IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`In re Patent of: Nanja
`U.S. Patent No.: 7,065,637
`Issue Date:
`
`June 20, 2006
`Serial No.:
`
`09/662,990
`
`Filing Date:
` September 15, 2000
`Title:
`System for Configuration of Dynamic Computing
`Environments Using a Visual Interface
`
`
`
`DECLARATION OF DR. BENJAMIN B. BEDERSON, Ph.D.
`
`
`I, Dr. Benjamin B. Bederson, Ph.D., declare as follows:
`
`
`
`(1.)
`
`I am currently a Professor in the Computer Science Department and
`
`the Institute of Advanced Computer Studies at the University of Maryland. I am
`
`also the Co-Founder and Chief Scientist for Zumobi, Inc., a venture capital funded
`
`startup created to commercialize mobile media for cell phones, as well as the Co-
`
`Founder and Technical Director for the International Children’s Digital Library
`
`Foundation, which provides free online children’s books to its members.
`
`(2.)
`
`For more than 25 years, I have studied, designed, and worked in the
`
`field of computer science and human-computer interaction. My experience
`
`includes 25 years of teaching and research, with research interests in human-
`
`computer interaction and the software and technology underlying today’s mobile
`
`computing world; web browsing and mobile computing, including the use of
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`proxies to enhance the functionality of the web; mobile media for cell phones; and
`
`user interface development, just to name a few.
`
`(3.)
`
`I received a Bachelor of Science degree in Computer Science from
`
`Rensselaer Polytechnic Institute in 1986, a Master of Science Degree in Computer
`
`Science from New York University in 1989, and a Doctor of Philosophy degree in
`
`Computer Science from New York University in 1992.
`
`(4.)
`
`I have designed and implemented over a dozen software platforms,
`
`including Pad++ (my original toolkit for building zoomable user interfaces,
`
`including web support); PadPrints (a proxy-based web browser offering a graphical
`
`web history) which is discussed in more detail below; the International Children’s
`
`Digital Library (a website of children’s books); and StoryKit (a mobile children’s
`
`story authoring tool).
`
`(5.)
`
`I am the co-inventor of 7 U.S. patents, listed below. The patents are
`
`generally directed to user interfaces/experience.
`
` Pahud, M., Murillo, O. E., Karlson, A. K., & Bederson, B. B. Monitoring
`Pointer Trajectory and Modifying Display Interface. US Patent # 8,261,211.
`
` Good, L. E., Bederson, B. B., & Stefik, M. J. Methods and Systems for
`Supporting Presentation Tools Using Zoomable User Interfaces. US Patent
`# 7,707,503.
`
` 
`
` Bederson, B. B., Good, L. E., & Stefik, M. J. Methods and Systems for
`Incrementally Changing Text Representation. US Patent # 7,650,562.
`
` Bederson, B. B., Good, L. E., & Stefik, M. J. Methods and Systems for
`Incrementally Changing Text Representation. US Patent # 7,549,114.
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`
`
` Wallace, R. S., Bederson, B. B., & Schwartz, E. L. TV Picture
`Compression and Expansion. US Patent # 5,642,167.
`
` Bederson, B. B., Wallace, R. S., & Schwartz, E. L. Two-Dimensional
`Pointing Motor. US Patent # 5,204,573.
`
` Wallace, R. S., Bederson, B. B., & Schwartz, E. L. Telephone Line
`PictureTransmission. US Patent # 5,175,617.
`
`(6.)
`
`I currently serve on the editorial board for the Association of
`
`Computing Machinery (ACM) publication Transactions on Computer-Human
`
`Interaction; Now Publishers’ Foundations and Trends in Human-Computer
`
`Interaction, for which I am the Editor-in-Chief; and Palgrave Press’ Information
`
`Visualization publication. I have also served on the review board for over 15
`
`conference or symposium proceedings, including conferences sponsored by ACM,
`
`the Institute of Electrical and Electronics Engineers (IEEE), and the National
`
`Science Foundation (NSF).
`
`(7.)
`
`In 2011 I was elected to the Computer Human Interaction (CHI)
`
`Academy, which is an honorary group of individuals who have made substantial
`
`contributions to the field of human-computer interaction. Members of the CHI
`
`Academy are the principal leaders of the field, whose efforts have shaped the
`
`discipline and/or industry, and lead the research and/or innovation in human-
`
`computer interaction. In 2011 I was also recognized as an ACM Distinguished
`
`Scientists, which recognizes those ACM members with at least 15 years of
`
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`professional experience and 5 years of continuous professional membership who
`
`have achieved significant accomplishments or have made a significant impact on
`
`the computing field.
