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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________
`
`APPLE INC.
`Petitioner
`
`v.
`
`PERSONALWEB TECHNOLOGIES, LLC and
`LEVEL 3 COMMUNICATIONS, LLC
`Patent Owner
`_________
`
`Case IPR2013-00596
`Patent 7,802,310
`_________
`
`
`PETITIONER’S BRIEF ON REMAND
`
`
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-145
`
`
`
`
`
`
`Case IPR2013-00596
`Patent 7,802,310
`
`I.
`
`II.
`
`TABLE OF CONTENTS
`ARGUMENT .................................................................................................. 1
`A. Apple’s petition specifically identifies where Woodhill and Stefik
`teach each and every claim element, including comparing a
`content-dependent identifier to a plurality of values. ........................... 2
`1. Woodhill teaches comparing a content-dependent
`identifier to a plurality of values. ............................................... 2
`2. Woodhill and Stefik in combination teach determining
`authorization based on comparing a content-
`dependent identifier to a plurality of values and
`selectively allowing access based on whether the
`relevant content-dependent identifier corresponds to
`one of the plurality of values. .................................................... 6
`Apple’s petition specifically explained why the skilled artisan
`would have combined Woodhill and Stefik and why the skilled
`artisan would have had a reasonable expectation of success. .............10
`1.
`The skilled artisan would have been motivated to add
`Stefik’s authorization layer to Woodhill. ................................. 10
`The skilled artisan would have had a reasonable
`expectation of success in doing so because the unique
`identifiers of Woodhill are readily usable in the
`context of Stefik. ...................................................................... 13
`CONCLUSION ............................................................................................. 14
`
`
`B.
`
`2.
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`
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`Case IPR2013-00596
`Patent 7,802,310
`On June 22, 2017 the Board authorized additional briefing to allow the
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`parties to address whether the petitioner (“Apple”) made out a proper case of
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`obviousness on the instituted ground of Woodhill and Stefik. (Paper No. 39.) The
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`Board has requested that emphasis be placed on elucidating where Apple’s petition
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`explains and supports (1) that the Woodhill and Stefik references disclose all of the
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`elements recited in the challenged claims; and (2) that a skilled artisan would have
`
`been motivated to combine Woodhill and Stefik as claimed in the ’310 patent with
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`a reasonable expectation of success. These points are addressed in detail below.
`
`I.
`
`ARGUMENT
`
`Apple’s petition set forth a proper case of obviousness. On appeal, the patent
`
`owner (“PersonalWeb”) focused on two limitations: (1) whether Woodhill and/or
`
`Stefik teach comparing a content-dependent identifier to a plurality of values; and
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`(2) whether Woodhill and/or Stefik teach determining authorization based on
`
`comparing a content-dependent identifier to a plurality of values and selectively
`
`allowing access based on whether the relevant content-dependent identifier
`
`corresponds to one of the plurality of values.1 Appellant Br. at 20-21.
`
`
`1 PersonalWeb did not appeal the Board’s findings that Woodhill and/or
`
`Stefik teach the remaining claim limitations. Therefore, PersonalWeb has waived
`
`any argument that the remaining limitations are not met.
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`Patent 7,802,310
`Apple’s petition identifies and explains where Woodhill and/or Stefik teach
`
`each of these claim elements. In addition to explaining how Woodhill and/or Stefik
`
`teach these claim elements, Apple’s petition also identifies and explains why the
`
`skilled artisan would have combined Woodhill and Stefik as claimed. As part of
`
`that analysis, Apple’s petition identifies and explains why the skilled artisan would
`
`have had a reasonable expectation of success in combining the elements of
`
`Woodhill and Stefik in the manner claimed. Likewise, Apple’s petitioner reply,
`
`which properly responded to PersonalWeb’s arguments in its Patent Owner’s
`
`Response, further supported the case of obviousness Apple set forth in its petition.
