`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD IN THE UNITED
`STATES PATENT AND TRADEMARK OFFICE
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`Trial No.:
`IPR 2013-00083
`In re:
`U.S. Patent No. 6,415,280
`Patent Owners:
`PersonalWeb Technologies, LLC & Level 3 Communications
`Petitioner:
`EMC Corp. and VMware, Inc.
`Inventors:
`David A. Farber and Ronald D. Lachman
`For: IDENTIFYING AND REQUESTING DATA IN NETWORK USING
`IDENTIFIERS WHICH ARE BASED ON CONTENTS OF DATA
`* * * * * * * * * * *
`July 24, 2013
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`PATENT OWNER’S RESPONSE PURSUANT TO 37 C.F.R. § 42.120
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`Patent Owner’s Response (U.S. Pat. No. 6,415,280)
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`TABLE OF CONTENTS
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`Page
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`I.
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`II.
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`INSTITUTED GROUNDS .............................................................................. 1
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`THE BOARD’S CLAIM CONSTRUCTIONS ASSUMED AND
`USED BY PATENT OWNER HEREIN ........................................................ 1
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`III. LAW REGARDING ANTICIPATION .......................................................... 2
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`IV. WOODHILL DOES NOT ANTICIPATE CLAIM 36 ................................... 3
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`V. WOODHILL DOES NOT ANTICIPATE CLAIM 38 ................................. 11
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`VI. CLAIMS 36 and 38 ARE NOT OBVIOUS OVER WOODHILL ................ 11
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`VII. SECONDARY CONSIDERATIONS ........................................................... 12
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`VIII. CONCLUSION .............................................................................................. 13
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`PATENT OWNER’S EXHIBIT LIST
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.120, PersonalWeb Technologies, LLC (“patent
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`owner”) submits this response to the petition. Petitioner has the burden of proving
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`unpatentability by a preponderance of the evidence. 35 U.S.C. § 316(e). Petitioner
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`has not met its burden for the reasons explained below.
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`I. INSTITUTED GROUNDS
`The Board, on May 17, 2013, instituted a trial regarding U.S. Patent No.
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`6,415,280 (the ‘280 patent) for only the following:
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`1.
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`2.
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`Whether claims 36 and 38 are anticipated under 35 U.S.C. §102(e)
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`by Woodhill (Ex. EMC 1005).
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`Whether claims 36 and 38 are unpatentable as obvious under 35
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`U.S.C. §103(a) over Woodhill.
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`II. THE BOARD’S CLAIM CONSTRUCTIONS ASSUMED AND USED BY
`PATENT OWNER HEREIN
`The Board construed, inter alia, the following in its Decision dated May 17,
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`2013. The Board’s constructions in the chart immediately below have been
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`assumed to be correct by patent owner for purposes of this IPR proceeding and
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`have been used by patent owner herein (without prejudice to argue otherwise in
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`other proceedings).
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`Claim Term
`Preamble of claims 36
`and 38
`“data file” (claims 36 and
`38)
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`Board’s Construction
`Preambles of claims 36 and 38 are entitled to
`patentable weight.
`A named data item, such as a simple file that includes
`a single, fixed sequence of data bytes or a compound
`file that includes multiple, fixed sequences of data
`bytes. (‘280 patent, col. 5:47-50) (May 17, 2013 Dec.
`10-11).
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`III. LAW REGARDING ANTICIPATION
`“A claim is anticipated only if each and every element as set forth in the
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`claim is found, either expressly or inherently described, in a single prior art
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`reference.” Verdegaal Bros. v. Union Oil Co. of California, 814 F.2d 628, 631
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`(Fed. Cir. 1987). A feature is “inherent” in a reference only if that feature is
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`“necessarily present” in the reference, “not merely probably or possibly present.”
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`Trintec Indus., Inc. v. Top-U.S.A. Corp., 295 F.3d 1292, 1295 (Fed. Cir. 2002).
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`Furthermore, in order to anticipate, a prior art reference must not only disclose all
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`elements of the claim, but must also disclose those elements “arranged or
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`combined in the same way as in the claim.” Net MoneyIN, Inc. v. VeriSign, Inc.,
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`545 F.3d 1359, 1369-71 (Fed. Cir. 2008).