`
`(8.)
`
`I have presented in over 85 conferences throughout the United States
`
`and across the globe regarding human-computer interaction, web browsing, user
`
`interfaces, and user experience, to name a few relevant topics. I have also been
`
`honored to present as a keynote speaker at 6 conferences, largely for my work
`
`regarding zoomable user interfaces.
`
`(9.)
`
`I am the author or co-author of 10 book chapters and over 100
`
`technical articles directed to web browsing, mobile computing, user interfaces, user
`
`experience, and the software and technology underlying this technology. Many of
`
`these publications address various aspects of software visualization techniques
`
`implemented on a variety of hardware platforms. These publications highlight my
`
`familiarity with graphical user interfaces operating on a variety of platforms.
`
`Below is a list of my publications that are particularly relevant to the above topics:
`
` Bederson, B. B., Grosjean, J., Meyer, J. (2004). Toolkit Design for
`Interactive Structured Graphics, Transactions on Software
`Engineering, New York: IEEE, 30 (8), 535-546.
` Bederson, B. B., Shneiderman, B. (Eds.) (2003). The Craft of
`Information Visualization: Readings and Reflections. San Francisco:
`Morgan Kaufmann.
` Hourcade, J.P., Bederson, B.B., Druin, A., Rose, A., Farber, A.,
`Takayama, Y. (2003). The International Children's Digital Library:
`
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`Viewing Digital Books Online. Interacting with Computers, Elsevier
`Press, 15 (3), 151-167.
` Hourcade, J., Bederson, B. (May 1999). Architecture and
`Implementation of a Java Package for Multiple Input Devices (MID)
`HCIL-99-08, CS-TR-4018, UMIACS-TR-99-26.
` Hollan, J. D., Bederson, B. B., & Helfman, J. (1998). Information
`Visualization. Helander, M., Landauer, T. K., & Prabhu, P. V. (eds.),
`The Handbook of Human Computer Interaction (Chap. 2, 33-48).
`Amsterdam: Elsevier Press.
` Bederson, B. B., & Druin, A. (1995). Computer Augmented
`Environments: Physical Spaces to Enrich Our Lives. Jakob Nielsen
`(eds.), Advances in Human-Computer Interaction (Vol. 5, Chap.
`2, 37-66). New Jersey: Ablex Press.
` Bederson, B. B., & Hollan, J. D. (1994). Pad++: A Zooming
`Graphical Interface for Exploring Alternate Interface Physics. In Proc.
`of User Interface and Software Technology (UIST 94) ACM
`Press, 17-26.
`
`
`(10.)
`
`A copy of my curriculum vitae, which describes in further detail my
`
`qualifications, responsibilities, employment history, honors, awards, professional
`
`associations, invited presentations, and publications is attached to this declaration
`
`as Appendix A-1.
`
`(11.)
`
`I have reviewed United States Patent No. 7,065,6371 (“the ‘637
`
`patent”) to Sekaran Nanja as well as the patents and applications referenced in the
`
`section of the ‘637 patent entitled “Related U.S. Application Data.” I have also
`
`                                                       
`1 Sekaran Nanja, “System for Configuration of Dynamic Computing Environments Using a
`Visual Interface.” U.S. Patent No. 7,065,637, filed September 15, 2000, claiming priority to a
`Provisional Application (U.S. Ser. No. 60/228,105) filed August 24, 2000. (Ex. 1001)
`
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`reviewed the publications cited in the footnotes of this declaration and referenced
`
`in the inter partes review petition submitted herewith.
`
`
`STATE OF THE ART AS OF 2000
`
`(12.)
`
`In the late 1990’s, the World Wide Web (WWW) was achieving its
`
`first peak. Known as the “dot-com” era, there was a tremendous amount of
`
`innovation around e-commerce and web-based companies in general. Essentially
`
`every one of these companies ran web servers which provided users with web
`
`pages, typically backed by databases. These web servers were regular computers
`
`running special “server” software, and the computers ran an operating system such
`
`as Windows or Linux. While it was possible to simply plug one of these
`
`computers into an office network, and provide a website to the world, that was
`
`uncommon as that would not offer a reliable or scalable solution.