`
`A. Apple’s petition specifically identifies where Woodhill and Stefik
`teach each and every claim element, including comparing a
`content-dependent identifier to a plurality of values.
`
`Apple’s petition, supported by the declaration of Dr. Benjamin Goldberg
`
`(Ex. 1007), explains where one or both of the Woodhill (Ex. 1014) and Stefik (Ex.
`
`1013) references teaches each and every claim element. (Petition, pp. 28-43.)
`
`1. Woodhill teaches the claim element of comparing a content-
`dependent identifier to a plurality of values.
`
`Apple’s petition identifies where and explains how Woodhill teaches the
`
`claim element of comparing a content-dependent identifier to a plurality of values.
`
`Ground 6 of Apple’s petition—the ground that combines Woodhill and Stefik—
`
`references and incorporates an earlier discussion of Woodhill in Grounds 4 and 5
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`of the petition, where Woodhill’s disclosure of this claim element (in particular,
`
`Woodhill’s disclosure at column 17) is discussed in depth. (Petition, pp. 41-43.)
`
`The petition’s discussion of Ground 4 covers this “comparing” feature
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`extensively. (Petition, pp. 33-36.) For example, the petition cites to Woodhill:
`
`Program control then continues with step 446 where the
`Distributed Storage Manager program 448 transmits an
`‘update request’ to the remote backup file server 12
`which includes the Binary Object Identification Record
`58 for the previous version of each binary object as well
`as the list of ‘contents identifiers’ calculated in step 444.
`
`(Woodhill, 17:40-46; cited in Petition pp. 32-34).
`
`With support from Apple’s technical expert, Dr. Goldberg, the petition goes
`
`on to explain that “[t]o determine which data needs to be restored by the update
`
`request, the remote backup file server of Woodhill must be able to reference its
`
`local files using the information it receives -- namely the Binary Object
`
`Identification Record.” (Petition, p. 34; citing Goldberg Decl., ¶ 70.)
`
`Then, using Woodhill’s Figure 1 for context, the petition explains that “the
`
`remote backup fileserver needs to access its local data using the Binary Object
`
`Identification Record as an identifier,” adding that “[l]ocal computer 20, running
`
`an instance of the Distributed Storage Manager Program, simply informs the
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`Patent 7,802,310
`remote backup fileserver of the required data using the Binary Object Identification
`
`Record.” (Petition, p. 35.) Figure 1, as shown in the petition, is reproduced below:
`
`
`
`(Petition, p. 35.)
`
`The petition explains, supported by Dr. Goldberg’s declaration, that “[t]he
`
`remote backup fileserver maintains some sort of file system or other mapping (i.e.,
`
`a database) that allows the Binary Object Identification Record to serve as a lookup
`
`for the requisite file data.” (Petition, p. 35; citing Goldberg Decl., ¶ 72.)
`
`Based on this, the Board found sufficient teaching of the “content-dependent
`
`name” (and therefore its related behaviors, including the comparison to a plurality
`
`of values) to institute trial. (Institution Decision, pp. 15-16.) (“Based on this, two
`
`identical items will have the same Binary Object Identifier. Ex. 1007 ¶ 67.”)
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`During trial, PersonalWeb’s expert, Dr. Dewar, admitted that the ’310 patent
`
`uses “name” and “identifier” interchangeably, supporting a finding that the Binary
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`Object Identifiers of Woodhill are equivalent to the “digital identifier,” “content-
`
`dependent name,” and “content-based identifier” recited in the claims. (See, e.g.,
`
`Pet. Reply, p. 4; Hearing Tr. pp. 6-7.) Apple’s reply further explained how,
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`consistent with what is shown in the petition, Woodhill’s Binary Object Identifiers
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`may be used to access, search for, or address binary objects. (Pet. Reply, pp. 4-8.)
