IPR2012-00026, No. 2007 Exhibit - Hearing Demonstrative Proxyconns Opposition to Petition for Inter Partes Review of US Pat 717 (P.T.A.B. Nov. 13, 2013)

Patent Owner’s Opposition to
`Petition for Inter Partes Review of
`U.S. Patent 6,575,717
`
`IRP2012-00026
`IPR2013-00109
`
`Hearing Date: November 18, 2013
`
`1
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Grounds of Review
`
`• Anticipation by Perlman of claims 1, 3 and 22-24
`• Anticipation by Yohe of claims 1, 3, 6, 7, 10, 22 and 23
`• Obviousness over the combination of Perlman and
`Yohe of claims 1, 3, 10 and 22-24
`• Anticipation by Santos of claims 1, 3 and 22-23
`
`• Anticipation by DRP of claims 6, 7, 9, 11, 12 and 14
`• Obviousness over the combination of Mattis and DRP
`of original claims 6, 7, 9, 11, 12 and 14
`
`2
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Petition’s Cited Art
`
`• Perlman – a synchronization mechanism
`• Yohe – a file oriented caching system
`• Santos – intermediate compressor/decompressor
`• DRP – an index protocol
`• Mattis – a file storage method
`
`3
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Construction of Claim Terms
`
`1. Data Access
`– Obtaining data on a remote computer network, in
`response to a request from the client.
`
`Ex.1002 at 1:18-26
`
`Ex.1002 at 7:65-67
`
`4
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`PROXYCONN
`DEM. EX. 2007
`
`

`Construction of Claim Terms
`
`2. Permanent Storage Memory
`– Non-volatile memory that allows reading and
`writing of data.
`
`Ex.1002 at 7:38-40
`
`5
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Construction of Claim Terms
`
`3. Sender/Computer and Receiver/Computer
`
`Ex.1002 at 1:18-26
`
`Ex.1002 at 2:14-15
`
`Ex.1002 at 2:44-47
`
`Ex.1002 at 4:41-45
`
`6
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`PROXYCONN
`DEM. EX. 2007
`
`

