique, fixed-length digest
`‘signature,’” e.g., a 128-bit “cryptographic message digest” or CRC calculated
`from database data of arbitrary size, including fragments of any number and size.
`(’820, Abstract, 4:13-20, 5:2-5, 7:15-22, 7:24-30, 7:36-49, 7:60-65, 8:49-9:2,
`claims 1 (“a database identifier generated by each node of the computer network”),
`4-6, 8, 10).
`
`Yohe: Cache verifying computer calculates “a signature of the data characteristic
`of one of a file and [file-system] directory” (’943, 2:47-51) and includes “a BSG
`[(block signature generator)] 56 (of the type described herein), a directory
`signature generator (DSG) 57…” (id., 5:14-16) which use MD5 or CRC to
`calculate these signatures (id., 7:19-8:3, 8:7-9) from data of arbitrary length (id.,
`3:19). (See id., 5:14-17, 5:33-36, 7:24-25, 11:56-12:65, 13:36-40, 13:65-67, 14:1-
`12, Fig. 2, Fig. 8, step 354, Figs. 15, 16, claims 1, 8).
`
`
`
`
`
`Santos: Each computer’s compressor module calculates a fixed-size (16-byte)
`MD5 or other hash value (fingerprint) from packet payload data of arbitrary size
`(Santos § 2.4, ¶¶ 1-2). (See id., § 3, ¶ 4, § 3.1.2, ¶ 1, § 3.2.1, ¶ 2, § 3.4, ¶¶ 1-3, § 4,
`¶ 1, Figs. 4-5).
`
`(e) said receiver/computer
`further including
`
`See above. (A5:11).
`
` (i) a network cache
`
`Perlman: The receiver stores in memory “only the most recently received” data it
`
`
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`1 2 3 4 5 6 7 8 9
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`11
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`12
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`13
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`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 8 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`memory and
`
`receives from sender nodes over a network and later uses that stored network-
`received data, rather than re-requesting it over the network—if the fingerprint
`comparison operation indicates that the data has not been changed at its remote
`source. (’820, 3:12-30, 4:63-5:5, 8:52-9:2).
`
`
`
`Yohe: Each receiver has a “cache memory” (’943, 2:52), including on a
`“permanent storage disk” (id., 14:40-15:3, 15:24-33), which “contains the most-
`recently-used blocks of data read from a remote file server” (id., 3:13-18), and a
`“RAM based disk cacher (RBDC) 30” (id., 4:60-62) and “network file cacher 42”
`(id., 4:66-5:1). (See id., Abstract, Fig. 2, claims 1, 6, 8).
`
`Santos: Each receiver has a “network-based cache” (e.g., “dictionary caches
`using hash table structures with a least-recently-used replacement strategy”
`(Santos § 3.4, ¶ 3)) and “cache module” (id., § 3.1.2, ¶¶ 1-2). The receiver stores
`in cache the data packet payloads it receives over a network, and re-uses that
`network-received data rather than receiving a redundant copy over the network—if
`a fingerprint comparison validates that cached data. (See id., § 1, ¶ 3, § 3, ¶ 1, §
`3.1.2, ¶ 3, § 3.2.1, ¶ 2, § 6, ¶ 1, Fig. 3).
`
`
`
` (ii) means for creating
`digital digests on data in
`said network cache
`memory; and
`
`Perlman: Each receiver has an ability to calculate a “unique, fixed-length digest
`‘signature’”, e.g., a 128-bit “cryptographic message digest” or CRC calculated
`from its database data of arbitrary size. (’820, Abstract, 4:13-20, 4:24-30, 7:15-22,
`7:24-30, 7:36-49, 7:60-65, 8:31-36, 8:52-9:2, claims 1, 4-6, 8).
`
`Yohe: Each remote client computer includes “means for performing an operation
`on data stored in the cache memory to produce a signature of the data” (’943, 2:53-
`54; see id., 14:53-57), including “a block signature generator (BSG) 44” (id., 4:66-
`
`
`
`
`
`1 2 3 4 5 6 7 8 9
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`10
`
`11
`
`12
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`13
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`14
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`15
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`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 9 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`5:5) capable of creating CRC or MD5 hashes (id., 13:36-39) on data in the
`receiver’s cache (id., 6:8-26). (See id., Abstract, Fig. 2, claims 1, 8).