`
`These issues were addressed in depth during the oral hearing, providing even
`
`more support for the Board’s determination that Woodhill teaches comparing a
`
`content-dependent identifier to a plurality of values. (See, e.g., Hearing Tr., p. 7,
`
`line 18 - p. 17, line 8) (explaining that if Woodhill’s backup file server determines
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`that the binary object identifier in the request does not match the binary object
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`identifier in the database, access would not be provided to the local computer.)
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`In its final written decision, the Board cited Apple’s petition at page 42 as
`
`providing the support for this claim element. (Final Written Decision, pp. 14-15.)
`
`While this citation was correct, it appears that because the citation pointed to
`
`Ground 6 (Petition, p. 41), the Federal Circuit did not look to the discussion of this
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`claim element in the other sections of the petition (Grounds 4 and 5, which Ground
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`6 references and incorporates) that fully discuss the Woodhill reference. But as
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`described in detail above, the petition fully explains how Woodhill discloses the
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`claim element of comparing a content-dependent identifier to a plurality of values.
`
`2. Woodhill and Stefik in combination teach determining
`authorization based on comparing a content-dependent
`identifier to a plurality of values and selectively allowing
`access based on whether the relevant content-dependent
`identifier corresponds to one of the plurality of values.
`
`Apple’s petition specifically explains how Woodhill and Stefik teach
`
`determining authorization based on comparing a content-dependent identifier to a
`
`plurality of values and selectively allowing access based on whether the relevant
`
`content-dependent identifier corresponds to one of the plurality of values.2
`
`Woodhill alone, and in combination with Stefik, teaches or suggests the
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`limitation of selective access based on the comparison of the content-dependent
`
`identifiers to the plurality of values. Under one interpretation, the selective access
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`limitation simply means “that the location can be provided if known, and not
`
`provided if not known,” in which case the selective access limitation is fully taught
`
`by Woodhill. (Petition, p. 37; see also Petition, p. 21.) As the petition explains:
`
`Woodhill meets the “selectively permitting . . . access[]”
`limitation because the remote backup file server 12 is
`
`
`2 Unlike the “comparing” limitation addressed above, the Federal Circuit’s
`
`opinion does not address the Board’s finding that Woodhill in combination with
`
`Stefik teaches these claim elements.
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`able to locate the corresponding file using the Binary
`Object Identification Record, and no further information
`(e.g., a file name) is necessary. (Goldberg, APL 1007, ¶
`75.) This approach would entail a database, as a form of
`mapping, between the Binary Object Identification
`Record and a copy of the file at the remote backup file
`server 12. (Goldberg, APL 1007, ¶ 75.) As a result, the
`remote backup file server 12 of Woodhill makes a
`determination whether the Binary Object Identification
`Record exists -- namely, whether the remote backup file
`server 12 has a copy of the requested file associated with
`that Binary Object Identification Record. (Goldberg,
`APL 1007, ¶ 75.)
`
`(Petition, p. 37-38.)
`
`This limitation is also fully taught or suggested by the combination of
`
`Woodhill and Stefik. Specifically, Apple’s petition explains that while Woodhill
`
`has its own form of “selective access,” Stefik is cited as teaching this feature based
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`on its disclosure of a system that addresses the problem of preventing unauthorized
`
`access to digital works. (Petition, pp. 41-43.) In particular, Stefik discloses
`
`receiving a request for access to a particular digital work, where the request
`
`includes a unique identifier for the digital work. (Petition, p. 26.) The background
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`teachings of Stefik are incorporated by reference into instituted Ground 6 through
`
`explicit citation to Section IX(C) of the petition. (Petition, p. 41.) While Section
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`Patent 7,802,310
`IX(C) ultimately proposes the combination of Browne and Stefik, Section IX(C)
`
`also introduces the relevant background teachings of Stefik that are referenced and
`
`incorporated in Ground 6 to avoid unnecessary repetition. (Petition, pp. 25-28.)
