Patent No. 7,900,057
`
`Case No. IPR2014-01297
`
`November 2, 2015
`
`Seagate Technology (US) Holdings, Inc.,
`
`and Seagate Technology LLC,
`
`Petitioners
`
`Enova Technology Corp.,
`
`Patent Owner
`
`v.
`
`
`
`Case No. IPR2014-01297
`
`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
`
`(4)Alleged evidence of secondary considerations
`(3)“command set” limitations in claims 36-38
`(2)“command set” limitations in claims 34, 39
`(1)“association” limitation in claim 33
`Agenda
`
`IPR2014-01297 Claims 33-39
`IPR2014-01297 Claims 33-39
`
`’057 Patent -Claim 40
`
`
`
`5
`
`(4)Alleged evidence of secondary considerations
`(3)“command set” limitations in claims 26-38
`(2)“command set” limitations in claims 34, 39
`(1)“association” limitation in claim 33
`Agenda
`
`IPR2014-01297 Claims 33-39
`IPR2014-01297 Claims 33-39
`
`’057 Patent -Claim 40
`
`
`
`6
`
`from the device interface.
`interface without decryption responsive to receiving the Register-Device to Host FIS
`the SATAdevice protocol stack to process a Register-Device to Host FISto the host
`first data FISto the host interface; and
`the SATAdevice protocol stack to send the decrypted portion of the first payload of the
`the SATAhost protocol stack;
`the cryptographic engine to decrypt at least a portion of the first payload received from
`category of command set;
`cryptographic engine responsive to the first data FISassociated with a pre-defined
`the SATAhost protocol stack to send at least first payload of a first data FISto the
`
`configured to cause:
`a main controller implemented at least partially in hardware, the main controller
`(Frame Information Structures) communicated to or from the device interface; and
`the SATAhost protocol stack for encrypting or decrypting at least a subset of data FISes
`a cryptographic engine operatively coupled between the SATAdevice protocol stack and
`a SATAhost protocol stack for communicating with a device interface of a SATAdevice;
`a SATAdevice protocol stack for communicating with a host interface of a SATAhost;
`33. A cryptographic Serial ATA (SATA) apparatus, comprising:
`
`’057 Patent: Claim 33
`’057 Patent: Claim 33
`
`’057 Patent -Claim 40
`
`
`
`7
`
`from the device interface.
`interface without decryption responsive to receiving the Register-Device to Host FIS
`the SATAdevice protocol stack to process a Register-Device to Host FISto the host
`first data FISto the host interface; and
`the SATAdevice protocol stack to send the decrypted portion of the first payload of the
`the SATAhost protocol stack;
`the cryptographic engine to decrypt at least a portion of the first payload received from
`category of command set;
`cryptographic engine responsive to the first data FISassociated with a pre-defined
`the SATAhost protocol stack to send at least first payload of a first data FISto the
`
`configured to cause:
`a main controller implemented at least partially in hardware, the main controller
`(Frame Information Structures) communicated to or from the device interface; and
`the SATAhost protocol stack for encrypting or decrypting at least a subset of data FISes
`a cryptographic engine operatively coupled between the SATAdevice protocol stack and
`a SATAhost protocol stack for communicating with a device interface of a SATAdevice;
`a SATAdevice protocol stack for communicating with a host interface of a SATAhost;
`33. A cryptographic Serial ATA (SATA) apparatus, comprising:
`
`’057 Patent: Claim 33
`’057 Patent: Claim 33
`
`’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, 16.)
`
`“WRITE SECTOR” Command:
`
`’057 Patent -Claim 40
`SATA SATA
`
`
`
`(Ex. 1002, 1.)
`
`11
`
`’057 Patent -Claim 40
`Sullivan
`Sullivan
`
`
`
`12
`
`unreadable.” (Ex. 1006, ¶ 96; Pet., 11; Reply, 3-4.)
`that information would render the information unusable or
`by the drive, and should not be changed because encrypting
`information is used by the hard disk drive, must be readable
`of a hard disk drive and is suitable for encryption, but control
`which I discussed above, that user data is stored on the disk
`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, 30, 32, 41, 46; Reply, 8, 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., 14-15, 20, 30, 37, 41; Reply, 4.)
`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., 11, 14, 20, 30, 32; 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, 3-4, 6, 12.)
`“themeaning of the stored datawill be protected via the encryption of the
`information.” (Ex. 1002, ¶ [0035]; Reply,3-4, 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., 11; 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
`
`responded if the encryption unit were not present.” (Ex. 1002, ¶ [0051]; Reply, 17-18.)
`encryption unit in the same manner in which the target device would have
`manufacturer, serialnumber, etc. of the target deviceis replied to by the
`“[A] command from the host that requests information such as the
`data in a normal fashion….” (Ex. 1002, ¶ [0050]; Reply, 3-4, 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., 20, 30, 37,41; 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; Reply, 13, 16.)