`
`Santos: Each receiver’s decompressor module has an ability to calculate a fixed-
`size (16-byte) MD5 or other hash (fingerprint) on each arbitrary-size packet
`payload it receives (subject to its classification filter) which it uses as an index for
`that payload in a hash table implementation of the cache, thereby “using caches of
`recently seen data at both ends of the link to maintain the dictionary and encode
`and decode these tokens.” (Santos § 3, ¶ 1). (See id., § 2, ¶ 1, § 2.4, ¶¶ 1-2, § 3, ¶
`4, § 3.1.2, ¶ 1, § 3.2.1, ¶ 2, § 3.4, ¶¶ 1-3, Figs. 4-5).
`
`
`
` (iii) said
`receiver/computer including
`means for comparison
`between digital digests.
`
`Perlman: Each receiver has an ability to “compare this unique identifier with
`their own generated database identifiers to determine if the identifiers, and thus
`their databases, are consistent and synchronized.” (’820, 3:67-4:4, Abstract). (See
`id., 4:24-32, 4:53-57, 7:46-52, 8:43-49, 8:63-9:2, claims 1, 8, 12).
`
`Yohe: Each receiver includes a “directory signature comparator (DSC) 46” (’943,
`5:1-3) “for comparing the signatures of data with one another to determine
`whether the signature of data of the remote client is valid.” (’943, 2:41-61). (See
`id., 2:58-61, 8:9-11, 8:13-21, Abstract, Fig. 2, claims 1, 8).
`
`
`
`
`
`Santos: Each receiver has “a dictionary cache[] using hash table structures”
`(Santos § 3.4, ¶ 3) in which the index is a hash (fingerprint) H(X) of the array
`element X. The “lookup” mechanism of checking whether a newly calculated
`fingerprint already exists in the cache requires a comparison of that new
`fingerprint to H(X) indices of the array of {H(X), X} pairs, for a match. (See id., §
`
`
`
`1 2 3 4 5 6 7 8 9
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`
`11
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`12
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`13
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`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 10 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`3.1.2, ¶ 5, § 3.2.1, ¶ 2, § 3.2.2, ¶ 3, Figs. 4, 5).
`
`3. The system as claimed in
`claim 1, wherein said
`receiver/computer further
`includes means for storing
`said created digital digest in
`its first or permanent
`memory.
`
`Perlman: Each receiver has an ability to store in its cache the created database
`identifiers (e.g., cryptographic message digests) it receives from the sending
`computer. (’820, 4:27-30; 7:66-8:1, 8:52-9:2, claims 10-13, 17).
`
`Yohe: Each receiver has an ability to store in its permanent-memory cache the
`created signatures received from the sender over the network. (’943, 1:39-46, 3:5-
`7, 3:13-18, 4:60-63, 8:20-21, Figs. 2, 15, claims 1, 6). And, each receiver
`necessarily stores in RAM signatures calculated by its BSG 44 (id., Fig. 2).
`
`
`
`
`
`Santos: Each receiver has an ability to store the fingerprint H(X) it calculates as
`an index for that payload X in a hash table implementation of the cache. (Santos §
`3, ¶ 1). (See id., § 2.4, ¶¶ 1-2, § 3, ¶ 4, § 3.1.2, ¶ 1, § 3.2.1, ¶ 2, § 3.4, ¶¶ 1-3, Figs.
`4-5).
`
`See preamble of claim 1. (A2:9).
`
`See same elements in claim 1. (A3:2 – A7:12).