`
`(13.)
`
`Instead, it was common to put these server computers in “data
`
`centers” or “server rooms” that were special facilities with “racks” of many
`
`computers. As there could be, and often was, an abundance of users, it was not
`
`sufficient to simply have a single computer running a web server due to reliability
`
`and speed issues. Instead, clusters of computers were configured to collectively
`
`provide a faster or reliable service even when being used by many users. The
`
`computers could be structured in different ways, but one typical organization was
`
`to have a number of web servers that would connect to a separate set of computers
`
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`that provided access to a database. To decide which web server would respond to
`
`a specific request, a “load balancer” was typically put up front, and it would direct
`
`requests to balance the load across numerous web servers.2
`
`(14.)
`
`The basic architecture described above captures the essence of how
`
`web server systems were set up in the late 1990’s, but there is another basic issue
`
`when managing computer systems: adaptability. It was (and is) common for
`
`websites to get more (or less) popular over time, and so the systems manager must
`
`be able to increase or decrease the number of computers in the system to respond
`
`to varying loads. Doing this manually by physically going to the server room or
`
`data center and plugging cables between machines was an extremely time
`
`consuming task. And so it was not surprising that a number of solutions were
`
`made to provide software based configuration of these systems to avoid having to
`
`physically visit the servers.
`
`(15.)
`
`The Dell Computer Company was a significant seller of computers
`
`designed to be used for web servers in the late 1990’s. For example, in 1999, Dell
`
`sold a specialized piece of hardware called a “Dell OpenManage Remote Assistant
`
`Card” (DRAC).3 These DRAC cards, which I used in the ICDL server
`
`                                                       
`2 Anderson, P., et al. “Performance Soars, Features Vary,” Network World (June 14, 1999)
`viewed at http://www.networkworld.com/reviews/0614rev.html (Last visited December 21,
`2012). (Appendix A-2).
`3 “Dell OpenManage™ Remote Assistant Card II (DRAC II),” Dell OpenManage Documents
`(14 Dec 1999) viewed at http://support.dell.com/support/edocs/software/smdrac/index.htm. (Last
`visited December 21, 2012). (Appendix A-3).
`
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`configuration, enabled remote management of individual servers to, for example,
`
`reboot a machine when it became unresponsive. This was important because it
`
`allowed remote management of a computer without having to physically touch it.
`
`It was part of the ecosystem of devices that enabled the software based
`
`configuration of computer systems. 
`
`(16.)
`
`Additionally, companies were offering full service solutions allowing
`
`a customer to configure and order web servers entirely over the web as early as
`
`1998. For example, Rackspace allowed clients to custom configure servers via the
`
`Rackspace website.4 The following screenshots of their website in February of
`
`1998 shows the ability to pick amongst a plurality of configurations of web servers
`
`as well as to specify which operating system should be used on a server and what
`
`resources should be made available on that server:5
`
`                                                       
`4 “About Rackspace.” (“We got started in 1998 and since have grown to serve more than 197,000
`customers.”) viewed at http://www.rackspace.com/information/aboutus/ (Last visited December
`21, 2012). (Appendix A-4).
`5See Feb. 8, 1999 Rackspace.com website capture:
`http://web.archive.org/web/19990208005938/http://rackspace.com/ (Last visited December 21,
`2012) (Appendix A-5) and March 2, 2000 Rackspace.com website Capture:
`http://web.archive.org/web/19990125091600/http://rackspace.com/http://web.archive.org/web/20
`000302000851/http://www.rackspace.com/goconfigure/pricing.php3 (Last visited December 21,
`2012). (Appendix A-6).
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`(17.)
