Patent No. 7,900,057
`
`Case No. IPR2014-01178
`
`November 2, 2015
`
`Seagate Technology (US) Holdings, Inc.,
`
`and Seagate Technology LLC,
`
`Petitioners
`
`Enova Technology Corp.,
`
`Patent Owner
`
`v.
`
`
`
`Case No. IPR2014-01178
`
`November 2, 2015
`
`Seagate Technology (US) Holdings, Inc.,
`
`and Seagate Technology LLC,
`
`Petitioners
`
`Enova Technology Corp.,
`
`Patent Owner
`
`v.
`
`
`
`2
`
`(3)IPR2014-01449, Claims 40-53
`(2)IPR2014-01297, Claims 33-39
`(1)IPR2014-01178, Claims 1-32
`3 Proceedings:
`
`Overview
`Overview
`
`’057 Patent -Claim 40
`
`
`
`3
`
`(3)IPR2014-01449, Claims 40-53
`(2)IPR2014-01297, Claims 33-39
`(1)IPR2014-01178, Claims 1-32
`3 Proceedings:
`
`Overview
`Overview
`
`’057 Patent -Claim 40
`
`
`
`4
`
`(5)Alleged evidence of secondary considerations
`(4)“layers” limitations in claims 16-19, 28-32
`(3)“command set” limitations in claims 7, 9
`(2)“bypass” limitations in claims 5, 16, 17, 19
`(1)“association” limitation in claim 1
`Agenda
`
`IPR2014-01178 Claims 1-32
`IPR2014-01178 Claims 1-32
`
`’057 Patent -Claim 40
`
`
`
`5
`
`(5)Alleged evidence of secondary considerations
`(4)“layers” limitations in claims 16-19, 28-32
`(3)“bypass” limitations in claims 5, 16, 17, 19
`(2)“command set” limitations in claims 7, 9
`(1)“association” limitation in claim 1
`Agenda
`
`IPR2014-01178 Claims 1-32
`IPR2014-01178 Claims 1-32
`
`’057 Patent -Claim 40
`
`
`
`6
`
`Host FIS from the interface of the device.
`without decryption responsive to receiving the Register-Device to
`
`the SATA protocol stack to process a Register-Device to Host FIS
`
`the cryptographic engine to decrypt at least a portion of the first
`
`payload received from the SATA protocol stack; and
`
`associated with a pre-defined category of command set;
`FIS to the cryptographic engine responsive to the first data FIS
`the SATA protocol stack to send at least first payload of a first data
`
`a main controller implemented at least partially in hardware, the main
`
`controller configured to cause:
`
`a cryptographic engine operatively coupled to the SATA protocol stack for
`a SATA protocol stack for communicating with an interface of a device;
`1. A cryptographic Serial ATA (SATA) apparatus, comprising:
`
`stack; and
`Information Structures) communicated to or from the SATA protocol
`encrypting or decrypting at least a subset of data FISes (Frame
`
`’057 Patent: Claim 1
`’057 Patent: Claim 1
`
`’057 Patent -Claim 40
`
`
`
`7
`
`Host FIS from the interface of the device.
`without decryption responsive to receiving the Register-Device to
`
`the SATA protocol stack to process a Register-Device to Host FIS
`
`the cryptographic engine to decrypt at least a portion of the first
`
`payload received from the SATA protocol stack; and
`
`associated with a pre-defined category of command set;
`FIS to the cryptographic engine responsive to the first data FIS
`the SATA protocol stack to send at least first payload of a first data
`
`a main controller implemented at least partially in hardware, the main
`
`controller configured to cause:
`
`a cryptographic engine operatively coupled to the SATA protocol stack for
`a SATA protocol stack for communicating with an interface of a device;
`1. A cryptographic Serial ATA (SATA) apparatus, comprising:
`
`stack; and
`Information Structures) communicated to or from the SATA protocol
`encrypting or decrypting at least a subset of data FISes (Frame
`
`’057 Patent: Claim 1
`’057 Patent: Claim 1
`
`’057 Patent -Claim 40
`
`
`
`(Ex. 1003, 1.)
`
`8
`
`(Ex. 1002, 1.)
`
`Sullivan + SATA
`Sullivan + SATA
`
`’057 Patent -Claim 40
`
`
`
`(Ex. 1002, Abstract.)
`
`9
`
`(Ex. 1002, Fig. 8.)
`
`’057 Patent -Claim 40
`Sullivan
`Sullivan
`
`
`
`10
`
`(Ex. 2061, ¶ 43; Reply, 5, 15.)
`
`“WRITE SECTOR” Command:
`
`’057 Patent -Claim 40
`SATA SATA
`
`
`
`(Ex. 1002, 1.)
