Patent No. 7,900,057
`
`Case No. IPR2014-01449
`
`November 2, 2015
`
`Seagate Technology (US) Holdings, Inc.,
`
`and Seagate Technology LLC,
`
`Petitioners
`
`Enova Technology Corp.,
`
`Patent Owner
`
`v.
`
`
`
`Case No. IPR2014-01449
`
`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 44, 47, 50, 53
`(2)“pass” limitation in claim 40
`(1)“association” limitations in claims 40-42, 45, 48, 51
`Agenda
`
`IPR2014-01449 Claims 40-53
`IPR2014-01449 Claims 40-53
`
`’057 Patent -Claim 40
`
`
`
`5
`
`(4)Alleged evidence of secondary considerations
`(3)“command set” limitations in claims 44, 47, 50, 53
`(2)“pass” limitation in claim 40
`(1)“association” limitations in claims 40-42, 45, 48, 51
`Agenda
`
`IPR2014-01449 Claims 40-53
`IPR2014-01449 Claims 40-53
`
`’057 Patent -Claim 40
`
`
`
`6
`
`command FIS.
`completion of an operation or an aborted operation associated with the PIOdata-out
`received from said device interface, said Register-Device to Host FIS representing
`
`said cryptographic SATA apparatus detecting a Register-Device to Host FIS
`
`said cryptographic SATA apparatus encrypting said detected data FIS payload;
`
`and
`
`said cryptographic SATA apparatus detecting a data FIS payload received from
`
`said host interface;
`
`said cryptographic SATA apparatus passing a PIOsetup FIS received from a
`
`device interface to the host interface;
`
`requires setting in encryption mode;
`out command FIS is associated with a pre-defined category of command set that
`said cryptographic SATA apparatus determining whether the received PIOdata-
`
`data-out command FIS (Frame Information Structure) received from a host interface;
`
`a cryptographic SATA apparatus detecting a PIO(Programmed Input/Output)
`
`40. A cryptographic method, comprising the steps of:
`
`’057 Patent -Claim 40
`’057 Patent –Claim 40
`’057 Patent –Claim 40
`
`
`
`7
`
`command FIS.
`completion of an operation or an aborted operation associated with the PIOdata-out
`received from said device interface, said Register-Device to Host FIS representing
`
`said cryptographic SATA apparatus detecting a Register-Device to Host FIS
`
`said cryptographic SATA apparatus encrypting said detected data FIS payload;
`
`and
`
`said cryptographic SATA apparatus detecting a data FIS payload received from
`
`said host interface;
`
`said cryptographic SATA apparatus passing a PIOsetup FIS received from a
`
`device interface to the host interface;
`
`requires setting in encryption mode;
`out command FIS is associated with a pre-defined category of command set that
`said cryptographic SATA apparatus determining whether the received PIOdata-
`
`data-out command FIS (Frame Information Structure) received from a host interface;
`
`a cryptographic SATA apparatus detecting a PIO(Programmed Input/Output)
`
`40. A cryptographic method, comprising the steps of:
`
`’057 Patent -Claim 40
`’057 Patent –Claim 40
`’057 Patent –Claim 40
`
`
`
`(Ex. 1003, 1.)
`
`8
`
`(Ex. 1002, 1.)
`
`Sullivan + SATA
`Sullivan + SATA
`
`’057 Patent -Claim 40
`
`
`
`(Ex. 1002, Fig. 8, Abstract.)
`
`9
`
`’057 Patent -Claim 40
`Sullivan
`Sullivan
`
`
`
`10
`
`(Ex. 2061, ¶ 43; Reply, 16.)
`
`“WRITE SECTOR” Command:
`
`’057 Patent -Claim 40
`SATA SATA
`
`
`
`(Ex. 1002, 1.)
`
`11
`
`’057 Patent -Claim 40
`Sullivan
`Sullivan
`
`
`
`12
`
`(Ex. 1006, ¶ 100; Reply, 3, 4, 8.)
`render the information unusable or unreadable.”
