DROPBOX EX. 1009
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`DROPB OX EX. 1009
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`UN11l:D S IA] 135 PA ll:.N[ AND TRADt.MARI( O1+lCl:
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`UNITED STATES DEPARTMENT OF‘ COMMERCE
`United States Patent and '1‘ratIcn1ark Oflicc
`Acixlrus-;:(I()i\-1M|SS|()N]iR 1"()R 1’A'1'|ii\"l'S
`P.(). Iiulx I450
`Alexmldria. Virginia .‘.2?-l3- I450
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`;\|’|’l.I(I;’\'l‘I()N N0.
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`1-'|RS'|' NAMILI) Ii\W'|iN'|'()R
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`;’\'I'1‘()RN|iY ])()t"K|'i'l' N0.
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`(T()N1"|R!\«'I.¢\'l'|0N N().
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`951002.339
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`(J9!]4!2{J12
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`6._6?]f"5?
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`4036CI]US
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`2230
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`llAVl":RSTOCI(&O uwsm T
`I62 N WOLFE ROAD
`STEELMAN MAR‘-F1
`"“"““’S“’
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`3992
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`Please find below andlor attached an Office communication concerning this application or proceeding.
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`The time period for reply, if any, is set in the attached communication.
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`03!] 5:90] 3
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`PAJ-‘L-LR
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`PTOL—9'0A (Rev. 0-H0?)
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`Control No.
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`Patent Under Reexamination
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`ACTION CLOSING PROSECUTION 95r0o2,339
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`6,671,757
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`
`
`MARY STEELMAN
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`3992
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`- The MAILING DA TE of this communication appears on the cover sheet with the correspondence address. --
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`Responsive to the communication(s) filed by:
`Patent Owner on 08 February, 2013
`Third Party(ies) on
`
`Patent owner may once file a submission under 37 CFR 1.951(a) within 1 month(s) from the mailing date of this
`Office action. Where a submission is filed, third party requester may file responsive comments under 37 CFR
`1.951 (b) within 30-days (not extendable- 35 U.S.C. § 314(b)(2)) from the date of service of the initial
`submission on the requester. Appeal cannot be taken from this action. Appeal can only be taken from a
`Right of Appeal Notice under 37 CFR 1.953.
`
`All correspondence relating to this inter partes reexamination proceeding should be directed to the Central
`Reexamination Unit at the mail, FAX, or hand-carry addresses given at the end of this Office action.
`
`PART I. THE FOLLOWING A'|TACH|'llIENT(S) ARE PART OF THIS ACTION:
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`1. I:I Notice of References Cited by Examiner, PTO-892
`2. Q Information Disclosure Citation, PTOiSBi08
`3—l:|
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`PART II. SUMMARY OF ACTION:
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`
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`1a. IE Claims 1 3 1 1 24 25 and 27 are subject to reexamination.
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`1b. IE Claims 2 4-10 12-23 26 28 and 29 are not subject to reexamination.
`2.
`I:l Claims_ have been canceled.
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`IE Claims 1 3 11 24 25 and 27 are confirmed. [Unamended patent claims]
`I:l Claims? are patentable. [Amended or new claims]
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`3.
`4.
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`5. I] Claimsj are rejected.
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`6.
`7.
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`are objected to.
`I:l Claims
`|:| The drawings filed on j I:I are acceptable
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`I:| are not acceptable.
`
`8
`9
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`I:I disapproved.
`I:I approved.
`is:
`I:I The drawing correction request filed on
`I] Acknowledgment is made of the claim for priority under 35 U.S.C. 119 (a)-(d). The certified copy has:
`I:l been received.
`I:I not been received.
`I:I been filed in Applicationicontrol No
`10. I:l Otherj
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`US. Patent and Trademark Office
`PTOL-2065 (08106)
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`Paper No. 20130228
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`Application.r"Control Number: 95:"002,339
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`Art Unit: 3992
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`Page 2
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`INTER PARTES REEXAMINATION OF USPN 6,671,757 B1 to Multer et al.
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`ACTION CLOSING PROSECUTION (ACP)
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`This office action is fully responsive to Patent Owner Response received 02!'08./2013. Claims 1,
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`3, ll, 24, 25, and 27 of USPN 6,67l,T57 B1 to Multe1' et al. are pending and per Non Final
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`Office Action mailed 12/lU:"20l2 are rejected.