`
`11
`
`’057 Patent -Claim 40
`Sullivan
`Sullivan
`
`
`
`12
`
`unreadable.” (Ex. 1006, ¶ 104; Pet., 12; Reply, 3-4, 8.)
`information would render the information unusable or
`device, and should not be changed because encrypting that
`information is used by the device, must be readable by the
`storage device and is suitable for encryption, but control
`which I discussed above, that user data is stored on a
`ordinary skill in the art at the time the ’057 Patent was filed,
`“Sullivan thus reflects the concept, well known to persons of
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`13
`
`Pet., 14-15, 30; Reply, 8, 19, 21.)
`information is transmitted in an unencrypted form.” (Ex. 1002, claim 9;
`information to the second device, where the associated control
`“transmitting the encrypted data with the associated control
`
`1; Pet., 12, 14-15, 30.)
`leave the control information substantially unaltered” (Ex. 1002, claim
`“an encrypt module configured to encrypt the data bits and to
`transmitted information” (Ex. 1002, ¶ [0006]; Pet., 12, 14, 22, 30, 34; Reply, 3-4, 8.)
`attacks and covert processes embedded in or achieved by the
`for both encryption purposes and for handling various types of
`the data and control information can be treated separately
`channel can be accomplished in-line and in real time, where
`“A system is needed whereby transmission of data in a serial
`’057 Patent -Claim 40
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`
`
`14
`
`original data.” (Ex. 1002, ¶ [0070]; Pet. 29, 43; Reply, 3, 6, 12.)
`“themeaning of the stored datawill be protected via the encryption of the
`information.” (Ex. 1002, ¶ [0035]; Reply,3, 6, 12.)
`encrypted … and thus storage unit 60 never receives unencrypted classified
`“[A]nydata passing through bus 65 to storage unit 60 (see FIG. 1) is
`the storage system.” (Ex. 1002, ¶ [0004] ; Reply, 3.)
`“encryption and decryption of the data as it is written to and retrieved from
`and decryption of the data ....” (Ex. 1002, ¶ [0004]; Reply, 3.)
`“One way to provide security to sensitive datais to use in-line encryption
`based systems.” (Ex. 1002, ¶ [0002]; see also¶¶ [0027],[0050]; Pet., 12, 29; Reply, 3.)
`“The present invention relates to encryption of data storedby processor-
`
`Data
`
`’057 Patent -Claim 40
`“Data” and “Control Information” in Sullivan
`“Data” and “Control Information” in Sullivan
`
`
`
`15
`
`have responded if the encryption unit were not present.” (Ex. 1002, ¶ [0051]; Reply, 17, 19.)
`encryption unit 90 in the same manner in which the target device would
`manufacturer, serialnumber, etc. of the target deviceis replied to by the
`“[A] command from the host 10 that requests information such as the
`data in a normal fashion….” (Ex. 1002, ¶ [0050]; Reply, 3, 8.)
`receive control information (including commands,header data, etc.) and
`“The encryption unit 90 is set up such that the host 10 can transmit and
`information ….” (Ex. 1002, ¶ [0010]; Pet.,14, 22, 30, 34; Reply,13.)
`“The control information, which may include commands and status
`
`Control Information
`
`’057 Patent -Claim 40
`“Data” and “Control Information” in Sullivan
`“Data” and “Control Information” in Sullivan
`
`
`
`16
`
`processed.” (Ex. 1001, 8:26-30; Pet., 5, 17-18; Reply, 13.)
`FISesin that particular command protocol will be cryptographically
`CDRWor sectors of a hard disk drive), the payloads of all data
`from/to physical storage media(such as optical tracks of a
`“if a SATAcommand protocol relates to reading/writing-data
`
`Data
`
`’057 Patent Excerpt
`’057 Patent Excerpt
`
`’057 Patent -Claim 40
`
`
`
`17
`
`bypassescryptographicengine22”(Ex. 1001, 7:31-33; Pet., 5, 17-18; Resp., 21.)
`device setup, configuration, and status inquiries
`“A data FISwith ATA commands that are associated with
`
`Control Information
`
`’057 Patent Excerpt
`’057 Patent Excerpt
`
`’057 Patent -Claim 40
`
`
`
`18
`
`(Ex. 1041, 65:19-22; Reply at 4.)
`A.Generally, yes, it would be unintelligible.”
`device?
`command, will the command be unintelligible to the
`“Q. Dr. Conte, if a storage device receives an encrypted
`
`protect sensitive information.” (Ex. 1041, 39:18-20; Reply at 3.)