`
`The petition, with support from Dr. Goldberg, states that “a POSA reading
`
`Woodhill and Stefik would have understood that Woodhill discloses the alleged
`
`invention of claim 24 substantially as claimed, and that Stefik discloses the
`
`claimed selective access features.” (Petition, p. 42.) The petition emphasizes that
`
`Stefik, like Woodhill, utilizes unique identifiers to provide access control:
`
`Stefik addresses the problem of preventing unauthorized
`access to digital works. (Stefik, APL 1013, 1:17-20.)
`Stefik proposes a solution to that problem in the form of
`a system that allows only licensed or authorized access,
`e.g., by parties who have paid for or are otherwise
`entitled to access a digital work. (Stefik, APL 1013, 3:58-
`62.) In particular, Stefik discloses receiving a request for
`access to a particular digital work from a requestor
`repository, where
`the request
`includes a unique
`identifier for the digital work. (Stefik, APL 1013, 9:47-
`61 and 41:60-65.) Stefik’s server repository does not
`allow the particular digital work to be provided to or
`accessed by the requester repository if it is determined
`that access
`to
`the particular digital work
`is not
`authorized. (Stefik, APL 1013, 31:12-40.)
`
`(Petition, pp. 26-27; emphasis added.)
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`The Board determined in its final decision that “Stefik discloses receiving a
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`request for access to a particular digital work from a requester, including a unique
`
`identifier for the digital work, and only providing access if it is determined that the
`
`request is authorized.” (Final Written Decision, p. 22; citing Stefik at 9:47-49,
`
`31:13-20, 41:60-65.) These portions of Stefik are all cited in Apple’s petition and
`
`are discussed by Dr. Goldberg. (Petition, pp. 26-27; Goldberg Decl., ¶¶ 57, 85.)
`
`Selective access based on comparing the content-dependent identifiers to the
`
`plurality of values is taught by Woodhill alone as well as the combination of
`
`Woodhill and Stefik, as discussed above. In combining Woodhill and Stefik, the
`
`limitation is taught by applying Stefik’s selective access to the comparison
`
`performed by Woodhill. (Petition, p. 42.) Arguing, as PersonalWeb does, that this
`
`limitation must be fully disclosed in either Woodhill alone or Stefik alone is
`
`contrary to settled principles of obviousness. As the Board noted, “[o]ne cannot
`
`show nonobviousness by attacking references individually where the rejections are
`
`based on combinations of references.” (Final Written Decision, p. 22.)
`
`In sum, Woodhill and Stefik teach determining authorization based on
`
`comparing a content-dependent identifier to a plurality of values and selectively
`
`allowing access based on whether the relevant content-dependent identifier
`
`corresponds to one of the plurality of values. Apple’s petition explained where and
`
`how each is disclosed in either Woodhill or the Woodhill and Stefik combination,
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`as supported by Dr. Goldberg’s declaration. Thus, Apple’s petition fully supports
`
`the Board’s findings. Additional support for the Board’s findings that is responsive
`
`to PersonalWeb’s arguments appears in Apple’s reply. (Pet. Reply, pp. 4-8.)
`
`B. Apple’s petition specifically explained why the skilled artisan
`would have combined Woodhill and Stefik and why the skilled
`artisan would have had a reasonable expectation of success.
`
`Apple’s petition identifies “a precise and specific reason why” the skilled
`
`artisan would have modified Woodhill with Stefik to arrive at the claimed subject
`
`matter. Outdry Techs. Corp. v. Geox S.p.A., No. 2016-1769, 2017 WL 2603139, at
`
`*4 (Fed. Cir. June 16, 2017). Apple’s petition “explain[s] why one of skill would
`
`have been so motivated” based on evidence in the references and “supported by
`
`evidence of the knowledge of a skilled artisan” in the form of Dr. Goldberg’s
`
`declaration. Id. Apple’s petition demonstrates that the skilled artisan in fact would
`
`have been motivated to combine Woodhill with Stefik to arrive at what is recited in
`
`the claims. See Belden Inc. v. Berk-Tek LLC, 805 F.3d 1064, 1073 (Fed. Cir. 2015).
`
`1.