`
`10. A system for data access
`in a packet-switched
`network, comprising:
`
`(a) a sender/computer
`including (i) an operating
`unit, (ii) a first memory, (iii)
`a permanent storage
`memory and (iv) a
`processor and a (b) remote
`receiver/computer including
`
`
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`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 11 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`(i) an operating unit, (ii) a
`first memory, (iii) a
`permanent storage memory
`and (iv) a processor, (c) said
`sender/computer and said
`receiver/ computer
`communicating through a
`network;
`
`(d) said sender/computer
`further including means for
`creating digital digests on
`data, and
`
`(e) said receiver/computer
`further including
`
` (i) a network cache
`memory,
`
` (ii) means for storing a
`digital digest received from
`said network in its
`permanent storage memory
`and
`
`See claim 1, element (d). (A8:4).
`
`See claim 1, element (e). (A8:14).
`
`See claim 1, element (e)(1). (A8:15).
`
`Perlman: Each receiver is able to store the database identifiers it receives from
`the network in its database. (’820, 4:27-30; 7:66-8:1, 10:34-37, claims 10-13).
`Perlman discloses that its “mechanism described herein may be used in any type of
`distributed system requiring efficient synchronization of the contents of databases
`stored on nodes of a computer network.” (’820, 8:52-9:2). That “any type”
`includes the distributed system of Yohe in which the receiving node’s cache is in
`permanent storage. (See Exhibit 1007, 12:8-13:13). Also, Perlman’s general-
`purpose computer is capable of storing data in its permanent memory and thus is
`capable of storing a “digital digest” in its permanent memory. (Id.)
`
`
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`
`
`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 12 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`
`
`Yohe: Each receiver is able to store in its cache in its permanent memory
`signatures received from the sender over the network. (’943, 8:20-21, Fig. 15).
`(See id., 3:5-7, 3:13-18, 4:60-63, Fig. 2, claims 1, 6).
`
`
`Santos: Each receiver is able to store the fingerprint H(X) it calculates as an index
`for that payload X in a hash table implementation of the cache. (Santos § 3, ¶ 1).
`(See id., § 2.4, ¶¶ 1-2, § 3, ¶ 4, § 3.1.2, ¶ 1, § 3.2.1, ¶ 2, § 3.4, ¶¶ 1-3, Figs. 4-5).
`This stored fingerprint H(X) is the same value as the H(X) fingerprint the receiver
`receives from the sender over the network. (Id., Figs. 4-5). The general-purpose
`computer implementation is capable of storing this value in permanent memory.
`
`See claim 1, element (e)(3). (A10:7).
`
`See preamble of claim 1. (A2:9).
`
`See claim 1, element (a)(i)-(iv). (A3:2 - A5:5).
`
`See claim 1, element (c). (A7:12).
`
` (iii) means for comparison
`between digital digests.
`
`11. A method performed by
`a sender/computer in a
`packet-switched network for
`increasing data access,
`
`(a) said sender/computer
`including an operating unit,
`a first memory, a permanent
`storage memory and a
`processor and
`
`(b) said sender/computer
`being operative to transmit
`
`
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`
`
`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 13 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`data to a receiver/computer,
`the method comprising the
`steps of:
`
`(c) creating and transmitting
`a digital digest of said data
`from said sender/computer
`to said receiver/computer;
`
`Perlman: See above. (A8:4). Sender calculates its database identifier(s) (’820,
`4:13-20, 7:15-22, 7:24-30, 7:36-49, 7:60-65, 8:52-9:2, claim 8) and sends it or
`them to the receiver nodes (id., 3:64-66, 4:9-13, 4:43-47, 4:50-53, 7:15-22, 8:14-
`17, 8:25-28, 8:60-63, claim 10).
`
`(d) receiving a response
`signal from said
`receiver/computer at said
`sender/computer,
`
`Yohe: See above. (A8:4). Sender creates and sends a CRC or MD5 directory
`signature of directory data to the receiver computer. (’943, 7:19-8:4, 8:8-9, 8:20-
`21, Fig. 15, claim 8).
`
`Santos: See above. (A8:4). Each sender calculates a fingerprint H(X) (Santos §
`2.4, ¶¶ 1-2, § 3, ¶ 4, § 3.1.2, ¶ 1, § 3.2.1, ¶¶ 2-3, § 3.22, ¶ 3, § 3.4, ¶¶ 1-3, Figs. 4-
`5) and transmits it to a receiver (id., § 3.2.1, ¶ 3, Figs. 4-5).