`that time frame as today that encryption is used to
`“I think one of skill in the art would understand back in
`
`Dr. Conte
`Dr. Conte
`
`’057 Patent -Claim 40
`
`
`
`19
`
`(Ex. 1006, ¶ 109;Pet. 14.)
`describing a general ‘packet’ of information.”
`many serial protocols (including SATA) by
`“Sullivan teaches principles applicable to
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`20
`
`12.)
`SCSI, fibrechannel, and so on.” (Ex. 1002, ¶ [0038]; Pet., 13, 14, 24, 25, 42;Resp.,
`other suitable serial channels, such as serial ATA, serial
`1394) protocol buses, or they may be any of a number of
`“The serial channels herein may thus be Firewire® (IEEE
`
`transmission.”(Ex. 1002, ¶ [0069]; Reply, 8.)
`various types, such as multiple types of serial data
`and security system that can accommodate protocols of
`“This invention thus provides a high-speed, in-line encryption
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`21
`
`(Resp., 23 (citing Dr. Conte, Ex. 2061, ¶ 95); Reply, 4.)
`payloads for encryption and others do not.”
`other organizational structure in which some packets contain
`Sullivan actually discloses any different packet format or
`neither Petitioner nor Dr. Long point to any suggestion that
`operate with other serial protocols, including SATA,
`“But, other than Sullivan’s general disclosure that it can
`
`(Resp., 19 (citing Dr. Conte, Ex. 2061, ¶ 88); Reply, 4.)
`serial interfaces, including SATA.”
`processing of the serial packets used by the disclosed
`“Sullivan’s encryption approach is described as based on
`
`Patent Owner
`Patent Owner
`
`’057 Patent -Claim 40
`
`
`
`22
`
`(Ex. 1006, ¶ 111; Pet., 14-15; Reply, 3, 4.)
`
`control information, will be encrypted….”
`before encryption so that only the data, and not the
`information) will be separated from the payload
`packet), the header (which contains control
`the control information is in the header of the
`storage device is in the payload of the packet and
`of information (where the data to be written to a
`“Sullivan teaches that, when processing a ‘packet’
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`23
`
`target device….” (Ex. 1002, ¶ [0009]; Pet., 14, 30; Resp., 24; Reply, 4.)
`recombined with the header, and transmitted to the
`“The data is separated from the header, encrypted,
`
`(Ex. 1002, Fig. 8.)
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`24
`
`serial channel 65.” (Ex. 1006, ¶ 107; Pet., 13.)
`storage device to the cryptographic core 920 over another
`channel 50, while the cipher text interface 910 links a
`links the host to the cryptographic core 920 over a serial
`“Also as shown in Figure 11, the plain text interface 900
`Dr. Long:
`
`(Ex. 1002, Fig. 11.)
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`26, 42.)
`modules or other logic discussed above and shown in FIG. 2.” (Ex. 1002, [0062]; Pet., 13, 25,
`Between these two layers is the cryptographic core 920, which may include the
`the side of the unit 90 presented to a channel in which encrypted data may be sent.
`data may be sent. A cipher text interface 910 couples to serial channel 65, i.e. is on
`50, i.e. is on the side of the unit 90 presented to a channel in which unencrypted
`layers, as illustrated in FIG. 11. A plain text interface 900 couples to serial channel
`“The data encryption unit 90 may be implemented as a device with three logic
`
`25
`
`(Ex. 1002, Fig. 11.)
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`26
`
`plain text interface.”(Ex. 1002, ¶ [0064]; Pet., 13, 32.)
`“The filter module 730 … may be included in the
`
`(Ex. 1002, Fig. 11.)
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`27
`
`(Ex. 1006, ¶ 114; Pet. 15; Reply, 13.)
`processing.”
`transmitted to the cryptographic core for cryptographic
`associated with data or memory access and storage) will be
`the predetermined set of commands(i.e., those typically
`“Sullivan therefore teaches that only data associated with
`
`(Ex. 1006, ¶ 114; Pet. 15; Reply, 13.)
`further processing by the cryptographic core…..”
`pass only a ‘predetermined allowed set of commands’ for
`“Sullivan teaches that its filter module may be configured to
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`28
`
`(Ex. 1002, ¶ [0056]; Pet., 15, 32, 57; Resp., 28, 29, 47, 50; Reply, 6, 13, 21.)
`storage.”
`commands associated with data or memory access and
`“Typical allowed commands will be read, write, and other
`
`(Ex. 1002, ¶ [0055]; Pet., 15, 32, 57; Resp., 28, 30, 47-48; Reply, 6, 21, 22.)
`categories of information….”
`allowed set of commands, status and other information or
`other logic configured to pass only a predetermined
`module 730, which may include a look-up table, a formula or
`“The encryption unit in this embodiment includes a filter
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`(Ex. 1003, 1.)