`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
`
`engine22”(Ex. 1001, 7:31-33; Pet., 5, 17; Resp., 21.)
`setup, configuration, and status inquiriesbypassescryptographic
`“A data FISwith ATA commands that are associated with device
`
`Control Information
`
`’057 Patent Excerpt
`’057 Patent Excerpt
`
`’057 Patent -Claim 40
`
`
`
`18
`
`(Ex. 1041, 65:19-22; Reply, 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, 3-4.)
`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, ¶ 101; Pet. 13.)
`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., 12, 21, 23-26, 31; 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, 8-9.)
`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, ¶ 104; Reply, 8, 17-18.)
`
`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., 30-31; 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
`
`1006, ¶ 99; Pet., 12.)
`cryptographic core 920 over another serial channel 65.” (Ex.
`cipher text interface 910 links a storage device to the
`cryptographic core 920 over a serial channel 50, while the
`“In Sullivan, the plain text interface 900 links the host to the
`Dr. Long:
`
`(Ex. 1002, Fig. 11.)
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`24, 26, 35, 45)
`modules or other logic discussed above and shown in FIG. 2.” (Ex. 1002, ¶ [0062]; Pet., 12,
`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., 12.)
`“The filter module 730 … may be included in the
`
`(Ex. 1002, Fig. 11.)
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`27
`
`(Ex. 1006, ¶ 109; Pet. 14; 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, ¶ 109; Pet. 14; 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., 14-15, 33, 43; Resp., 28, 29, 47-48, 49; 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., 14, 33, 43; Resp., 29, 31; 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., 30-31; 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, ¶ 88; Pet., 8; 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, 15-16.)
`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, 15-16.)
`
`Dr. Conte:
`
`(Ex. 1006, ¶ 89; Pet., 8.)
`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, 15-16.)
`Dr. Conte:
`
`(Ex. 1006, ¶ 90; Pet., 8.)
`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, 15-16.)
`“Dr. Long correctly shows the series of FISesin the diagram
`Dr. Conte:
`
`(Ex. 2061, ¶ 45; Reply, 5, 15-16.)
`Dr. Conte:
`
`(Ex. 1006, ¶ 92; Pet., 8.)
`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, 15-16.)
`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, 15-16.)
`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, ¶ 93; Reply, 6, 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, ¶ 93; Pet. 10; Reply, 6.)
`“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 data and 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, ¶93; 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, ¶93; 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, ¶ 147; Reply, 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 33
`Claim 33
`
`
`
`43
`
`(Ex. 1006, ¶ 148; Reply, 6.)
`information.”
`without encrypting or decrypting command, control, or status
`user data to be written to or read from a storage device
`have been motivated to do so in order to encrypt or decrypt
`such as read and write commands. Such a person would
`associated with a predetermined allowed set of commands,
`therefore could be used to encrypt or decrypt only data
`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 33
`Claim 33
`
`
`
`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., 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., 32-33 (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
`
`(4)Alleged evidence of secondary considerations
`(3)“command set” limitations in claims 36-38
`(2)“command set” limitations in claims 34, 39
`(1)“association” limitation in claim 33
`Agenda
`
`IPR2014-01297 Claims 33-39
`IPR2014-01297 Claims 33-39
`
`’057 Patent -Claim 40
`
`
`
`48
`
`command, and WRITE DMA EXT command.
`command, WRITE BUFFER command, WRITE DMA
`WRITE MULTIPLE command, WRITE MULTIPLE EXT
`SECTOR command, WRITE SECTOR EXT command,
`the pre-defined category of command set comprises WRITE
`39. The cryptographic SATAapparatus ofclaim 35, wherein
`
`READ DMA EXT command.
`READ BUFFER command, READ DMA command, and
`MULTIPLE command, READ MULTIPLE EXT command,
`SECTOR command, READ SECTOR EXT command, READ
`the pre-defined category of command set comprises READ
`34. The cryptographic SATAapparatus ofclaim 33, wherein
`
`’057 Patent -Claims 34 and 39
`’057 Patent -Claims 34 and 39
`
`’057 Patent -Claim 40
`
`
`
`49
`
`•The “allowed” commands in Sullivan include commands
`21.)
`disclosure of particular SATA commands” (Resp., 48-50; Reply, 20-
`this manner” and “Sullivan does not include any
`
`•“The SATA Standard itself does not group commands in
`obvious because:
`Patent Owner asserts claims 34 and 39 would not be
`
`cryptographically processed.” (Resp., 49-50; Reply, 21.)
`that “do not transport user data and should not be
`
`Patent Owner
`
`
`
`50
`
`(Ex. 1002, ¶ [0056]; Pet., 14-15, 33, 43; Resp., 28, 29, 47-48, 49; Reply, 6, 13, 21.)
`
`access and storage.”