`be changed because encrypting that information would
`disk drive, must be readable by the drive, and should not
`encryption, but control information is used by the hard
`on the disk of a hard disk drive and is suitable for
`filed, which I discussed above, that user data is stored
`of ordinary skill in the art at the time the ’057 Patent was
`“Sullivan thus reflects the concept well-known to persons
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`13
`
`Pet., 13-14, 15, 26; Reply, 8, 20, 22.)
`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., 13-14, 15, 26.)
`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., 15, 21, 26; 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]; Reply, 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]; Pet., 12, 29, 43; 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, 18.)
`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.)
`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.,21 26, 48;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
`
`(Ex. 1001, 8:26-30; Pet., 5, 19; Reply, 13.)
`particular command protocol will be cryptographically processed.”
`or sectors of a hard disk drive), the payloads of all data FISesin that
`from/to physical storage media(such as optical tracks of a CDRW
`“if a SATA command protocol relates to reading/writing-data
`
`Data
`
`’057 Patent Excerpt
`’057 Patent Excerpt
`
`’057 Patent -Claim 40
`
`
`
`17
`
`(Ex. 1001, 7:31-33; Pet., 5, 19; Resp., 20.)
`cryptographicengine22”
`setup, configuration, and status inquiriesbypasses
`“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.)
`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, ¶ 105; Pet., 14.)
`general ‘packet’ of information.”
`serial protocols (including SATA) by describing a
`“Sullivan teaches principles applicable to many
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`20
`
`SCSI, fibrechannel, and so on.” (Ex. 1002, ¶ [0038]; Pet., 14; Reply, 4, 9.)
`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, 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., 22 (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., 18 (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, ¶ 155 (citations and editorial marks omitted); Pet., 26; Reply, 4.)
`data is encrypted.”
`control information in the header so that only the user
`the encryption operation, the data is separated from the
`the user data is placed in the body of the packet. During
`information) is placed in the header of the packet and
`control information (e.g., commands and status
`“In particular, Sullivan describes a ‘packet’ in which
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`23
`
`device….” (Ex. 1002, ¶ [0009]; Pet., 26; Resp., 23; Reply, 4.)
`recombined with the header, and transmitted to the target
`“The data is separated from the header, encrypted,
`
`(Ex. 1002, Fig. 8.)
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`24
`
`(Ex. 1006, ¶ 103; Pet., 15.)
`cryptographic core 920 over another serial channel 65.”
`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
`
`
`
`25
`shown in FIG. 2.” (Ex. 1002, ¶ [0062]; Pet., 14.)
`core 920, which may include the modules or other logic discussed above and
`encrypted data may be sent. Between these two layers is the cryptographic
`channel 65, i.e. is on the side of the unit 90 presented to a channel in which
`unencrypted data may be sent. A cipher text interface 910 couples to serial
`channel 50, i.e. is on the side of the unit 90 presented to a channel in which
`layers, as illustrated in FIG. 11. A plain text interface 900 couples to serial
`“The data encryption unit 90 may be implemented as a device with three logic
`
`(Ex. 1002, Fig. 11.)
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`26
`
`text interface.” (Ex. 1002, ¶ [0064]; Pet., 15, 28.)
`“The filter module 730 … may be included in the plain
`
`(Ex. 1002, Fig. 11.)
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`27
`
`(Ex. 1006, ¶ 117; Pet. 16; Reply, 6, 11-13, 21.)
`access and storage.’”
`set of commands’ that are ‘associated with data or memory
`specifically identify commands from a ‘predetermined allowed
`distinguish among different received commands and
`“Sullivan therefore discloses a component that is able to
`
`(Ex. 1006, ¶ 117; Pet. 16; Reply, 6, 11-13, 21.)
`allowed set of commands.’”
`whether a received command is part of a ‘predetermined
`unit with a ‘look-up table’ that may be used to determine
`“Sullivan discloses a ‘command pass filter’ in the encryption
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`28
`
`(Ex. 1002, ¶ [0056]; Pet., 16, 28, 29; Resp., 28, 35; Reply, 6, 11, 13, 22.)