`
`Another basic and well-known characteristic of data centers was the
`
`increasing need for storage. In 2000, storage was taking about 40% of system cost6
`
`and was predicted to account for over 75% of all computer hardware in the ensuing
`
`5 years.7 At the same time, there was growing demand to share that storage.8
`
`Fortunately, by this time, there had been significant development of mechanisms to
`
`deploy significant volumes of reliable storage. Going back at least to the early
`
`1990’s, the concept of “network-attached storage” (NAS) had become a popular
`
`way to address some of these challenges. Instead of connecting storage devices
`
`(such as hard disks) directly to computers, they were instead connected to a local
`
`area network, and then any computer on the network could access the storage.9 A
`
`variant called “storage area network” (SAN) used the same strategy, and by 2000,
`
`both techniques were in common commercial use as indicated by both a tutorial
`
`given by an HP employee in 2000 (Alvarez), as well as a commercial web page
`
`providing a guide to these services.10,11
`
`                                                       
`6 Alvarez, G., et al. “Storage Systems Management.” Sigmetrics 00 Tutorial, Hewlett-Packard
`Labs, 4 (17 June 2000) viewed at http://www.hpl.hp.com/research/ssp/papers/Tutorial00.pdf.
`(Last visited May 7, 2013). (Appendix A-7).
`7 AUSPEX, “Selecting the right storage solution for an optimized e-Business network
`infrastructure.” Auspex Systems, Inc. (May 29, 2000) viewed at
`http://www.auspex.com/storage_guide2k/guide1.htm. (Last visited April 7, 2013). (Appendix A-
`8).
`8 Alvarez, 15.
`9 Coyne, R. A., et al. “Storage systems for national information assets.” IEEE (1992). (Appendix
`A-9).
`10 AUSPEX, “Determining the right storage architecture for a specific application.” Auspex
`Systems, Inc. (Aug. 17, 2000) viewed at http://www.auspex.com/storage_guide2k/guide3_3.htm.
`(Last visited April 7, 2013). (Appendix A-10).
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`(18.) With storage hardware essentially a commodity, there was a need for
`
`a simple and consistent mechanism to provide software access to that storage.
`
`Fortunately, a standard mechanism had been developed and used widely on most
`
`operating systems. For example, all variations of Unix going back to the 1970’s
`
`have had a simple and consistent mechanism for managing who gets access to
`
`which files. Files are organized in a hierarchy of directories. The hierarchical
`
`Unix file system starts with the root directory (/), which is available to the root user
`
`when a system boots and is needed to run a system.12 Each file and directory is
`
`owned by a “user” and is associated with a “group.” Access to files is governed by
`
`these user and group attributes in that each file can be made read-only, writable or
`
`executable to the specific user that owns a file, to the group members associated
`
`with a file’s group, or to everyone. The details of how these permissions can be
`
`changed are described under the description of the “chmod” command in the 1994
`
`SunOS Reference Manual.13
`
`                                                                                                                                                                               
`11 AUSPEX, “Determining the right storage architecture for a specific application. Storage
`Attached Network.” Auspex Systems, Inc. (Aug. 17, 2000) viewed at
`http://www.auspex.com/storage_guide2k/guide3_4.htm. (Last visited April 7, 2013). (Appendix
`A-11).
`12 SunSoft File System Administration, Sun Microsystems, Inc., 13-14, 21 (1994) viewed at
`http://docs.oracle.com/cd/E19457-01/801-6631/801-6631.pdf. (Last visited May 7, 2013).
`(Appendix A-12).
`13 SunSoft SunOS Reference Manual, Sun Microsystems, Inc., 1-83 – 1-86 (1994) viewed at
`http://docs.oracle.com/cd/E19457-01/801-6680-01/801-6680-01.pdf. (Last visited May 7, 2013).
`(Appendix A-13).
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`(19.)
`
`In addition to user and group access permission in Unix, there is a
`
`concept of a “root” super user that is the primary administrator and who has full
`
`access to every file, no matter how a file’s permissions are set. Unix computer
`
`systems are booted (i.e., started up) running as this “root” super user, and only
`
`change to a specific user when a user logs in. Root access is crucial to security and
`
`access to files as root is typically logged.14
`
`(20.)
`
`The ‘637 patent alleges a novel interactive system for allowing
`
`allocation of resources such as digital processors, networks and software to create a
`
`software configured, networked arrangement of processors and processes.15
`
`However, as shown by the discussion of relevant patents and articles below, the
`
`methods and systems proposed by the patentee represent nothing more than
`
`standard resource allocation and system configuration utilizing standard user
`
`interfaces, which was pursued and accomplished by many before the Patent
`
`Owner.
`
`
`THE ‘637 PATENT
`
`(21.)