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`Woodhill represents prior art under 35 U.S.C. § 102(e). Woodhill was
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`“filed” before April 11, 1995 (the effective filing date of the ‘280 patent), but was
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`not published until after April 11, 1995. Therefore, the only content in Woodhill
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`that can be relied upon in this proceeding is the content that was included at the
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`time of Woodhill’s July 1, 1993 filing date. And any material added to Woodhill
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`after April 11, 1995 cannot be relied upon for prior art purposes in this IPR
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`proceeding. Excerpts from Woodhill’s file history have been provided herewith to
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`evidence the content in Woodhill that can be relied on in this respect. (Ex. 2007.)
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`IV. WOODHILL DOES NOT ANTICIPATE CLAIM 36
`Claim 36 of the ‘280 patent recites, inter alia,
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`“responsive to a client request for the data file, the request
`including a hash of the contents of the data file, causing the data
`file to be provided to the client.”
`Woodhill, for several reasons, fails to anticipate this subject matter of claim 36.
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`(Dewar Decl., ¶¶ 100-109 [Ex. 2013].)
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`First, claim 36 requires a request for the data file from a client, where the
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`request includes a hash of the contents of the data file. Woodhill fails to disclose a
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`“request” for a data file including “a hash of the contents of the data file.” (Dewar
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`Decl., ¶¶ 102-104 [Ex. 2013].)
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`Petitioner relies on the self-auditing procedure described by Woodhill at col.
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`18:10-38 for this feature. (Pet. 43-44; and Ex. EMCVMW 1009 at ¶ 26.)
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`Petitioner contends that the “data file” in claim 36 corresponds to a “binary
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`object” in Woodhill. (Pet. 44; and Ex. EMCVMW 1032 at 3-4.) For the self-
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`auditing procedure, Woodhill explains that “Distributed Storage Manager program
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`24 initiates a restore of a randomly selected binary object identified by a Binary
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`Object Identification Record 58 stored in File Database 25.” (Woodhill, col.
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`18:16-19). As shown in Fig. 3 of Woodhill, the Binary Object Identification
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`Record 58 includes a Binary Object Identifier 74, and the Identifier 74 includes a
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`hash field 70. However, Woodhill expressly states in its description of the self-
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`auditing procedure that the Binary Object Identification Record 58 is “stored in
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`File Database 25.” (Woodhill, col. 18:16-19.) Tellingly, petitioner omits this
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`important portion of Woodhill’s sentence from its quotations of Woodhill. (Pet.
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`44; and Ex. EMCVMW 1009 at ¶ 26.) The Binary Object Identifier 74 in
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`Woodhill is not included in any such “request” - it is merely used for comparison
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`purposes after the binary object has already been accessed in order to determine if
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`the audit restore worked properly. (Woodhill, col. 18:28-38; Dewar Decl., ¶ 103
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`[Ex. 2013].)
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`Thus, while the Record 58 identifies the binary object, Woodhill states that
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`the Record 58 is “stored in File Database 25” and never describes it as part of a
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`“request” for the binary object. (Woodhill, col. 18:16-19; Dewar Decl., ¶ 104 [Ex.
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`2013].) Accordingly, in Woodhill’s self-auditing procedure there is no description
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`of a “request” for a binary object that includes Record 58. (Dewar Decl., ¶ 104
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`[Ex. 2013].) Woodhill never describes Record 58 being sent as part of any request
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`for a binary object, and instead simply states that the Record 58 is “stored in File
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`Database 25” which suggests that the Record 58 is not sent as part of any such
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`request. Id. The Record 58 is not necessarily included in a “client request” for the
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`binary object. Id.
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`Indeed, petitioner’s expert acknowledged that Woodill fails to describe the
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`Binary Object Identifier 74 as part of such a request, as petitioner’s expert testified
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`that it is unclear how binary objects are accessed in Woodhill:
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`Q. Which portion of the record 58 is employed to access the binary
`object in the auditing procedure in Woodhill?
`A. So he doesn't tell us about that.
`Q. Does that matter?
`A. So I can only speculate.
`Q. So Woodhill doesn't say which portion of the record 58 is used?
`A. He does not.
`Q. Do you think that's important point?
`MS. VREELAND: Objection to form.
`A. I don't know how to answer.
`(Clark Dep. 167-68 [Ex. 2008].)
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`Q. Do you know how the binary object is accessed in Woodhill's
`auditing procedure?
` (Witness reviewing)
`A. I do not.
`Q. . . . New question. If you took Woodhill's Binary Object
`Identification Record 58 and you removed the Binary Object Identifier 74
`portion from it, leaving only fields 72, 62, and 60, do you have an
`understanding of that?
`A. Yes.
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`Q. If you did that, would Woodhill's auditing procedure access the
`binary object in the exact same way?
`MS. VREELAND: Objection to form; objection outside the scope.