`access and storage.”
`other commands associated with data or memory
`“Typical allowed commands will be read, write, and
`
`(Ex. 1002, ¶ [0055]; Pet., 16, 28, 29; Resp., 28, 35; Reply, 6, 11, 22.)
`other information or categories of information….”
`predetermined allowed set of commands, status and
`formula or other logic configured to pass only a
`module 730, which may include a look-up table, a
`“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., 26; Resp., 23; 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
`
`the order of FISesfor various operations.” (Ex. 2061, ¶ 42; Reply, 4.)
`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:
`
`execute a particular command.” (Ex. 1006, ¶ 92; Pet., 7, 9-10; Reply, 4.)
`transmitted between the host and the device in order to
`“The SATA Standard 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, 16.)
`SECTOR command, a PIOdata-out command.”
`correctly identifies the order of FIS transactions for a WRITE
`Dr. Conte: “For example, in the diagram [above], Dr. Long
`
`(Ex. 2061, ¶ 43; Reply 5, 16.)
`Dr. Conte:
`
`(Ex. 1006, ¶ 93; Pet. 10-11.)
`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, 16.)
`Dr. Conte:
`
`(Ex. 1006, ¶ 95; Pet. 11-12.)
`Dr. Long:
`
`’057 Patent -Claim 40
`Dr. Long and Dr. Conte: READ DMA Command
`Dr. Long and Dr. Conte: READ DMA Command
`
`
`
`34
`
`Long’s declaration.” (Ex. 2061, ¶ 44; Reply, 5, 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, 16.)
`Dr. Conte:
`
`Dr. Conte: READ SECTOR Command
`Dr. Conte: READ SECTOR Command
`
`’057 Patent -Claim 40
`
`
`
`35
`
`(Ex. 1041, 37:4-13 (objection omitted), Reply, 5.)
`Long’s examples were correct.”
`the art would have been able to determine that Dr.
`A: In light of the SATA standard, one of ordinary skill in
`
`right?
`sequence of FISesbased on the SATA standard; is that
`November of 2005 would have been aware of this
`declaration, a person of ordinary skill in the art in
`I guess, in paragraphs 43, 44, 45 and 46 of your
`“Q: So for each of these examples that we’ve described,
`
`Dr. Conte
`Dr. Conte
`
`’057 Patent -Claim 40
`
`
`
`36
`
`the subsequent Data FISes.” (Ex. 1006, ¶ 97; Reply, 4, 6.)
`Standard creates an association between a command and
`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
`
`
`
`37
`
`45, Reply, 5, 16.)
`FISesas in my diagram above for READ SECTOR.” (Ex. 2061, ¶
`regarding the device to the host with the same sequence of
`PIOdata-in command that sends control information
`“As Dr. Long notes, the IDENTIFY DEVICE command is a
`Dr. Conte:
`
`(Ex. 2061, ¶ 45; Ex. 1041, 29:6-37:13, Reply, 5, 16.)
`IDENTIFY DEVICE command:
`Dr. Conte:
`
`Dr. Long:
`
`Dr. Conte
`Dr. Conte
`
`’057 Patent -Claim 40
`
`
`
`38
`
`(Ex. 1041, 32:10-15; Reply, 5.)
`Long would call user dataand then a status type 34.”
`a packet with a header of 46 indicating or containing what Dr.
`then sending back a packet indicating device ready and then
`“This shows the host sending a packet to device, the device
`Dr. Conte:
`
`(Ex. 2061, ¶ 44; Ex. 1041, 29:6-37:13, Reply, 5, 16.)
`READ SECTOR command:
`Dr. Conte:
`
`Dr. Long:
`
`Dr. Conte
`Dr. Conte
`
`’057 Patent -Claim 40
`
`
`
`39
`
`Dr. Long:
`
`(Ex. 1006, ¶ 97; Reply 4, 16.)
`identifies the type of information in associated Data FISes.”