`
`The skilled artisan would have been motivated to add
`Stefik’s authorization layer to Woodhill.
`
`Apple’s petition explains how Stefik’s authorization layer would have been
`
`advantageously applied to Woodhill. (Petition, pp. 41-43.) This is supported by Dr.
`
`Goldberg, who explains that the skilled artisan would have combined the backup
`
`and restore system in Woodhill with the repository in Stefik to add an authorization
`
`layer to prevent unauthorized users from accessing a different user’s back up files.
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`(Goldberg Decl., ¶ 84.) Preventing unauthorized users from accessing a different
`
`user’s back up files is “a precise and specific reason why” the skilled artisan would
`
`have modified Woodhill with Stefik to arrive at the claimed subject matter. Outdry
`
`Techs. Corp., No. 2016-1769, 2017 WL 2603139, at *4. Accordingly, Apple’s
`
`petition provides a clear and concrete motivation as to why a skilled artisan would
`
`have added Stefik’s authorization layer to Woodhill. Belden, 805 F.3d at 1073.
`
`Moreover, in first introducing Stefik, Apple’s petition explains that “Stefik
`
`addresses the problem of preventing unauthorized access to digital works” and that
`
`“Stefik proposes a solution to that problem in the form of a system that allows only
`
`licensed or authorized access, e.g., by parties who have paid for or are otherwise
`
`entitled to access a digital work.” (Petition, p. 26; see also Petition, pp. 41-43.)
`
`This is supported by Dr. Goldberg, who explains that both Stefik and Woodhill
`
`involve file management and aim to solve problems with secure access. (Goldberg
`
`Decl., ¶¶ 57, 85, 88.) The petition explains that Stefik contains “even more specific
`
`disclosures related to ‘authorization,’” and those disclosures would “remedy any
`
`perceived deficiency in Woodhill.” (Petition, p. 42; citing Goldberg Decl., ¶ 88.)
`
`Apple’s petition emphasizes that Stefik and Woodhill are in the same field,
`
`i.e., file management, and involve the same general problem, i.e., secure access.
`
`Accordingly, the petition supports that the skilled artisan would have combined
`
`Stefik and Woodhill. Apple emphasized this point again during oral hearing:
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`We have two references that are in the same field, file
`management on a network system, two references that
`are addressing the same problem, secure access to data,
`and then each of these two references, Stefik and
`Woodhill, certainly take different approaches or they
`approach this problem in different ways, but they do so in
`a way that lends itself to a combination with the other in
`the way that the Board described in the decision, again,
`using
`the unique content-dependent
`identifiers of
`Woodhill with the selective access concept of Stefik.
`
`(Hearing Tr., p. 18, line 19 - p. 19, line 2.)
`
`In sum, Apple’s petition provided a legally sufficient and factually supported
`
`motivation to combine: to add an authorization layer to prevent unauthorized users
`
`from accessing a different user’s back up files. (Goldberg Decl., ¶ 84.) The result is
`
`a specific combination: the backup and restore system of Woodhill combined with
`
`the repository of Stefik. (Goldberg Decl., ¶ 84.) A skilled artisan would also have
`
`envisaged the combination based on the similar disclosures of Woodhill and Stefik,
`
`which both involve file management systems and are both concerned with secure
`
`access. PersonalWeb did not argue that this particular motivation was deficient or
`
`insufficiently articulated. Rather, during trial, PersonalWeb attacked the technical
`
`combinability of the references. Apple responded to these arguments in its reply.
`
`(Pet. Reply, pp. 4-13.) The Federal Circuit did not conclude that PersonalWeb’s
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`technical incompatibility arguments had merit. Nor did the Court conclude that the
`
`Board’s obviousness determination lacked sufficient support in the record. Rather,
`
`the Court held that the Chenery doctrine requires that administrative decisions have
`
`“the amount of explanation” needed for it to perform its judicial review function.
`
`2.