`Construction of Claim Terms
`
`3. Sender/Computer and Receiver/Computer
`
`VS.
`
`7
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Perlman
`
`Microsoft has not shown that Perlman anticipates
`claims 1, 3, and 22-24
`1. Perlman is not a data access system/method. (claims
`1, 3, 22-24)
`2. Perlman does not disclose a permanent storage
`memory. (claims 1 and 3)
`3. Perlman does not disclose searching for data with
`the same digital digest. (claims 22-24)
`4. Perlman does not disclose searching in
`predetermined locations in permanent storage
`memory for data with a digital digest. (claim 23)
`
`9
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Perlman
`1. Perlman is not a data access system/method, it is a data
`synchronization mechanism.
`
`Ex.1003 at 3:60-64
`
`Ex.1003 at 4:63-5:5
`
`10
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`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Perlman
`2. Perlman does not disclose permanent storage memory.
`
`Ex.1003 at 5:46-48
`
`11
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Perlman
`3. Perlman does not disclose searching for data with the same
`digital digest in the network cache memory.
`
`Ex. 1003 at 6:52-64
`
`12
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`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Perlman
`4. Perlman does not disclose searching in predetermined
`locations in permanent storage memory for data with a digital
`digest.
`
`Ex. 1003 at 8:32-42
`
`13
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Yohe
`
`Microsoft has not shown that Yohe anticipates claims 1,
`3, 6, 7, 10, 22 and 23
`1. Yohe does not disclose a sender computer having both
`permanent storage memory and means for creating a
`digital digest. (Claims 1, 3, and 10)
`2. Yohe does not disclose a Receiver/Computer with both
`means for creating digital digests on data and means for
`comparison between digital digests. (Claims 1, 3, and 10)
`3. Yohe does not disclose a caching computer having
`permanent storage memory. (Claims 6 and 7)
`4. Yohe does not disclose a Receiver/Computer searching
`for data having the same digital digests. (Claims 22 and
`23)
`
`15
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Yohe
`
`1. Yohe does not disclose a sender computer having both
`permanent storage memory and means for creating a digital
`digest.
`
`Ex.1002 at 10:31-40
`
`Ex.1002 at 11:20-29
`
`16
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`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Yohe
`Yohe discloses a separate file server 18 and a cache verifying
`computer 14, each being separate from the permanent storage
`device 80.
`
`Microsoft’s Sender/Computer
`
`17
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Yohe
`
`2. Yohe does not disclose a Receiver/Computer with both
`means for creating digital digests on data and means for
`comparison between digital digests.
`
`Ex.1002 at 10:31-45
`
`18
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Yohe
`
`Microsoft’s Receiver/Computer
`
`44 creates
`digests of
`data
`compared in
`the Sender
`
`46 compares
`digests of
`directories
`created in the
`Sender
`
`Microsoft’s Sender/Computer
`
`19
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Yohe
`3. Yohe does not disclose a caching computer having permanent
`storage memory.
`
`No Permanent
`Storage
`Memory
`
`Microsoft’s Sender/Computer Caching Computer
`
`20
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Yohe
`
`Microsoft’s Receiver/Computer Caching Computer
`
`21
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Yohe
`4. Yohe does not disclose a Receiver/Computer searching
`for data having the same digital digests.
`Microsoft’s Receiver/Computer
`
`Only ONE
`Directory
`Signature
`stored in
`Remote
`Client 12
`
`22
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Perlman and Yohe
`
`Microsoft has not shown that the combination of
`Perlman and Yohe makes claims 1, 3, 10 and 22-24
`obvious.
`1. Perlman is not analogous art because it is a synchronizing
`mechanism, not a data transfer system/method. (Claims
`1, 3, 10, and 22-24)
`It would not have been obvious to add permanent
`storage memory to Perlman. (Claims 1, 3, 10, and 22-24)
`3. The combination of Perlman and Yohe still lack a
`sender/computer; means for creating a digital digest on
`data; a caching computer having permanent storage
`memory; and searching for data having the same digital
`digest. (Claims 1, 3, 10, and 22-24)
`
`2.
`
`24
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Perlman and Yohe
`
`1. Perlman is not analogous art because it is a synchronizing
`mechanism, not a data transfer system/method.
`
`Ex. 1003 at 7:23-35
`
`25
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Perlman and Yohe
`
`2. It would not have been obvious to add permanent storage
`memory to Perlman.
`
`Improper to Add Permanent Storage Memory to
`Perlman
`A.
`“…routers typically are rebooted only rarely, so it’s
`cache naturally was in volatile RAM.” EX1007 at 14:4-5
`B. Permanent Storage Memory would serve to purpose.
`
`26
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Perlman and Yohe
`
`3. Microsoft only suggests adding bundling of multiple
`signatures (as recited in Claim 24) to Yohe, however, this fails
`to remedy the shortcomings of Yohe, as outlined above.
`In particular, Yohe still lacks
`A. A Sender/Computer
`B. Means for Creating a Digital Digest on Data
`C. A Caching Computer having permanent
`Storage Memory
`D. Searching for Data Having the Same Digital
`Digest
`
`27
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Grounds of Review
`
`• Anticipation by Perlman of claims 1, 3 and 22-24
`• Anticipation by Yohe of claims 1, 3, 6, 7, 10, 22 and 23
`• Obviousness over the combination of Perlman and