`
`29
`
`SATA SATA
`’057 Patent -Claim 40
`
`
`
`30
`
`target device….” (Ex. 1002, [0009]; Pet., 14, 30; Resp., 24; Reply, 4.)
`recombined with the header, and transmitted to the
`“The data is separated from the header, encrypted,
`
`(Ex. 1002, Fig. 8.)
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`31
`
`(Ex. 2061, ¶ 42; Reply, 4.)
`the order of FISesfor various operations.”
`declaration. I generally agree with Dr. Long’s recitation of
`FIStransmissions, which Dr. Long describes in his
`“The command protocols dictate a prescribed sequence of
`Dr. Conte:
`
`(Ex. 1006, ¶ 96; Pet., 8-9; Reply, 4.)
`execute a particular command.”
`transmitted between the host and the device in order to
`“The SATAStandard also specifies the sequence of FISes
`Dr. Long
`
`Dr. Long and Dr. Conte
`Dr. Long and Dr. Conte
`
`’057 Patent -Claim 40
`
`
`
`32
`
`(Ex. 2061, ¶ 43; Reply, 5, 15.)
`SECTOR command, a PIOdata-out command.”
`correctly identifies the order of FIStransactions for a WRITE
`Dr. Conte: “For example, in the diagram [above], Dr. Long
`
`(Ex. 2061, ¶ 43; Reply, 5, 15.)
`Dr. Conte:
`
`(Ex. 1006, ¶ 97, Pet., 9.)
`Dr. Long:
`
`’057 Patent -Claim 40
`Dr. Long and Dr. Conte: WRITE SECTOR Command
`Dr. Long and Dr. Conte: WRITE SECTOR Command
`
`
`
`33
`
`standard.” (Ex. 1041, 36:11-12; Reply, 5.)
`“I verified this sequence was congruent with the [SATA]
`Dr. Conte:
`
`(Ex. 2061, ¶ 46; Reply, 5, 15.)
`Dr. Conte:
`
`(Ex. 1006, ¶ 98; Pet., 9.)
`Dr. Long:
`
`’057 Patent -Claim 40
`Dr. Long and Dr. Conte: READ DMA Command
`Dr. Long and Dr. Conte: READ DMA Command
`
`
`
`34
`
`[above].” (Ex. 2061, ¶ 45; Reply, 5, 15.)
`“Dr. Long correctly shows the series of FISesin the diagram
`Dr. Conte:
`
`(Ex. 2061, ¶ 45; Reply, 5, 15.)
`Dr. Conte:
`
`(Ex. 1006, ¶ 100; Pet., 9.)
`Dr. Long:
`
`’057 Patent -Claim 40
`Dr. Long and Dr. Conte: IDENTIFY DEVICE Command
`Dr. Long and Dr. Conte: IDENTIFY DEVICE Command
`
`
`
`35
`
`Long’s declaration.” (Ex. 2061, ¶ 44; Reply, 5, 15.)
`similar and is shown in the diagram [above], which is not in Dr.
`“A PIOdata-in operation reading data from the device is
`Dr. Conte:
`
`(Ex. 2061, ¶ 44; Reply 5, 15.)
`Dr. Conte:
`
`Dr. Conte: READ SECTOR Command
`Dr. Conte: READ SECTOR Command
`
`’057 Patent -Claim 40
`
`
`
`36
`
`were correct.” (Ex. 1041, 37:4-13 (objection omitted); Reply, 5.)
`would have been able to determine that Dr. Long’s examples
`A: In light of the SATAstandard, one of ordinary skill in the art
`
`SATA standard; is that right?
`have been aware of this sequence of FISesbased on the
`person of ordinary skill in the art in November of 2005 would
`guess, in paragraphs 43, 44, 45 and 46 of your declaration, a
`“Q: So for each of these examples that we’ve described, I
`
`Dr. Conte
`Dr. Conte
`
`’057 Patent -Claim 40
`
`
`
`37
`
`and the subsequent Data FISes.” (Ex. 1006, ¶ 101; Reply, 5-6, 11-12.)
`Standard creates an association between a command
`contents of those Data FISes. As a result, the SATA
`triggers the transmission of Data FISesand dictates the
`“Importantly, in SATA, execution of a particular command
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`38
`
`SECTOR.” (Ex. 2061, ¶ 45; Reply, 17.)
`with the same sequence of FISesas in my diagram above for READ
`command that sends control informationregarding the device to the host
`“As Dr. Long notes, the IDENTIFY DEVICE command is a PIOdata-in
`Dr. Conte:
`a Data FIScontaining control information.” (Ex. 1006, ¶101; Pet. 9-10; Reply, 4-5.)