`(sent in a Register-Host to Device FIS or FIS Type 27h)
`included in the Data FIS. As a result, a command in SATA
`information (i.e., control information or user data) to be
`associated with each Data FIS require different types of
`transfer of Data FISes(FIS Type 46h), the commands
`“Although the execution of [different] commands involves the
`Dr. Long:
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`40
`
`(Ex. 1006, ¶ 116 ; Reply, 3-6.)
`when those Data FISescontain user data).”
`those Data FISesare associated with read or write commands (i.e.,
`implemented in SATA, encrypts and decrypts Data FISesonly when
`such a person would have understood that Sullivan, when
`control information are associated with other commands in SATA,
`with read or write commands in SATA and that Data FISescontaining
`have known that Data FISescontaining user data are associated
`“Furthermore, because a person of ordinary skill in the art would
`
`as the other FIS types that also contain control information.”
`decryption those Data FISescontaining control information as well
`FISescontaining user data and will bypass without encryption or
`when implemented in SATA, will encrypt or decrypt only those Data
`“[O]ne of ordinary skill in the art would have understood that Sullivan,
`Dr. Long:
`’057 Patent -Claim 40
`Claim 40
`Claim 40
`
`
`
`41
`
`cryptographic engine.” (Ex. 1006, ¶ 117; Reply, 6, 11-13.)
`or memory access and storage’ (i.e., user data) will pass to the
`predetermined set of commands ‘typically associated with data
`teaches a means by which only data transmitted pursuant to a
`have recognized that Sullivan, when implemented using SATA,
`“Accordingly, in my opinion, one of ordinary skill in the art would
`purposes of encryption and decryption.” (Ex. 1006, ¶ 116; Reply, 3-6.)
`Sullivan, to distinguish user data from control information for
`Standard with an encryption device, such as the one taught in
`identification schemes and relationships established by the SATA
`been familiar with and readily able to use the conventional
`“Thus, in my opinion, one of ordinary skill in the art would have
`Dr. Long:
`
`’057 Patent -Claim 40
`Claim 40
`Claim 40
`
`
`
`42
`
`encrypted.” (Resp., 25 (emphasis added); Reply, 7, 9.)
`payloads of even non-Data FISeswould be
`result in a non-functional system in which the
`“Following this approach, as Dr. Long suggests, would
`
`Patent Owner
`Patent Owner
`
`’057 Patent -Claim 40
`
`
`
`43
`
`reject this packet.” (Resp., 32 (citing Ex. 2061, ¶ 106); Reply, 11.)
`command,’ Sullivan’s filter module embodiment would
`“Since a Data FIS does not contain any ‘allowed
`
`(citing Ex. 2061, ¶ 106); Reply, 11.)
`way: the command itself would be encrypted….” (Resp., 32
`per Sullivan’s disclosure, would be treated in the same
`“A read command, also one that would be ‘allowed’
`Dr. Conte:
`
`Patent Owner
`Patent Owner
`
`’057 Patent -Claim 40
`
`
`
`parallel ATA protocol.” (Ex. 2061, ¶ 27; Reply, 14-15.)
`“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 specification itself, 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 commands described by the
`(Ex. 1003, 13; Reply, 5.)
`
`44
`
`SATA:
`
`’057 Patent -Claim 40
`SATA SATA
`
`
`
`45
`
`(4)Alleged evidence of secondary considerations
`(3)“command set” limitations in claims 44, 47, 50, 53
`(2)“pass” limitation in claim 40
`(1)“association” limitations in claims 40-42, 45, 48, 51
`Agenda
`
`IPR2014-01449 Claims 40-53
`IPR2014-01449 Claims 40-53
`
`’057 Patent -Claim 40
`
`
`
`46
`
`command FIS.