`
`The ‘637 is generally directed to a system for providing “such fast
`
`allocation and configuration of resources that environments can be created from a
`
`                                                       
`14 SunSoft Security, Performance, and Accounting Administration, Sun Microsystems, Inc., 4, 14
`(1994) viewed at http://docs.oracle.com/cd/E19457-01/801-6629/801-6629.pdf. (Last visited
`May 7, 2013). (Appendix A-14).
`15 ‘637 Patent, 1:18-24.
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`pool of resources within minutes, or even seconds, (virtually) destroyed, and
`
`reallocated for creating different environments from the same pool of resources.”16
`
`This “provides an efficient system for provisioning ‘crash and burn’ systems which
`
`can be used in different software development life-cycle scenarios including
`
`testing, rapid beta deployment, etc.”17 A preferred embodiment allows customers
`
`to create a computing environment from a remotely accessible user interface such
`
`as a web page on the Internet.18
`
`(22.)
`
`Once a user logs in, a configuration page is displayed as illustrated in
`
`the web page of Fig. 5:
`
`
`
`                                                       
`16 Id. at 4:42-48.
`17 Id. at 4:52-56.
`18 Id. at 4:58-60.
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`Based on a selection made by the user, a configuration server allocates a computer
`
`with the requested operating system and other application software.19 Accordingly,
`
`if a user wishes to configure a server for the computing environment, the user
`
`clicks on “select a configuration or the user may open a window on one of the
`
`machines which were previously configured and the access server provides the
`
`user with access to the specific machine.20 Once allocated, the user can open a
`
`terminal to access the specific computing device and when the user tries to access,
`
`the configuration/access server activates the machine from the inventory.21
`
`
`PREVIOUSLY FILED PETITION FOR INTER PARTES REVIEW
`
`(23.)
`
`Independent claim 1 was previously addressed in a petition for inter
`
`partes review against claims 1-4 and 6 of the ‘637 patent on December 21, 2012.22
`
`The claim charts duplicated below demonstrate how claim 1 of the ‘637 patent is
`
`anticipated and/or rendered obvious under 35 U.S.C. § 102(e) / § 103(a) by several
`
`different references.
`
`(24.)
`
`The following claim chart demonstrates, on a limitation-by-limitation
`
`basis, how claim 1 of the ‘637 patent is anticipated under 35 U.S.C. § 102(e) by
`
`Patterson.23
`
`                                                       
`19 Id. at 6:57-60.
`20 Id. at 6:15-22.
`21 Id. at 7:1-13.
`22 See IPR 2013-00099. (Ex. 1012).
`23 Id. at 21-29.
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`U.S. Patent No.
`7,065,637 Claim
`Language
`1. A system for
`providing configurable
`resources to create a
`computing
`environment, the
`system comprising:
`
`a configurable
`communication link;
`
`plurality of hardware
`devices coupled to the
`communication link;
`
`Correspondence to
`U.S. Patent No. 7,093,005 to Patterson
`Patterson discloses methods to “visually create a logical
`description of a virtual server farm and instantiate a
`corresponding tangible, operable computing system
`relatively instantly . . .” (Ex. 1003 at 2:14-16). (See also
`Ex. 1004 at 3).
`
`Patterson describes a dynamically configurable network
`that allows creation of an “instant data center.”
`In this document, the terms "virtual server
`farm," "VSF," "farm," "instant data center," and
`"IDC" are used interchangeably to refer to a
`networked computer system that comprises the
`combination of more than one processor, one or
`more storage devices, and one or more
`protective elements or management elements
`such as a firewall or load balancer. Such a
`system is created on demand from a large grid
`of generic computing elements and storage
`elements of the type described in Aziz, et al.
`(Ex. 1003 at 6:43-51). (See also Ex. 1004 at 2-
`3, 59, 62, 69, 73, 111-113, 119).
`Patterson also describes receiving a graphical
`representation of a logical configuration of the networked
`system. (Id. at 3:4-6).
`Aziz, which is incorporated by reference into Patterson,
`describes a plurality of VLANs, such as VLAN1 and
`VLAN2, configurable based on the creation of the VSF
`and the computing elements contained therein. (See Ex.
`1005 at 10:25-28, Fig. 6).
`As noted above, the instant data centers of Patterson are
`comprised of networked computer systems such as storage
`devices, processors and load balancers. (See Ex. 1003 at
`6:43-51). (See also Ex. 1004 at 2-3, 59, 62, 69, 73, 111-
`113, 119).