`“In contrast, the ‘IDENTIFY_DEVICE’ command will be associated with
`Dr. Long:
`
`(Ex. 2061, ¶ 45; Ex. 1041, 29:6-37:13; Reply, 5.)
`IDENTIFY DEVICE command:
`Dr. Conte:
`
`Dr. Conte and Dr. Long
`Dr. Conte and Dr. Long
`
`’057 Patent -Claim 40
`
`
`
`39
`
`status type 34.” (Ex. 1041, 32:10-15, Reply, 5.)
`46 indicating or containing what Dr. Long would call user dataand then a
`back a packet indicating device ready and then a packet with a header of
`“This shows the host sending a packet to device, the device then sending
`Dr. Conte:
`
`disk.” (Ex. 1006, ¶101; Pet. 10.)
`a Data FIS containing user datapreviously stored on and read from the
`“For example, the “READ SECTOR(S)” command will be associated with
`Dr. Long:
`
`(Ex. 2061, ¶¶ 42-46; Ex. 1041, 29:6-37:13; Reply, 5.)
`READ SECTOR command:
`
`Dr. Conte and Dr. Long
`Dr. Conte and Dr. Long
`
`’057 Patent -Claim 40
`
`
`
`40
`
`type 34.” (Ex. 1041, 32:9-15; Reply, 5, 16.)
`indicating or containing what Dr. Long would call user data and then a status
`back a packet indicating device ready and then a packet with a header of 46
`“This shows the host sending a packet to device, the device then sending
`Dr. Conte:
`
`(Ex. 2061, ¶¶ 42-46; Ex. 1041, 29:6-37:13, Reply, 5.)
`READ SECTOR command:
`
`(Ex. 2061, ¶¶ 42-46; Ex. 1041, 29:6-37:13, Reply, 5.)
`IDENTIFY DEVICE command:
`
`Dr. Conte
`Dr. Conte
`
`’057 Patent -Claim 40
`
`
`
`Dr. Long:
`(Ex. 1006, ¶ 101; Pet. 10.)
`Type 27h) identifies the type of information in the associated Data FIS.”
`“As a result, a command in SATA (sent in a Register-Host to Device FIS or FIS
`be included in the Data FIS.”
`require different types of information (i.e., control information or user data) to
`Data FISes(FIS Type 46h), the commands associated with each Data FIS
`“Although the execution of both of these commands involves the transfer of
`Dr. Long:
`
`41
`
`(Ex. 2061, ¶¶ 42-46; Ex. 1041, 29:6-37:13, Reply, 5.)
`READ SECTOR command:
`
`(Ex. 2061, ¶¶ 42-46; Ex. 1041, 29:6-37:13, Reply, 5.)
`IDENTIFY DEVICE command:
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`42
`
`(Ex. 1006, ¶ 155; Reply, 4, 6, 16.)
`prior art elements according to their established functions.”
`would have been nothing more than the predictable use of
`control information. To one of ordinary skill in the art, this
`from a storage device without encrypting or decrypting
`in order to encrypt or decrypt data to be written to or read
`between the Data FISand its associated command in SATA,
`contained in a particular Data FIS, using the relationship
`would have been motivated to identify the type of information
`“[O]ne of skill in the art at the time the ’057 Patent was filed
`Dr. Long:
`
`’057 Patent -Claim 40
`Claim 1
`Claim 1
`
`
`
`43
`
`(Ex. 1006, ¶ 156; Reply, 6.)
`control, or status information.”
`storage device without encrypting or decrypting command,
`encrypt or decrypt data to be written to or read from a
`person would have been motivated to do so in order to
`commands, such as read and write commands. Such a
`data associated with a predetermined allowed set of
`therefore could be used to encrypt (and then decrypt) only
`was filed would have appreciated that Sullivan’s filter
`“One of ordinary skill in the art at the time the ’057 Patent
`Dr. Long:
`
`’057 Patent -Claim 40
`Claim 1
`Claim 1
`
`
`
`44
`
`encrypted.” (Resp., 26 (emphasis added); Reply, 9.)
`the payloads of even non-Data FISeswould be
`would result in a non-functional system in which
`“Following this approach, as Dr. Long suggests,
`
`Patent Owner
`Patent Owner
`
`’057 Patent -Claim 40
`
`
`
`45
`
`(Resp., 31-32 (citing Ex. 2061, ¶ 106); Reply, 11.)
`Sullivan’s filter module embodiment would reject this packet.”
`“Since a Data FIS does not contain any ‘allowed command,’
`
`(Resp., 31-32 (citing Ex. 2061, ¶ 106); Reply, 11.)