`other commands associated with data or memory
`“Typical allowed commands will be read, write, and
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`51
`
`original data.” (Ex. 1002, ¶ [0070]; Pet. 29, 43; Reply, 3-4, 6, 12.)
`“themeaning of the stored datawill be protected via the encryption of the
`information.” (Ex. 1002, ¶ [0035]; Reply,3-4, 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., 11; Reply, 3.)
`“The present invention relates to encryption of data storedby processor-
`
`Data
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`52
`
`(Ex. 1001 at 8:11-35).” (Ex. 1006, ¶ 171; Reply, 17.)
`1003 at 252, 254), as recognized by the ’057 patent itself
`commands were copied from the SATAStandard (Ex.
`writing user data to a storage device and that these
`“[T]he commands in claim 39 are write commands for
`
`21.)
`’057 Patent itself (Ex. 1001 at 8:11-35).” (Ex. 1006, ¶ 156; Reply, 16,
`Standard (Ex. 1003 at 250, 253), as recognized by the
`and that these commands were copied from the SATA
`commands for reading user data from a storage device,
`“[T]he specific commands recited in claim 34 are read
`Dr. Long
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`53
`
`cryptographically processed.” (Ex. 1001, 8:26-30; Pet. 5, 17; Reply, 13, 16.)
`FISesin that particular command protocol will be
`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
`
`
`
`54
`
`commands.” (Ex. 1006, ¶ 156; Reply, 16, 17, 21.)
`payloads of Data FISesassociated with those read
`skill in the art would have found it obvious to decrypt the
`read from a storage device is decrypted, one of ordinary
`1001 at 8:11-35). Because Sullivan teaches that user data
`SATAStandard, as recognized by the ’057 Patent itself (Ex.
`device, and that these commands were copied from the
`read commands for reading user data from a storage
`known that the specific commands recited in claim 34 are
`“In my opinion, one of ordinary skill in the art would have
`Dr. Long:
`
`Dr. Long
`Dr. Long
`
`’057 Patent -Claim 40
`
`
`
`55
`
`(Exhibit 1041, 80:3-11; Reply, 16-17.)
`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
`
`
`
`56
`
`(4)Alleged evidence of secondary considerations
`(3)“command set” limitations in claims 36-38
`(2)“command set” limitations in claims 34, 39
`(1)“association” limitation in claim 33
`Agenda
`
`IPR2014-01297 Claims 33-39
`IPR2014-01297 Claims 33-39
`
`’057 Patent -Claim 40
`
`
`
`57
`
`command set carries status information.
`the data FISnot associated with the pre-defined category of
`38. The cryptographic SATAapparatus ofclaim 35, wherein
`
`command set carries control information.
`the data FISnot associated with the pre-defined category of
`37. The cryptographic SATAapparatus ofclaim 35, wherein
`
`command set carries command information.
`the data FISnot associated with the pre-defined category of
`36. The cryptographic SATAapparatus ofclaim 35, wherein
`
`’057 Patent -Claims 36-38
`’057 Patent -Claims 36-38
`
`’057 Patent -Claim 40
`
`
`
`58
`
`cryptographically processed.”(Resp. 48; Reply, 20.)
`command, control, or status information, should not be
`•“Data FISesassociated with these commands, carrying
`
`•The filter in Sullivan would “allow” certain commands that
`
`itself.” (Resp. 48; Reply, 20.)
`“access data in memory and/or on the storage media
`
`associations….” (Resp., 47; Reply, 19.)
`Sullivan or the SATAStandard which teaches these
`•“[T]he Petition fails to disclose any disclosure in the
`because:
`Patent Owner asserts claims 36-38 would not be obvious
`
`Patent Owner
`
`
`
`59
`
`encrypted.” (Reply, 20.)
`skilled artisan that control information should not be
`“omits the knowledge and common sense of a
`than user data and not encrypted” (Reply, 20.)
`control information should be treated differently
`“ignores Sullivan’s actual teachings that such
`filter module”(Reply, 20.)
`“misconstrues Sullivan’s teachings regarding the
`
`•
`
`•
`
`•
`
`Patent owner’s argument:
`
`Petitioner
`Petitioner
`
`’057 Patent -Claim 40
`
`
`
`60
`
`(4)Alleged evidence of secondary considerations
`(3)“command set” limitations in claims 26-38
`(2)“command set” limitations in claims 34, 39
`(1)“association” limitation in claim 33
`Agenda
`
`IPR2014-01297 Claims 33-39
`IPR2014-01297 Claims 33-39
`
`’057 Patent -Claim 40
`
`
`
`Patent No. 7,900,057
`
`Case No. IPR2014-01297
`
`November 2, 2015
`
`Seagate Technology (US) Holdings, Inc.,
`
`and Seagate Technology LLC,
`
`Petitioners
`
`Enova Technology Corp.,
`
`Patent Owner
`
`v.
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