`A. I do not know.
`Q. So then you don't know whether Binary Object 74 is employed or
`relied upon in accessing the binary object in the auditing procedure?
` MS. VREELAND: Objection to form.
` A. That's correct.
`(Clark Dep. 172-73 [Ex. 2008].) Given the testimony by petitioner’s expert that it
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`is unclear if the Binary Object Identifier 74 is employed or relied upon in accessing
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`the binary object, Woodhill cannot anticipate claim 36 because the Binary Object
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`Identifier 74 is certainly not necessarily part of any “request” that is sent for the
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`binary object. The last Q and A in the above-identified excerpt for his deposition
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`testimony is particularly telling. Woodhill never states that either Record 58 or
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`Binary Object Identifier 74 is part of a “request” for a binary object in the auditing
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`procedure.
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`Claim 36 is not anticipated by Woodhill for at least this first reason, and
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`petitioner’s allegations of obviousness cannot cure this deficiency in Woodhill.
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`Second, petitioner incorrectly contends that the “data file” in claim 36
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`corresponds to a “binary object” in Woodhill. (Pet. 44; and Ex. EMCVMW 1032
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`at 3-4.) A binary object in Woodhill is not a “data file”, because a binary object in
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`Woodhill is not a named data item. (Dewar Decl., ¶¶ 105-106 [Ex. 2013].) The
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`Board correctly construed “data file” as a named data item. (‘280 patent, col.
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`5:47-50) (May 17, 2013 Dec. 10-11). Binary objects in Woodhill are not “named.”
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`(Dewar Decl., ¶¶ 105-106 [Ex. 2013].) Instead, binary objects in Woodhill are
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`identified by respective Binary Object Identifiers 74. (E.g., Woodhill, col. 4:45-
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`46.) However, Binary Object Identifiers 74 are not file names. (Dewar Decl., ¶
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`105 [Ex. 2013].) Indeed, petitioner’s expert agreed that Binary Object Identifiers
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`74 in Woodhill are not file names:
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`Q. . . . In Woodhill, is a Binary Object Identifier a file name?
`A. No.
`(Clark Dep. 227 [Ex. 2008].)1 Given that a Binary Object Identifier 74 in
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`Woodhill is not a file name, it follows that a binary object is not a “named” data
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`item. (Dewar Decl., ¶ 105 [Ex. 2013].) File names 40 in Woodhill identify files,
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`not binary objects. (Woodhill, Fig. 3; and col. 3:61.) Therefore, this basis of
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`petitioner’s anticipation allegation, namely that a binary object in Woodhill is a
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`“data file”, is incorrect. (Dewar Decl., ¶ 105 [Ex. 2013].)
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`Woodhill’s Binary Object Identifier 74 includes a hash field resulting from
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`application of a hash function to a binary object. (Woodhill, col. 8:22-31.)
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`However, Woodhill fails to disclose applying a hash to the contents of a named
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`“file.” (Dewar Decl., ¶ 106 [Ex. 2013].) The claim language “a hash of the
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`1 Patent Owner has submitted a complete copy of the Clark deposition transcript
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`herewith for the Board’s convenience. Patent owner reserves its right to move to
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`exclude portions of that transcript subject to patent owner’s objections therein.
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`contents of the data file” means that the hash must be of all data in the data file,
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`which is consistent with the specification of the ‘280 patent which explains that the
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`True Name or substantially unique identifier for a data item is based on a hash of
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`“all” data in the data item. (E.g., ‘280 patent, col. 1:14-16; col. 3:29-31; and col.
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`33:1-7.) Therefore, while Woodhill discloses applying a hash to a binary object,
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`Woodhill fails to disclose a hash of the contents of a named data item (named file).
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`(Dewar Decl., ¶ 106 [Ex. 2013].) In this respect, Woodhill fails to disclose the
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`“hash of the contents of the data file” required by claim 36. Id.
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`Claim 36 is not anticipated by Woodhill for at least this second reason, and
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`petitioner’s allegations of obviousness cannot cure this deficiency in Woodhill.
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`Third, Woodhill fails to disclose a named “file” that consists of only one
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`binary object. Even if a “file” in Woodhill were to include only one “binary
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`object”, this does not necessarily mean that the binary object makes up the entire
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`file. (Dewar Decl., ¶ 107 [Ex. 2013].) To the contrary, one of ordinary skill in the
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`art would have recognized that a “file” could allocate a number of bits for
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`metadata which allows the file to contain some basic information about itself. Id.