`command itself would be encrypted….”
`Sullivan’s disclosure would be treated in the same way: the
`“A read command, also one that would be ‘allowed’ per
`Dr. Conte:
`
`Patent Owner
`Patent Owner
`
`’057 Patent -Claim 40
`
`
`
`parallel ATA protocol.” (Ex. 2061, ¶ 27; Reply, 14.)
`“The SATAprotocol was developed as a high-speed replacement for the then-popular
`of the references on which the Board instituted review.”(Ex. 2061, ¶41; Reply, 5)
`Petitions rely; they are described by the ATA specificationitself, which is not itself one
`various command protocols is outside the scope of the SATAStandard on which the
`Dr. Conte:“The purpose and function of the individual commandsdescribed by the
`
`46
`
`(Ex. 1003, 13; Reply, 5.)
`
`SATA:
`
`’057 Patent -Claim 40
`SATA SATA
`
`
`
`47
`
`(5)Alleged evidence of secondary considerations
`(4)“layers” limitations in claims 16-19, 28-32
`(3)“command set” limitations in claims 7, 9
`(2)“bypass” limitations in claims 5, 16, 17, 19
`(1)“association” limitation in claim 1
`Agenda:
`
`IPR2014-01178 Claims 1-32
`IPR2014-01178 Claims 1-32
`
`’057 Patent -Claim 40
`
`
`
`(Ex. 1001, claims 5, 16, 17, 19.)
`
`48
`
`19. The cryptographic SATAapparatus ofclaim 18, wherein a bypass control signal
`
`or bypassa data FISreceived by the cryptographic engine.
`cryptographic engine responsive to the bypass flag signal to encrypt, decrypt
`signal in said main controller to generate a bypass flag signal, said at least one
`provided by said ATA command filter is logically ORedwith a bypass preset
`
`17. The cryptographic SATAapparatus ofclaim 16, wherein the FIStype detector is
`
`said decoded FISto bypasssaid at least one cryptographic engine.
`type field not having a hexadecimal value of 0x46, said main controller causing
`configured to determine the FISdecoded at said Link Layer responsive to the
`
`or bypassing.
`decoded FISto be sent to said cryptographic engine for encryption, decryption
`type field having a hexadecimal value of 0x46, said main controller causing said
`configured to determine the FISdecoded at said Link Layer responsive to said
`
`16. The cryptographic SATAapparatus ofclaim 15, wherein the FIStype detector is
`
`cryptographic engine.
`whether to encrypt, decrypt, or bypassthe data FISes received at the
`configured to send a signal to the cryptographic engine, the signal instructing
`5. The cryptographic SATA apparatus ofclaim 1, wherein said main controller is
`
`’057 Patent -Claim 40
`’057 Patent –Claims 5, 16, 17, 19
`’057 Patent –Claims 5, 16, 17, 19
`
`
`
`49
`
`are rejected and filtered out.” (Resp., 47; Reply 20.)
`passed to the cryptographic module and encrypted, or they
`packets that reach the cryptographic module: they are
`limitations because it “permits only two operations for
`
`•Sullivan’s filter module “teaches away” from these
`
`would know to do so.” (Resp., 45; Reply, 19.)
`support for its claim that a person of ordinary skill in the art
`option to bypass the Data FIS, and Seagate presents no
`•“[N]either Sullivan nor the SATA Standard discloses the
`obvious because:
`Patent Owner asserts that these limitations would not be
`
`Patent Owner
`Patent Owner
`
`’057 Patent -Claim 40
`
`
`
`50
`
`(Ex. 1002, claim 9; Pet., 14-15, 30; Reply, 8, 19, 21.)
`
`is transmitted in an unencrypted form.”
`device, where the associated control information
`associated control information to the second
`“transmitting the encrypted data with the
`
`Sullivan Excerpt
`
`
`
`51
`
`garbled and not useable by the host.” (Ex. 2061, ¶ 90; Reply, 4, 17.)
`host adapter, the resulting ‘decrypted’ data would be
`processed as they are sent from the storage device to the
`the IDENTIFY DEVICE command] are cryptographically
`regarding device capabilities [i.e., control information from
`“For example, if the DATA FISescarrying the data
`Dr. Conte:
`
`(Ex. 2061, ¶ 45; Reply 17.)
`
`Dr. Conte
`
`
`
`52
`
`(Ex. 1006, ¶ 167; Resp., 46; Reply, 3, 19.)
`those Data FISesincluded user data or control information.”