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`A Notice was received (02!06J'20l3) from Ronald Prague, the Executive Vice President and
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`General Counsel of the Patent Owner, Synchronoss Technologies, Inc. (“STI”). Mr. Prague
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`states:
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`3. On or about December 24, 2012, STI purchased all the assets of the Requester.
`Requester is now a wholly owned subsidiary of ST].
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`I am also the Vice President and General Counsel of the Requester, and am authorized
`4.
`to take action upon behalf of, and bind STI's wholly owned subsidiary, the Requester.
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`5. In regard to the above-captioned inter parres reexamination, I hereby revoke all prior
`powers of attorney granted by the Requester.
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`6. I hereby appoint Practi[ti]one1's associated with Customer Number 28,960 as the
`Requester's attorneys or agents to prosecute the proceedings identified above, and to
`transact all business in the United States Patent and Trademark Office connected
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`therewith.
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`7. Please change the co1'respondence information on file to the address associated with
`Customer Number 28,960. Because this is the same Customer Number also working on
`this Enter parles reexamination on behalf of the Patent Owner, we authorize the USPTO
`to send only a single copy of any correspondence, hereafter.
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`Application.r"Control Number: 95:"002,339
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`Art Unit: 3992
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`Page 3
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`E I
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`DS received 02!] l:"20l3 has been considered and entered into the record. With respect to the
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`Info1'mation Disclosure Statement (PTOISBJOSA and 08B or its equivalent) conside1'ed with this
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`action, the information cited has been considered as described in the MPEP. Note that MPEP
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`2256 and 2656 indicate that degree of consideration to be given to such information will be
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`normally limited by the degree to which the party filing the information citation has explained
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`the content and relevance of the information. A concise explanation of the relevance, as it is
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`presently understood by the individual designated in § 1.56(c) most knowledgeable about the
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`content of the information, of each patent, publication, o1' other information listed that is not in
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`the English language may be either separate from applicant's specification or incorporated
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`therein.
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`PO Arguments directed to Mendez ‘22l (regarding claims 1 and 24; claims 3,
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`1 l, 25 and 27
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`are argued fo1' being dependent on claims 1 or 24):
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`PO argues (p. 3): Mendez '22 "I does not teach "a data store coupled to the network and
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`in communication with the first and second systems" of claim 1. The Requester characterizes a
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`client's workspace data 180 as a data store and the server's workspace data 163 also as a data
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`store. See, Request at 33. Howeve1', workspace data is not the same as a data store. One skilled
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`in the art understands that data is a body of information, whe1'eas a data store is a repository for
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`storing data and is not the data itself.
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`Application.r"Contro1 Number: 95:"002,339
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`Art Unit: 3992
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`Page 4
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`PO argues (pp. 3-4): Mendez '221 does not teach "a second sync engine on the second
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`system coupled to receive the difference information in the difference transaction from the data
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`store via the network, and interfacing with data on the second system to update said data on the
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`second system with said difference information" of claim 1. The Requester states that Mendez
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`'22] teaches a system for synchronizing data between a first system and a second system, and
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`provides three scenarios: client (acting as a first system) to client (acting as a second system),
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`client (acting as a first system) to sewer (acting as a second system), and server (acting as a first
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`system) to client (acting as a second system). See, Request at 29-30. The Requester characterizes
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`a client's base system 170 as a sync engine and the server's synchronization agent 145 also as a
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`sync engine. See, Request at 31 and 35. Also, the Requester characterizes a client's workspace
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`data 180 as a data store and the server's workspace data 163 also as a data store. See, Request at
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`33. Based on such cha1'acterizations, neither of the asserted sync engines receives any data from
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`an asserted data store.
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`As discussed above, workspace data is not the same as a data store. One skilled in the art
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`understands that data is a body of information, whereas a data store is a repository for storing
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`data and is not the data itself. Even if somehow workspace data can be considered the same as a
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`data store (which we do not admit), Mendez '22] does not [typo presumed, should rccitc “does
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`not teach] that difference information in a difference transaction is retrieved from its workspace
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`data. Again, data is simply a body of information. Instead, Mendez '22] teaches that the general
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`synchronization module 410 in the server forwards translated changes to the general
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`synchronization module 825 in the client for updating outdated workspace element in the
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`workspace data 180. Mendez '22] also teaches that the general synchronization module 825
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`sends changes in the workspace data 180 to global translator 150 in the server for translation and
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`then to the general synchronization module 410 for updating the outdated workspace element in
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`the workspace data 163. The general synchronization module 410 in the serve1' is separate and
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`dzfiérerrt f1'om the workspace data 163 in the server. See, Figures 3-4 of Mendez '22]. Similarly,
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`the general synchronization module 825 in the client is Separate and different from the
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`w01'kspace data 180 in the client. See, Figures 7-8 of Mendez '22l.