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`U.S. Patent No.
`7,065,637 Claim
`Language
`a plurality of software
`programs executable by
`the hardware devices,
`the software programs
`comprising at least one
`of operating system
`software and
`application software,
`wherein the computing
`environment comprises
`the communication
`link, at least one of the
`hardware devices and
`at least one of the
`software programs; and
`
`Correspondence to
`U.S. Patent No. 7,093,005 to Patterson
`Patterson discloses that instant data center may include, for
`example, a user-specified Web server running Windows
`NT and Internet Information Server version 3.0 :
`As described in detail in Aziz, et al., a data
`center may be defined in terms of a number of
`basic building blocks. By selecting one or more
`of the basic building blocks and specifying
`interconnections among the building blocks, a
`data center of any desired logical structure may
`be defined. The resulting logical structure may
`be saved as a named server image, and treated
`as a blueprint ("DNA") for creating any number
`of other IDCs that have the same logical
`structure. Thus, creating a DNA for a data
`center facilitates
`the automation of many
`manual tasks involved in constructing server
`farms using prior technologies.
`As defined herein, a data center DNA may
`specify roles of servers in a data center, and the
`relationship of the various servers in the roles.
`A role may be defined once and then re-used
`within a data center definition. For example, a
`Web Server role may be defined in terms of
`the hardware, operating
`system, and
`associated applications of the server, e.g.,
`dual Pentium of a specified minimum clock
`rate and memory size, NT version 4.0,
`Internet Information Server version 3.0 with
`specified plug-in components. This Web
`Server role then can be cloned many times to
`create an entire Web server tier or server group.
`The role definition also specifies whether a role
`is for a machine that is statically assigned, or
`dynamically added and removed from a data
` (Ex. 1003 at 9:42-67) (emphasis
`center.
`added).
`
` 
`
`- 16 -
`
`Oracle Exhibit 1011
`
`

`

`U.S. Patent No.
`7,065,637 Claim
`Language
`
`a visual construction of
`the computing
`environment via a user
`interface, the user
`interface coupled to a
`display screen and to
`an input device for
`generating signals in
`response to interactions
`of a user,
`
`Correspondence to
`U.S. Patent No. 7,093,005 to Patterson
`(See also Ex. 1004 at 111-114, 118).
`Patterson discloses a graphical drag-and-drop interface for
`designing the instant data center via a visual editor (Ex.
`1003 at Fig. 2B) (See also Ex. 1004 at 28) operating on a
`computer system having a display and input device (Ex.
`1003 at 40:54 – 41:24, Fig. 9) (See also Ex. 1004 at 4,
`15):
`
`Design and creation of Instant Data Centers
`generally involves providing a drag-and-drop
`graphical editor with which a user may draw
`server farm designs. In a preferred embodiment,
`the editor includes a palette that features icons
`representing standard server farm elements. For
`example,
`icons may
`represent hardware
`elements such as firewalls, load-balancers;
`application servers or database servers having
`various processor and RAM configurations,
`generic or general purpose servers having
`various processor and RAM configurations, and
`Internet or network connectivity (e.g., icons
`may represent the Internet, sub networks,
`backhaul connections, etc.). (Ex. 1003 at
`19:51-62).
`(See also Ex. 1004 at 3, 14, 29-30, 62, 73, 118-119).
`The editor may be implemented, for example,
`in the form of a software plug-in for Microsoft
`Visio such that a Visio drawing may be saved
`in FML format. Alternatively, the editor may
`be
`implemented as a standalone software
`application program that can accept Visio
`format drawings as input. Such an application
`may be implemented in the form of one or
`more client-side software elements, such as
`browser applets or scripts, and server-side
`software elements, such as CGI scripts, Perl
`
` 
`
`- 17 -
`
`Oracle Exhibit 1011
`
`

`

`U.S. Patent No.
`7,065,637 Claim
`Language
`
`wherein the user
`interface is configured
`to accept a signal
`which enables the user
`to request a copy a
`device configuration,
`the system is
`configured to make the
`copy of the device
`configuration and save
`the copy of the device
`configuration in
`storage,
`
`Correspondence to
`U.S. Patent No. 7,093,005 to Patterson
`scripts, Java applications, etc. These software
`elements cooperate over a network
`that
`connects a client executing a browser to a
`server that executes the server-side software
`elements, and thereby carry out the functions
`described herein. In the example of FIG. 3A,
`graphical editor
`functions are shown as
`integrated with a customer control center
`application; however, this structure is not
`required, and a graphical editor may be
`provided as a standalone application. (Ex. 1003
`at 20:3-20).