`completion of an operation or an aborted operation associated with the PIOdata-out
`received from said device interface, said Register-Device to Host FIS representing
`
`said cryptographic SATA apparatus detecting a Register-Device to Host FIS
`
`said cryptographic SATA apparatus encrypting said detected data FIS payload;
`
`and
`
`said cryptographic SATA apparatus detecting a data FIS payload received from
`
`said host interface;
`
`said cryptographic SATA apparatus passing a PIOsetup FIS received from a
`
`device interface to the host interface;
`
`requires setting in encryption mode;
`out command FIS is associated with a pre-defined category of command set that
`said cryptographic SATA apparatus determining whether the received PIOdata-
`
`data-out command FIS (Frame Information Structure) received from a host interface;
`
`a cryptographic SATA apparatus detecting a PIO(Programmed Input/Output)
`
`40. A cryptographic method, comprising the steps of:
`
`’057 Patent -Claim 40
`’057 Patent –Claim 40
`’057 Patent –Claim 40
`
`
`
`47
`
`command FIS.
`completion of an operation or an aborted operation associated with the PIOdata-out
`received from said device interface, said Register-Device to Host FIS representing
`
`said cryptographic SATA apparatus detecting a Register-Device to Host FIS
`
`said cryptographic SATA apparatus encrypting said detected data FIS payload;
`
`and
`
`said cryptographic SATA apparatus detecting a data FIS payload received from
`
`said host interface;
`
`said cryptographic SATA apparatus passing a PIOsetup FIS received from a
`
`device interface to the host interface;
`
`requires setting in encryption mode;
`out command FIS is associated with a pre-defined category of command set that
`said cryptographic SATA apparatus determining whether the received PIOdata-
`
`data-out command FIS (Frame Information Structure) received from a host interface;
`
`a cryptographic SATA apparatus detecting a PIO(Programmed Input/Output)
`
`40. A cryptographic method, comprising the steps of:
`
`’057 Patent -Claim 40
`’057 Patent –Claim 40
`’057 Patent –Claim 40
`
`
`
`48
`
`are rejected and filtered out.” (Resp., 46-47; Reply 20-21.)
`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
`
`•“Petitioners do not address whether a PIOSetup FIS would
`because:
`Patent Owner asserts that claim 40 would not be obvious
`
`present a cryptographic determination.” (Resp., 45; Reply, 19.)
`
`Patent Owner
`
`
`
`49
`
`unencrypted form.” (Ex. 1002, claim 9; Pet., 15, 26; Reply, 8, 20, 22.)
`associated control information is transmitted in an
`control information to the second device, where the
`“transmitting the encrypted data with the associated
`
`Sullivan Excerpt
`
`
`
`50
`
`(Ex. 1006, ¶ 161; Petition, 29-30.)
`the second step of a PIOdata-out operation….”
`storage device and passes that FIS to the host as part of
`according to SATA, receives the PIOSetup FIS from the
`that Sullivan’s encryption unit, when implemented
`“One of ordinary skill in the art would have understood
`
`information.” (Ex. 1006, ¶ 179 (citations omitted); Reply, 19-20.)
`appreciated that the PIOSetup FIS conveyscontrol
`encrypted, and one of ordinary skill would have
`“Sullivan also teaches that control information is not
`
`Dr. Long
`
`
`
`51
`
`(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
`
`
`
`52
`
`(4)Alleged evidence of secondary considerations
`(3)“command set” limitations in claims 44, 47, 50, 53
`(2)“pass” limitation in claim 40
`(1)“association” limitation in claims 40-42, 45, 48, 51
`Agenda
`
`IPR2014-01449 Claims 40-53
`IPR2014-01449 Claims 40-53
`
`’057 Patent -Claim 40
`
`
`
`53
`
`command, and WRITE BUFFER command.
`WRITE MULTIPLE command, WRITE MULTIPLE EXT
`SECTOR command, WRITE SECTOR EXT command,
`defined category of command set comprises WRITE
`47. The cryptographic method ofclaim 45, wherein the pre-
`
`command, and WRITE BUFFER command.