`
`Perlman: Receiver, when it finds no match for the received database identifier,
`sends to sender a request for entire CSNP (’820, 4:21-32, 8:1-6) or requests for
`each particular low-level identifier it could not match (id., 8:17-21, 8:32-42).
`
`
`
`
`
`
`
`Yohe: Receiver, when it finds no match for the received signature, sends to
`sender a request for each sub-object of the directory. (’943, 8:11-19; Figs. 15, 16).
`
`Santos: Receiver, when it finds no match for the received H(X) fingerprint, sends
`to sender a response signal rejection packet (HdrB, H(X)) request for the packet
`
`
`
`
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`
`
`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 14 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`payload data X (Santos § 3.2.2, ¶ 3, Fig. 5), indicating that “H(X) is not a valid
`entry in its cache” (id., § 3.2.2, ¶ 3).
`
`See above. (A14:10). The “positive” and “partial” signals are optional and thus
`have no patentable weight, i.e., need not be disclosed in a prior art reference.
`
`Perlman: This conditional step has no patentable weight. In response to the
`receiver’s request, the sender sends the requested full CSNP or CSNP fragment.
`(’820, 4:35-46; 8:17-21).
`
`Yohe: This conditional step has no patentable weight. In response to the
`receiver’s request, the sender sends each sub-object of the directory to the receiver.
`(’943, 8:13-21, Figs. 15-16).
`
`
`
`
`
`Santos: This conditional step has no patentable weight. In response to the
`receiver’s request, the sender sends the requested payload data X to the receiver.
`(Santos § 3.2.2, ¶ 3 and Fig. 5).
`
`See above. (A14:4).
`
` (i) said response signal
`containing a positive, partial
`or negative indication signal
`for said digital digest, and
`
`(e) if a negative indication
`signal is received,
`transmitting said data from
`said sender/computer to said
`receiver/computer.
`
`12. The method as claimed
`in claim 11, wherein said
`sender/computer creates
`said digital digest for the
`data before transmitting it to
`said receiver/computer.
`
`14. The method as claimed Perlman: This conditional step has no patentable weight. Sender bundles in a
`
`
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`
`
`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 15 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`in claim 12, wherein, when
`a plurality of data objects is
`to be sent, a digital digest is
`sent for each of said data
`objects and a response
`signal is sent containing a
`separate indication signal
`for each of said data objects.
`
`22. A method for increased
`data access performed by a
`receiver/computer in a
`packet-switched network,
`
`(a) said receiver/computer
`including an operating unit,
`a first memory, a permanent
`storage memory, a
`processor and a network
`cache memory, said method
`comprising the steps of:
`
`(b) receiving a message
`containing a digital digest
`from said network;
`
`single message separate low-level database identifiers for separate database
`fragments and for each one the receiver does not match it returns a request for that
`fragment. (’820, 8:7-42, 8:52-9:2, Fig. 7).
`
`Yohe: This conditional step has no patentable weight. In response to a second
`Directory Request 115 for a second directory, the above-identified method is
`performed again. (’943, 7:6-8, Figs. 15-16).
`
`Santos: This conditional step has no patentable weight. In response to a second
`packet, the above-identified method is performed again. (Santos, Figs. 4-5).
`
`See preamble of claim 1. (A2:9, A5:11).
`
`
`
`
`
`See claim 1, elements (b)(i)-(iv). (A5:11-7:7).
`
`See claim 11, element (c). (A14:3).
`
`
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`
`
`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 16 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`(c) searching for data with
`the same digital digest in
`said network cache
`memory,
`
`Perlman: Each receiver looks for data in its cache that has the same database
`identifier as that received from the sender, by “compar[ing] this unique identifier
`with their own generated database identifiers to determine if the identifiers, and
`thus their databases, are consistent and synchronized.” (’820, 3:67-4:4, Abstract).