`Yohe of claims 1, 3, 10 and 22-24
`• Anticipation by Santos of claims 1, 3, 22, and 23
`
`• Anticipation by DRP of claims 6, 7, 9, 11, 12 and 14
`• Obviousness over the combination of Mattis and DRP
`of original claims 6, 7, 9, 11, 12 and 14
`
`28
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Santos
`
`Microsoft has not shown that Santos anticipates
`claims 1, 3, 22, and 23
`1. Santos does not disclose a receiver/computer.
`(Claims 1, 3, 22 and 23)
`2. Santos does not disclose creating a digital digest
`on data in network cache memory. (Claims 1 and
`3)
`3. Santos does not disclose searching in
`predetermined locations in permanent storage
`memory. (Claim 23)
`
`29
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Santos
`1. Santos does not disclose a receiver/computer.
`
`Ex. 1002 at 10:31-45
`
`Ex. 1002 at 12:30-45
`
`30
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Santos
`
`1. Santos does not disclose a receiver/computer.
`
`Microsoft’s Receiver/Computer
`
`Server
`
`Client
`
`31
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Santos
`1. Santos does not disclose a receiver/computer.
`
`DIFFERENT
`
`DIFFERENT
`
`32
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Santos
`2. Santos does not disclose creating a digital digest on data
`in network cache memory.
`
`Ex. 1004 at 7
`
`Ex. 1004 at 6
`
`33
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Santos
`3. Santos does not disclose searching in
`predetermined locations in permanent storage
`memory.
`
`Ex. 1002 at 12:46-49
`
`34
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Santos
`3. Santos does not disclose searching in predetermined
`locations in permanent storage memory.
`
`Ex. 1004 at 8
`
`Ex. 1004 at 9
`
`35
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of DRP
`
`Microsoft has not proven anticipation by DRP of claims 6, 7, 9,
`11, 12 and 14
`1. DRP discloses a protocol not a system. (Claims 6, 7, and 9)
`2. DRP does not disclose a caching computer having both
`permanent storage memory and means for comparison. (Claims 6,
`7, and 9)
`3. DRP does not disclose a caching computer with means for
`calculating a digital digest. (Claims 6, 7, and 9)
`4. DRP does not disclose a caching computer with means for
`storing the digital digest in permanent storage memory. (Claim 9)
`5. DRP does not disclose receiving a response signal. (Claims 11,
`12, and 14)
`6. DRP does not disclose separate indication signals. (Claim 14)
`
`37
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of DRP
`
`1. DRP discloses a protocol not a system
`
`38
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of DRP
`
`2. DRP does not disclose a caching computer having both
`permanent storage memory and means for comparison.
`
`Ex. 1003 at 7
`
`39
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of DRP
`
`3. DRP does not disclose a caching computer with means for
`calculating a digital digest.
`
`40
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of DRP
`4. DRP does not disclose a caching computer with means for
`storing the digital digest in permanent storage memory.
`
`41
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of DRP
`5. DRP does not disclose receiving a response signal, let
`alone the sender computer transmitting data upon receipt of
`a “response” signal.
`The client requests the files by content identifier, which
`the server determines matches or does not match its file.
`
`Ex. 1003 at 5
`The server does not even send the Index; it is also
`retrieved, by the client
`
`Ex. 1003 at 5
`
`42
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of DRP
`6. DRP does not disclose separate indication signals.
`
`The client is responsible for downloading the files its needs, and does not
`send indication signals to the server:
`
`Ex. 1003 at 5
`
`43
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Mattis and DRP
`
`Microsoft has not proven obviousness by the combination of Mattis
`and DRP of original claims 6, 7, 9, 11, 12 and 14:
`1. Mattis is not analogous prior art. (Claims 6, 7, 9, 11, 12, and 14)
`There is no reason to combine Mattis and DRP. (Claims 6, 7, 9, 11,
`2.
`12, and 14)
`The combination of Mattis and DRP still lacks a caching computer
`having a means for comparison. (Claims 6, 7, and 9)
`The combination of Mattis and DRP still lacks receiving a response
`signal from the receiver/computer. (Claims 11, 12, and 14)
`The combination of Mattis and DRP still lacks separate indication
`signals. (Claim 14)
`
`3.
`
`4.
`
`5.
`
`45
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Mattis and DRP
`1. Mattis is not analogous prior art.
`
`46
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Mattis and DRP
`
`2. There is no reason to combine Mattis and DRP.
`
`The only reason DRP and Mattis are related is their disclosure of MD5 Hash function.
`
`47
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Mattis and DRP
`
`3. The combination of Mattis and DRP still lacks a caching
`computer having a means for comparison.
`
`48
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Mattis and DRP
`
`4. The combination of Mattis and DRP still lacks receiving a
`response signal from the receiver/computer.
`
`49
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Deficiencies of Mattis and DRP
`
`5. The combination of Mattis and DRP still lacks separate
`indication signals.
`
`50
`
`PROXYCONN
`DEM. EX. 2007
`
`

`Conclusion
`
`• The Patent Owner respectfully requests that
`the Board find that Original Claims 1, 3, 6, 7,
`10, 11, 14, 22, 23 and 24 of the ‘717 Patent be
`found patentable in view of the Grounds of
`Review under consideration.
`
`51
`
`PROXYCONN
`DEM. EX. 2007
`
`

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