`received at the cryptographic engine, depending on whether
`encrypting, decrypting, or bypassing the Data FISes
`understood Sullivan in view of the SATA Standard to teach
`decrypted…. Thus, one of ordinary skill in the art would have
`associated with that command should not be encrypted or
`‘Identify Device’ command, and that payloads of Data FISes
`contain control information, for example, in response to an
`was filed would have known that Data FISesmay also
`“One of ordinary skill in the art at the time the ’057 Patent
`Dr. Long
`
`Dr. Long
`
`
`
`53
`
`(Ex. 2060, 71:24-72:10; Reply, 20.)
`
`disk drive operations of reading and writing.”
`you had a limited function device where you do just the basic
`way, I suppose, if you wanted to. If you wanted to have a --if
`A. Right. I don’t think it requires that. You could do it that
`Q. I’m just focusing on this embodiment.
`embodiment.
`A. Not necessarily. First of all, this is an alternative
`Or I should say has its data encrypted or decrypted.”
`is encrypted or decrypted, depending on the data direction.
`“Q. Okay. So every command that makes it through this filter
`
`Dr. Long
`
`
`
`54
`
`(5)Alleged evidence of secondary considerations
`(4)“layers” limitations in claims 16-19, 28-32
`(3)“command set” limitations in claims 7, 9
`(2)“bypass” limitations in claims 5, 16, 17, 19
`(1)“association” limitation in claim 1
`Agenda:
`
`IPR2014-01178 Claims 1-32
`IPR2014-01178 Claims 1-32
`
`’057 Patent -Claim 40
`
`
`
`55
`
`WRITE DMA EXT command.
`WRITE BUFFER command, WRITE DMA command, and
`MULTIPLE command, WRITE MULTIPLE EXT command,
`SECTOR command, WRITE SECTOR EXT command, WRITE
`pre-defined category of command set comprises WRITE
`9. The cryptographic SATAapparatus ofclaim 8, wherein the
`
`DMA EXT command.
`READ BUFFER command, READ DMA command, and READ
`MULTIPLE command, READ MULTIPLE EXT command,
`SECTOR command, READ SECTOR EXT command, READ
`pre-defined category of command set comprises READ
`7. The cryptographic SATA apparatus ofclaim 1, wherein the
`
`’057 Patent -Claims 7, 9
`’057 Patent -Claims 7, 9
`
`’057 Patent -Claim 40
`
`
`
`56
`
`•“The SATA Standard itself does not group commands in
`because:
`Patent Owner asserts claims 7 and 9 would not be obvious
`
`•The “allowed” commands in Sullivan include commands
`22.)
`disclosure of particular SATA commands” (Resp., 48-51; Reply, 20-
`this manner” and “Sullivan does not include any
`
`cryptographically processed.” (Resp., 50; Reply, 21.)
`that “do not transport user data and should not be
`
`Patent Owner’s Arguments
`
`
`
`57
`
`access and storage.” (Ex. 1002, ¶ [0056]; Pet., 15, 32, 57; Resp., 28, 29, 47, 50;
`other commands associated with data or memory
`“Typical allowed commands will be read, write, and
`
`Reply, 6, 13, 16, 21.)
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`58
`
`original data.” (Ex. 1002, ¶ [0070]; Pet. 29, 43; Reply, 3, 6, 12.)
`“themeaning of the stored datawill be protected via the encryption of the
`information.” (Ex. 1002, ¶ [0035]; Reply,3, 6, 12.)
`encrypted … and thus storage unit 60 never receives unencrypted classified
`“[A]nydata passing through bus 65 to storage unit 60 (see FIG. 1) is
`the storage system.” (Ex. 1002, ¶ [0004] ; Reply, 3.)
`“encryption and decryption of the data as it is written to and retrieved from
`and decryption of the data ....” (Ex. 1002, ¶ [0004]; Reply, 3.)
`“One way to provide security to sensitive datais to use in-line encryption
`based systems.” (Ex. 1002, ¶ [0002]; see also¶¶ [0027],[0050]; Pet., 12, 29; Reply, 3.)
`“The present invention relates to encryption of data storedby processor-
`
`Data
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`59
`
`as recognized by the ’057 patent itself.” (Ex. 1006, ¶ 176; Reply, 16.)
`write commands explicitly taught in the SATAStandard,
`“The specific commands recited in this claim [claim 9] are
`
`recognized by the ’057 patent itself.” (Ex. 1006, ¶ 171; Reply, 16.)
`commands explicitly taught in the SATAStandard, as
`“The specific commands recited in claim 7 are read
`Dr. Long
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`60
`
`processed.” (Ex. 1001, 8:26-30; Pet., 5, 17-18; Reply, 13.)