`(See id., 4:24-32, 4:53-57, 7:46-52, 7:60-63, 8:22-49, 8:57-9:2, claims 8, 10, 12-
`13).
`
`Yohe: Each receiver looks for data in its cache that has the same signature as that
`received from the sender, using a “directory signature comparator (DSC) 46”
`(’943, 5:1-3) “for comparing the signatures of data with one another to determine
`whether the signature of data of the remote client is valid” (id., 2:41-61), i.e., to
`“determine[] whether the signature of data match” (id., 13:34-35). (See id., 2:58-
`61, 8:9-11, 8:13-21, 14:40-15:3, Abstract, Fig. 15, claims 1, 8).
`
`
`
`
`
`Santos: Each receiver searches its network-based cache for an H(X) value that
`matches the H(X) value received over the network from the sender. (Santos, Fig. 4
`(“lookup(H(X)) = X), Fig. 5 (“H(X) not found). (See id., § 3.1.2, ¶ 5, § 3.2.1, ¶ 5,
`§ 3.2.2, ¶ 3, § 3.4, ¶ 3, Figs. 4-5).
`
`This conditional step has no patentable weight. See claim 11, element (d).
`(A14:10).
`
`(d) if data having the same
`digital digest as the digital
`digest received is not
`uncovered, forming a
`negative indication signal
`and transmitting it back
`through said network; and
`
`
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`
`
`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 17 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`(e) creating a digital digest
`for data received from said
`network cache memory.
`
`23. The method as claimed
`in claim 22, further
`comprising searching in
`predetermined locations in
`said permanent storage
`memory for data with a
`digital digest substantially
`identical to the digital digest
`received from said network.
`
`Perlman: “[E]ach receiving router calculates an identifier based on the entirety of
`its database.” (’820, 4:53-57). (See id., 4:24-27, 7:60-65, claims 1, 4-5, 8, 10, 15).
`
`Yohe: Receiver invokes its “BSG [block signature generator] 44 to generate a
`signature of data.” (’943, 6:8-23; Fig. 6). (See id., claim 8).
`
`Santos: Each receiver’s decompressor retrieves data X from its network-based
`cache memory to transmit that data X on the network (Santos §§ 3.2.1, 3.2.2, Figs.
`4-5), and also calculates a fingerprint H(X) on that same data X (id.). Each
`receiver’s compressor calculates H(X) on data X already stored in its cache. (Id.)
`
`Perlman: Receiver performs multiple searches in particular predetermined fields
`of its cache, i.e., “examine and compare the contents of these fixed length fields”
`(’820, 7:48-52), in response to a message containing “a” “digital digest,” first for
`the high-level identifier and then for low-level identifiers sent in the same
`message. (’820, 8:7-42, claim 18). (See ’820, 8:52-9:2).
`
`Yohe: Receiver searches multiple times for the same data in particular
`predetermined fields of its cache and tracks the ratio of successful hits therefor.
`(’943, 14:18-32, 15:4-10, 16:23-35, Fig. 2, item 45, claims 8-9).
`
`
`
`
`
`
`
`
`
`Santos: Per its rejection handling protocol, when receiver receives H(X) from
`sender it looks in particular predetermined fields of its cache for H(X), X; if not
`found it requests X; when it receives X it enters it, indexed by H(X), in its cache,
`necessitating an operation that searches for an entry with the same H(X) already in
`
`
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`
`
`Appendix A to Microsoft’s Petition for Inter Partes Review of U.S. Patent No. 6,757,717
`Page 18 of 19
`
`

`

`Claim Element-BRI
`
`PERLMAN & YOHE & SANTOS CLAIM MAPPINGS
`
`the cache. (Santos § 3.2.1, ¶ 5, § 3.2.2, ¶ 3, § 3.4, ¶¶ 1, 3, Figs. 4-5).
`
`24. The method as claimed
`in claim 22, wherein
`
`See above. (A16:8).
`
`(a) a plurality of digital
`digests for different data
`objects is received in the
`same message and
`
`(b) an ind

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