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`Woodhill appears to confirm this by stating that “a file may contain its normal data
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`and may also contain extended attribute data.” (Id.; and Woodhill, col. 4:18-19.)
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`Thus, data in a “file” in Woodhill may well include both metadata and the binary
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`object. (Dewar Decl., ¶ 107 [Ex. 2013].) Accordingly, even if a “file” in
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`Woodhill were to include only one binary object, the hash of that binary object
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`described by Woodhill at col. 8:21-31 would not necessarily be a “hash of the
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`contents of the data file” as required by claim 36 – it would just be a hash of the
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`binary object portion of the file. Id. Claim 36 is not anticipated by Woodhill for at
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`least this third reason, and petitioner’s allegations of obviousness cannot cure this
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`deficiency in Woodhill.
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`Fourth, while Woodhill refers to “data files comprised of one or more
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`binary objects” at col. 2:3, the definition of “file” given by Woodhill with respect
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`to the program 24 that controls Woodhill’s backup procedure and self-auditing
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`procedure relied upon by petitioner requires a “file” to have at least two binary
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`objects. (Dewar Decl., ¶ 108 [Ex. 2013].) Woodhill defines a “file” as viewed by
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`Distributed Storage Manager program 24 as “a collection of data streams” – with
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`“streams” being plural. (Id.; and Woodhill, col. 4:14-15.) The Board agreed that
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`Woodhill defines a “file” in this manner. (May 17, 2013 Dec. 14.) Thus,
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`according to Woodhill’s express definition, a “file” that is to be backed up or
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`subjected to the auditing procedure requires at least two data streams. (Dewar
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`Decl., ¶ 108 [Ex. 2013].) And each data stream includes one or more binary
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`objects. (Woodhill, col. 4:15-23.) Therefore, Woodhill’s definition of “file” as
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`viewed by Distributed Storage Manager program 24 (which is the program that
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`controls the backup procedure and auditing procedure relied on by petitioner)
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`requires that each “file” to be backed up includes at least two binary objects.
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`(Woodhill, col. 4:13-23; and Dewar Decl., ¶ 108 [Ex. 2013].) While Woodhill
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`discloses applying a hash to one binary object at col. 8:21-31, Woodhill never
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`discloses applying a hash to a combination of at least two binary objects of a file.
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`(Dewar Decl., ¶ 108 [Ex. 2013].) Stated another way, no Binary Object Identifier
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`74 in Woodhill includes a hash of multiple binary objects. Accordingly, Woodhill
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`again fails to disclose “a hash of the contents of the data file”, because each file to
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`be backed up in Woodhill has at least two binary objects and Woodhill fails to
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`disclose applying a hash to a combination of multiple binary objects. Id. Claim 36
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`is not anticipated by Woodhill for at least this fourth reason, and petitioner’s
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`allegations of obviousness cannot cure this deficiency in Woodhill.
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`While petitioner does not mention it, patent owner notes that Woodhill’s
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`“granularizing” embodiment also fails to anticipate claim 36. For example,
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`Woodhill’s granularizing embodiment relates only to large database files, each of
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`which includes many binary objects. (E.g., Woodhill, col. 14:53-60; col. 15:15-16;
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`col. 17:19-22.) Thus, Woodhill again fails to disclose “a hash of the contents of
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`the data file”, because each file in Woodhill’s granularizing procedure has many
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`binary objects and Woodhill fails to disclose applying a hash to a combination of
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`multiple binary objects. (Dewar Decl., ¶ 109 [Ex. 2013].) Moreover, this
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`embodiment of Woodhill “is not utilized in making backup copies of binary
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`objects for storage on local computers”, thereby teaching away from the paragraph
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`of claim 36 beginning with “storing . . .” Id.
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`Claim 36 is not anticipated by Woodhill for the foregoing reasons.
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`V. WOODHILL DOES NOT ANTICIPATE CLAIM 38
`Claim 38 of the ‘280 patent is not anticipated by Woodhill for the reasons
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`explained above regarding claim 36, except that “a hash of the contents of the data
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`file” in the reasons explained above regarding claim 36 is replaced with “a value
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`determined as a given function of the contents of the data file” in the reasons
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`regarding claim 38. (Dewar Decl., ¶ 110 [Ex. 2013].)
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`VI. CLAIMS 36 AND 38 ARE NOT OBVIOUS OVER WOODHILL
`The Board also instituted on petitioner’s Ground 4, namely whether claims
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`36 and 38 are obvious under Section 103(a) over Woodhill. However, petitioner’s
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`allegations of obviousness cannot cure the deficiencies of Woodhill discussed
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`above regarding claims 36 and 38.