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`PO argues (pp. 4-5): Mendez '221 does not teach "a storage server having an lnte1'net
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`connection" of claim 24. The Requester characterizes the server's workspace data 163 as a
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`storage server and the client's workspace data 180 also as a storage server. See, Request at 44-45.
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`As discussed above, data is a body of information. Data is not the same as a storage server.
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`Further, based on the Requester's characterizations, Mendez '221 does not teach that its
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`workspace data (i.e., storage seiver) has an Internet connection.
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`PO argues (pp. 5-6): Mendez '221 does not teach "wherein each said sync engine comprises
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`a data interface, a copy of a previous state of said data, and a difference transaction generator" of
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`claims 1 and 24. As mentioned above, the Requester characterizes a client's base system 170 as
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`a sync engine and the server's synchronization agent 145 also as a sync engine. Based on these
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`characterizations, each of asserted sync engines does not include all of the following: a data
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`interface, a copy of a previous state of said data and a difference transaction generator.
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`In
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`Application.r"Control Number: 95:"002,339
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`regards to the synchronization agent 145 in the server, which is shown in Figure 4, Mendez '22l
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`teaches that the synchronization agent 145 merely includes a communications module 405 and a
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`general synchronization module 410. The synchronization agent 145 in the server does not
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`include a copy of a previous state of said data. Mendez '22l teaches that data is stored separately
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`from the synchronization agent 145. Figure 3 explicitly shows the synchronization agent 145
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`being separate from the workspace data 163.
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`In regards to the base system 170 in the client, which is shown in Figure 8, Mendez '22]
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`teaches that the base system 170 merely includes a communications module 805, a user interface
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`module 810, locator modules 815, a synch—start module 820, a general synchronization module
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`825 and a content-based synchronization module 830. The base system 170 in the client does not
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`include a copy of a previous state of said data. Mendez '22] teaches that data is stored Separafefy
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`f1'om the base system 170. Figure 7 explicitly shows the base system 170 being separate from the
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`workspace data 180.
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`Examiner disagrees with P0 and asserts that a global server stores a set of workspace data.
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`(‘22l, 3: 8-29), “Each client includes a base system (a first system / a second system) and the
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`global server (alternately referred to as a second system in Request) includes a synchronization
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`agent. The base system and synchronization agent automatically establish a secure connection
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`the1'ebetween and synchronize the selected portions of the first set of workspace data sto1'ed on
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`the client and the second set of workspace stored on the global sewer. The base system operates
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`on the client and examines the selected portions (a data sto1'e) to determine whether any
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`Application.r"Control Number: 95:"002,339
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`workspace elements have been modified (synchronization functionality on a first system). . .Thc
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`synchronization agent operates on the global server (synchronization functionality on a second
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`system) and informs the base system Whether any of the workspace elements in the second set (a
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`data store) have been modified.”
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`Regarding claims I and 24, Examiner agrees that Mendez ‘22l at FIG. 3 (details of FIG. 1
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`Global Server, acting as a second system) shows data (copy of a previous state) stored separately
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`f1'om the synchronization agent 145. FIG. 2 (details of Client, acting as a first system) does not
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`show a “sync engine” wherein each said sync engine comprises a data interface, a copy of a
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`previous state of said data, and a difference transaction generator. Examiner finds that Mendez
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`‘22l is silent regarding "wherein each said sync engine (a first sync engine on the first system I a
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`second sync engine on the second system) comp1'ises a data interface, a copy of a previous state
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`of said data, and a difference transaction generator.
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`Examiner disagrees with P0 regarding the Internet feature. See Mendez ‘22l at 2: 44-47
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`(global server with Internet connection). Examiner is persuaded that Mendez ‘22l fails to
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`explicitly teach the limitations of independent claims 1 and 24.