`(See also Ex. 1004 at 3, 29, 62, 73, 112, 114-122).
`Patterson teaches creating and storing a textual
`representation of the logical and configuration of the
`networked system. (Ex. 1003 at 3:11-16). In the textual
`representation, a copied server definition is created and
`stored. (Id. at 4:1-4) (See also Ex. 1004 at 8, 9).
`Patterson teaches that the user can make copies or images
`of the configuration of the servers with the instant data
`center:
`4.5.1 Creating Server Images
`To create one or more server images, one or
`more operating systems, applications, data and
`support files that comprise the image are
`initially loaded onto a disk that forms a part of
`an IDC or farm. Thereafter,
`information
`identifying the image is associated with the
`image in the CCC database and a copy of the
`image is saved for future re-use. (Ex. 1003 at
`30:39-46). (See also Ex. 1004 at 61-64, 73-75,
`115).
`. . .
`FIG. 6B is a diagram of an example `Snapshot:
`
` 
`
`- 18 -
`
`Oracle Exhibit 1011
`
`

`

`U.S. Patent No.
`7,065,637 Claim
`Language
`
`Correspondence to
`U.S. Patent No. 7,093,005 to Patterson
`Image` window that opens in response to the
`selection from the context menu of FIG. 6A. In
`one embodiment, defining a server image
`involves entering data values in the fields of
`Snapshot Image window 610. For example, a
`unique name value is entered in Name field
`612. Description field 614 receives a brief
`description
`of
`the
`image. Hardware
`Compatibility radio buttons 616 are used to
`identify the hardware architecture required for
`the image in terms of whether the current
`architecture should be `tied` to the image or
`whether any architecture is allowed at time of
`deployment. Server field 618 receives a value
`indicating which specific server in the current
`server group is the source of the disk image.
`Disk field 620 is used to indicate which disk
`volume of the server identified using Server
`field 618 is to be used for image creation. (Ex.
`1003 at 30:55 – 31:3). (See also Ex. 1004 at
`62-64, 73-76, 97-102).
`. . .
`4.5.3 Load Balancer and Firewall Snapshot
`In one embodiment, a user can
`store
`information
`that
`identifies
`a
`current
`configuration of a firewall or load balancer, so
`that
`the configuration
`information can be
`applied to other firewalls or load balancers of
`other IDCs or farms in the user's account. This
`process is called taking a "snapshot" of the
`configuration of the firewall or load balancer.
`To store a snapshot, a user may right-click on a
`firewall or a load balancer in the Farm Builder
`page (Editor) and select a "Snapshot . . . "
`option from the context menu that is displayed
`in response. In response to selection of the
`
` 
`
`- 19 -
`
`Oracle Exhibit 1011
`
`

`

`U.S. Patent No.
`7,065,637 Claim
`Language
`
`the user interface is
`further configured to
`accept a signal which
`enables the user to
`instantiate a device
`from a stored
`configuration, and the
`system is further
`configured to
`instantiate the device
`from the stored
`configuration.
`
`Correspondence to
`U.S. Patent No. 7,093,005 to Patterson
`Snapshot option, a Snapshot Configuration
`window is displayed. The window provides a
`message to the user that confirms that the
`system is about to store a snapshot of the
`configuration of the current firewall or load
`balancer node. If the user selects `Snapshot
`Now,` the system sends a request to the server
`to snapshot the current firewall/load balancer
`and stores configuration information as the
`snapshot. (Ex. 1003 at 31:42-58). (See also
`Ex. 1004 at 62-64, 73-76, 97-102).
`Patterson teaches that each node may be configured by
`selecting a stored configuration or image:
`The image value is selected from a pull-down
`menu and identifies one of a plurality of pre-
`defined disk images to apply to the disk. A disk
`image can contain boot
`information, an
`operating system, applications, and associated
`configuration data. (Ex. 1003 at 27:9-13). (See
`also Ex. 1004 at 3, 62, 73, 80-96, 97-102).
`Patterson teaches that the instant data center is instantiated
`based on the configuration specified by the user through
`the graphi