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`Petitioner contends that it would have been obvious to have modified
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`Woodhill to meet the “storing copies of the data file on a set of servers in the
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`network distinct from the first server” requirement of claims 36 and 38. (Pet. 47-
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`48.) Petitioner contends that it would have been obvious to have added additional
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`remote backup servers 12 to Woodhill. Id. Petitioner makes no other obviousness
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`allegations regarding Woodhill. However, even if Woodhill were to have been
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`modified as alleged by petitioner, the deficiencies in Woodhill explained above
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`regarding claims 36 and 38 would still exist and the claims still would not be met
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`for the reasons explained above. Thus, petitioner’s allegations of obviousness
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`cannot overcome the deficiencies in Woodhill pointed out herein. Moreover, there
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`would have been no logical reason to have modified Woodhill to have met claims
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`36 and 38 in the above respects. Claims 36 and 38 are not obvious over Woodhill.
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`VII. SECONDARY CONSIDERATIONS
`The fact that others have licensed the patent is evidence of the validity of the
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`patent, and should be considered as evidence of nonobviousness rebutting any
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`alleged prima facie case of obviousness. Transocean Offshore Deepwater
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`Drilling, Inc. v. Maersk Drilling USA, Inc., 699 F.3d 1340 (Fed. Cir. 2012). This
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`is especially the case where the patent license was not for settling any patent
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`litigation, and the licensee paid amounts that exceed any reasonable litigation cost.
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`Id. at 1353. This occurred here.
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`Exhibits 2010, 2011 and 2012 are licenses where the patent was licensed,
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`and these licenses were not for the purpose of settling any patent litigation. (Ex.
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`2009, ¶¶ 3-9.) The licensees paid amounts that exceed any reasonable litigation
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`cost. Id. at ¶ 6. These licenses are for the ‘791 patent and any continuations
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`thereof, which includes the ‘280 patent at issue in this IPR. This represents
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`evidence of nonobviousness that further rebuts the obviousness allegations of
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`petitioner.
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`VIII. CONCLUSION
`For the foregoing reasons, the Board should confirm patentability of the
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`challenged claims. Petitioner has not met its burden of proving unpatentability by
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`a preponderance of the evidence for the reasons explained above.
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`Respectfully submitted,
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`NIXON & VANDERHYE P.C.
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`By: /Joseph A. Rhoa/
`Joseph A. Rhoa
`Reg. No. 37,515
`Updeep (Mickey) S. Gill
`Reg. No. 37,334
`Counsel for Patent Owner PersonalWeb
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`
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`Nixon & Vanderhye, PC
`901 North Glebe Road, 11th Floor
`Arlington, VA 22203-1808
`Telephone: (703) 816-4000
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`PATENT OWNER’S EXHIBIT LIST
`Exhibit No. Brief Description
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`2001
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`2002
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`2003
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`2004
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`2005
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`2006
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`2007
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`2008
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`2009
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`2010
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`2011
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`2012
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`2013
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`Claim construction of “substantially unique identifier” by the U.S.
`District Court for the District of Massachusetts.
`U.S. Patent No. 7,318,237, and portion of prosecution history
`thereof citing Browne.
`Altnet’s Opening Claim Construction Brief, in case styled Altnet
`Inc. v. Streamcast Networks, Inc., CV-06-5086, dated March 29,
`2007.
`CWIS’ Opening Markman Brief, CV-02-11430, dated July 25,
`2003.
`Patent Owner’s Opening Claim Construction Brief in litigation,
`dated June 5, 2013.
`Patent Owner’s Reply Claim Construction Brief in litigation, dated
`July 8, 2013.
`Excerpts from file history of U.S. 5,649,196 to Woodhill.
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`Deposition Transcript of Douglas W. Clark
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`Declaration of Kevin Bermeister
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`Skype License Agreement
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`Brilliant Digital/Altnet License Agreement
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`Sharman License Agreement
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`Declaration of Robert B. K. Dewar
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`CERTIFICATE OF SERVICE
`I hereby certify service of the foregoing Patent Owner’s Response (including
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`any new exhibits) to the following lead counsel for petitioner on July 24, 2013 via
`
`email (under an agreement between the parties):
`
`Peter M. Dichiara
`WilmerHale
`60 State Street
`Boston, MA 02109
`(peter.dichiara@wilmerhale.com)
`
`
`
`
`By: /Joseph A. Rhoa/
`Joseph A. Rhoa
`Reg. No. 37,515
`
`
`
`
`
`15
`
`2020057
`
`
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