`FISesin that particular command protocol will be cryptographically
`CDRWor sectors of a hard disk drive), the payloads of all data
`from/to physical storage media(such as optical tracks of a
`“if a SATAcommand protocol relates to reading/writing-data
`
`Data
`
`’057 Patent Excerpt
`’057 Patent Excerpt
`
`’057 Patent -Claim 40
`
`
`
`61
`
`skill in the art.” (Ex. 1006, ¶ 171; Reply, 17, 21.)
`according to their established functions to one of ordinary
`nothing more than a predictable use of prior art elements
`FISesassociated with those commands would have been
`implementing SATAand decrypting the payloads of Data
`storage device to a host, using those commands when
`commands cause the transmission of user data from a
`Patent was filed would have appreciated that the recited
`“Because one of ordinary skill in the art at the time the ’057
`Dr. Long:
`
`Dr. Long
`Dr. Long
`
`’057 Patent -Claim 40
`
`
`
`62
`
`(Exhibit 1041, 80:3-11; Reply, 16.)
`comprehensive list.”
`A: They may well be examples, but it is not a
`
`computer to a storage device?
`the purpose of transferring a Word document from a host
`would be examples of commands that could be used for
`the write commands contained on [Ex. 2061] page 21
`person of ordinary skill in the art would understand that
`“Q:Yeah. My question was, would you agree that a
`
`Dr. Conte
`Dr. Conte
`
`’057 Patent -Claim 40
`
`
`
`63
`
`(5)Alleged evidence of secondary considerations
`(4)“layers” limitations in claims 16-19, 28-32
`(3)“command set” limitations in claims 7, 9
`(2)“bypass” limitations in claims 5, 16, 17, 19
`(1)“association” limitation in claim 1
`Agenda:
`
`IPR2014-01178 Claims 1-32
`IPR2014-01178 Claims 1-32
`
`’057 Patent -Claim 40
`
`
`
`64
`
`•“Proposed combination does not teach ‘digging inside’ a
`53.)
`layers recited in claims 16-19 and 28-32 (Reply, 22-23; Resp., 51-
`or “FIS Type detector” operating at the specific SATA
`
`•The prior art does not disclose an “ATA command filter”
`be obvious because:
`Patent Owner asserts claims 16-19 and 28-32 would not
`
`52-53; Reply, 22-23.)
`purposes, as the ’057 Patent teaches and claims.” (Resp.,
`FISin order to more quickly sort it for cryptographic
`
`Patent Owner
`
`
`
`65
`
`“Patent Owner does not contest or even address that showing.”
`
`(Reply, 22.)
`
`•Petitioners and Dr. Long provided a detailed analysis showing
`Claim 19
`
`artisan. (Pet., 50-51 (citing Ex. 1006, ¶¶ 193-195); Reply, 22-23.)
`that the limitations of claim 19 would be obvious to a skilled
`
`1006, ¶¶ 190-191); Reply, 22-23.)
`have a ATA command filter at the Transport layer. (Pet., 50 (citing Ex.
`•Petitioners and Dr. Long demonstrated it would be obvious to
`Claim 18
`
`•Claims 16 & 17 require a FIStype detector at the Transport layer,
`Claims 16 & 17
`
`which is taught by SATA. (Pet., 48-50 (citing Ex. 1006, ¶¶ 186-188); Reply, 22-23.)
`
`Petitioner
`Petitioner
`
`’057 Patent -Claim 40
`
`
`
`66
`
`(Reply, 22.)
`“Patent Owner does not contest or even address that showing.”
`
`22-23.)
`would have been obvious. (Pet., 56-59 (citing Ex. 1006, ¶¶ 205-208); Reply,
`using the defined values from SATAthat identify that FIS,
`command filter identifying a Register-Host to Device FIS
`a command field of a FISat said Link layer, with the ATA
`showing that providing an ATA command filter for examining
`
`•Petitioners and Dr. Long provided a detailed analysis
`Claims 28-32
`
`Petitioner
`Petitioner
`
`’057 Patent -Claim 40
`
`
`
`67
`
`(5)Alleged evidence of secondary considerations
`(4)“layers” limitations in claims 16-19, 28-32
`(3)“command set” limitations in claims 7, 9
`(2)“bypass” limitations in claims 5, 16, 17, 19
`(1)“association” limitation in claim 1
`Agenda:
`
`IPR2014-01178 Claims 1-32
`IPR2014-01178 Claims 1-32
`
`’057 Patent -Claim 40
`
`
`
`Patent No. 7,900,057
`
`Case No. IPR2014-01178
`
`November 2, 2015
`
`Seagate Technology (US) Holdings, Inc.,
`
`and Seagate Technology LLC,
`
`Petitioners
`
`Enova Technology Corp.,
`
`Patent Owner
`
`v.
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