`
`The skilled artisan would have had a reasonable expectation
`of success in doing so because the unique identifiers of
`Woodhill are readily usable in the context of Stefik.
`
`Apple’s petition and Dr. Goldberg’s declaration also explained that the
`
`skilled artisan would have had a reasonable expectation of success in combining
`
`the backup and restore system of Woodhill with the repository of Stefik.
`
`Apple’s petition explains that the skilled artisan would have had a
`
`reasonable expectation of success because “any particular choice of a unique
`
`identifier would have been a mere design choice among well-known options,
`
`including content-dependent identifiers such as message digest identifiers.”
`
`(Petition, p. 42.) Dr. Goldberg’s declaration supports this. Dr. Goldberg explains
`
`that the properly motivated skilled artisan would have added Stefik’s authorization
`
`layer with a reasonable expectation of success because modifying Woodhill to
`
`perform Stefik’s selective access function would have been a mere design choice,
`
`with such options as using content-dependent identifiers. (Goldberg Decl., ¶ 87.)
`
`During trial, PersonalWeb did not dispute that there was an evident need to
`
`solve a specific problem. Nor did PersonalWeb dispute that using Stefik’s unique
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`identifier-based access control feature would have been one of a “finite number of
`
`identified, predictable solutions.” KSR Int’l Co. v. Teleflex, Inc., 550 U.S. 398, 421
`
`(2007). Rather, PersonalWeb attacked the technical combinability of Woodhill and
`
`Stefik in terms of incorporating one into the other. Apple rebutted these arguments
`
`in its reply. (Pet. Reply, pp. 4-13.) Ultimately, the Board correctly concluded that a
`
`person of ordinary skill is not an automaton and would have been able to modify
`
`Woodhill to include Stefik’s access control feature. (Final Written Decision, pp.
`
`15-22.) In other words, the skilled artisan would have expected success in adding
`
`Stefik’s authorization layer to Woodhill’s backup and restore system because using
`
`a particular unique identifier would have been a well-understood design choice.
`
`II. CONCLUSION
`Apple’s petition sets forth where all of the claim elements are taught in the
`
`Woodhill and Stefik combination. Apple’s petition articulates a legally sufficient
`
`and factually supported motivation to combine. Apple’s petition explains in detail
`
`why the skilled artisan would have had a reasonable expectation of success in
`
`combining Woodhill and Stefik in the manner claimed. Consistent with the Federal
`
`Circuit’s mandate, the Board should consider its obviousness determination in light
`
`of the record as a whole, including admissions made by PersonalWeb’s expert and
`
`the lack of any argument by PersonalWeb addressing the sufficiency of the
`
`rationale for combining Woodhill and Stefik with a reasonable expectation of
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`success. Here, the record clearly demonstrates that the combination of Woodhill
`
`and Stefik renders the challenged claims obvious, as set forth in Apple’s petition.
`
`Respectfully Submitted,
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`
`
`/SALVADOR M. BEZOS/
`
`Salvador M. Bezos, Reg. No. 60,889
`Attorney for Petitioner Apple Inc.
`
`Date: July 12, 2017
`
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`
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`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e))
`
`The undersigned hereby certifies that a true and correct copy of the
`
`foregoing PETITIONER’S BRIEF ON REMAND was served electronically via
`
`e-mail in its entirety on July 12, 2017, upon the following:
`
`
`
`jar@nixonvan.com
`usg@nixonvan.com
`
`Joseph A. Rhoa (Lead Counsel)
`Updeep S. Gill (Back-up Counsel)
`
`NIXON & VANDERHYE P.C.
`901 North Glebe Road, 11th Floor
`Arlington, VA 22203-1808
`
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`
`
`/SALVADOR M. BEZOS/
`
`Salvador M. Bezos, Reg. No. 60,889
`Attorney for Petitioner Apple Inc.
`
`Date: July 12, 2017
`
`
`1100 New York Avenue, N.W.
`Washington, D.C.20005-3934
`(202) 371-260
`
`
`
`
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