`WRITE MULTIPLE command, WRITE MULTIPLE EXT
`SECTOR command, WRITE SECTOR EXT command,
`defined category of command set comprises WRITE
`44. The cryptographic method ofclaim 42, wherein the pre-
`
`’057 Patent -Claim 40
`’057 Patent -Claims 44 and 47
`’057 Patent -Claims 44 and 47
`
`
`
`54
`
`command, and READ DMA EXT command.
`defined category of command set comprises READ DMA
`53. The cryptographic method ofclaim 51, wherein the pre-
`
`command, and READ DMA EXT command.
`defined category of command set comprises READ DMA
`50. The cryptographic method ofclaim 48, wherein the pre-
`
`’057 Patent -Claim 40
`’057 Patent -Claims 50 and 53
`’057 Patent -Claims 50 and 53
`
`
`
`55
`
`processed.” (Resp., 49; Reply, 22.)
`transport user data and should not be cryptographically
`with data or access memory and storage’ do not
`
`•“In particular, many commands which are ‘associated
`
`22.)
`disclosure of particular SATA commands” (Resp., 48-51; Reply, 21-
`this manner” and “Sullivan does not include any
`
`•“The SATA Standard itself does not group commands in
`obvious because:
`Patent Owner asserts that these claims would not be
`
`Patent Owner
`
`
`
`56
`
`(Ex. 1002, ¶ [0056]; Pet., 16, 28, 29; Resp., 28, 35; Reply, 6, 11, 13, 22.)
`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
`
`
`
`57
`
`original data.” (Ex. 1002,¶[0070]; Reply, 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]; Pet., 12, 29, 43; Reply, 3.)
`“The present invention relates to encryption of data storedby processor-
`
`Data
`
`Sullivan Excerpts
`Sullivan Excerpts
`
`’057 Patent -Claim 40
`
`
`
`58
`
`write commands.” (Ex. 1006, ¶ 193 (some citations omitted), see also¶ 210; Reply, 17.)
`encrypt the payloads of Data FISesassociated with those
`opinion, one of ordinary skill in the art would have known to
`Because Sullivan teaches encrypting user data, in my
`as recognized by the ’057 patent itself (Ex. 1001, 8:9-35).
`“These commands were copied from the SATA Standard,
`Regarding the commands in 44 and 47:
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`59
`
`omitted), see also ¶ 268; Reply, 17.)
`associated with those read commands.” (Ex. 1006, ¶ 249 (some citations
`would have known to decrypt the payloads of Data FISes
`storage device are decrypted, one of ordinary skill in the art
`Because Sullivan teaches that user data read from a
`recognized by the ’057 patent itself (Ex. 1001, 8:9-35).
`“These commands are from the SATA Standard, as
`Regarding the commands in 50 and 53:
`
`’057 Patent -Claim 40
`Dr. Long
`Dr. Long
`
`
`
`60
`
`(Ex. 1001, 8:26-30; Pet., 5, 19; Reply, 13.)
`particular command protocol will be cryptographically processed.”
`or sectors of a hard disk drive), the payloads of all data FISesin that
`from/to physical storage media(such as optical tracks of a CDRW
`“if a SATAcommand protocol relates to reading/writing-data
`
`Data
`
`’057 Patent Excerpt
`’057 Patent Excerpt
`
`’057 Patent -Claim 40
`
`
`
`61
`
`(Exhibit 1041, 80:3-11; Reply, 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
`
`
`
`62
`
`(4)Alleged evidence of secondary considerations
`(3)“command set” limitations in claims 44, 47, 50, 53
`(2)“pass” limitation in claim 40
`(1)“association” limitations in claims 40-42, 45, 48, 51
`Agenda
`
`IPR2014-01449 Claims 40-53
`IPR2014-01449 Claims 40-53
`
`’057 Patent -Claim 40
`
`
`
`Patent No. 7,900,057
`
`Case No. IPR2014-01449
`
`November 2, 2015
`
`Seagate Technology (US) Holdings, Inc.,
`
`and Seagate Technology LLC,
`
`Petitioners
`
`Enova Technology Corp.,
`
`Patent Owner
`
`v.
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