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`Arguments directed to Dickinson (regarding claims 1 and 1 1):
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`PO argues (pp. 7-3): Dickinson does not teach "a first sync engine on the first system
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`interfacing with data on the first system to provide difference info1'mation in a difference
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`transaction" of claim 1. Dickinson teaches synchronization and updating from a server computer
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`to a client computer. See, Abstract of Dickinson. The Requester characterizes Dickinson's server
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`computer as the first system and Dickinson's delta engine in the server computer as a first sync
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`engine. See, Request at 56. Dickinson's delta engine compa1'es two sets of segments to determine
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`which segments have been altered, and extracts new or changed segments and bundles these into
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`a file, called an update file. See, Dickinson at col. 9, lines 27-31 and 51-56. The update file is
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`illustrated in Figure l 1. See, Dickinson at col. 12, lines 8-46. Dickinson teaches that the actual
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`contents of new and modified segments, among other things, are transmitted. Dickinson fails to
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`teach difference information. It therefore follows that Dickinson fails to teach providing
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`difference information in a difference transaction.
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`PO argues (pp. 8-9): Dickinson does not teach "a second sync engine on the second system
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`coupled to receive the difference information in the difference transaction from the data store via
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`the network, and interfacing with data on the second system to update said data on the second
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`system with said difference information" of claim 1. First, as discussed above, Dickinson fails
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`to teach difference information in a difference transaction. Second, Dickinson fails to teach that a
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`second sync engine on the second system receives the difference informctfion from the data .S'f0!‘€.
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`The Requester characterizes Dickinson's network drive 202 as the data store and Dickinson's
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`client computer as the second system. Dickinson teaches and the Requester even acknowledges
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`Application.r"Control Number: 95:"002,339
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`that the "[c]lient computer 210 (the second system) receives infonnation related to any changes
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`in network drive 202's (the data sto1'e) files via an update file 801 from server computer 203 (the
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`firs‘! S)-‘slem). " See, Request at 56 and 57, emphasis included. However, claim I recites that
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`difference information in the difference transaction is rereivedfmm the data store.
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`In addition, Dickinson fails to teach interfacing with data on the second system to update
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`said data on the second system with said difference information. Instead, Dickinson teaches that
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`its update file is used to create a current copy on the client Compaterfrom a copy of the earlier
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`version on the client computer. Dickinson's client computer does not update the earlier file but
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`instead builds another file to be the current version. Figure 9 of Dickinson illustrates the Creation
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`of a current eap_v on the client computer. Further, the Requester even acknowledges that, in
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`Dickinson, "a server computer generates an update file for transmission to a client computer that
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`permits the client computer to generate a ('0p_v of a current versam of a .s'ab.s'(‘ripn'(m file from a
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`copy of an earlier Version of the subscription file" and "the new or
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`changed segments B2, B4 and B5 are extracted f1'om the current version of the subscription file
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`stored on the network drive 202 by the sewer computer 203, and are packaged in an update file
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`801 for transmission to the client computer 201 shown in FIG. 2 so that the client computer 201
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`can build a Copy ofthe (‘urrem version ofthe mbscription file from its copy of the earlier version
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`of the subscription file." See, Request at 58, emphasis included.
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`PO argues (pp. 9-10): Dickinson does not teach "wherein each said sync engine comprises a
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`data interface, a copy of a previous state of said data, and a difference transaction generator" of
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`claim 1. The Requester characterizes Dickinson's server computer as the first system and
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`Dickinson's delta engine in the server computer as a first sync engine, and characterizes
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`Dickinson's client computer as the second system, stating that the client computer "necessarily
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`contains circuitry andfor software to act as a second sync engine on client computer." See
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`Request at 56 and 57. Based on these characterizations, each of the asserted sync engines does
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`not include all of the following: a data interface, a copy of a previous state of said data and a
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`difference transaction generator.
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`First, as discussed above, Dickinson fails to teach difference information. It therefore
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`follows that Dickinson fails to teach a difference transaction generator.
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`Further, in regards to the delta engine in the server, Dickinson does not teach that the
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`delta engine includes a copy of a previous state of data. Dickinson's delta engine compares two
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`sets of segments of a subscription file to dete1'mine which segments have been altered, and
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`extracts new or changed segments and bundles these into a file, called an update file. See
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`Dickinson at col. 9, lines 27-31 and 51-56. Dickinson does not teach that the delta engine
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`includes a copy of one or both sets of segments.
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`Examiner disagrees with P0 that Dickinson’s delta engine does not include a copy of a previous
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`state of data. Such a copy would be necessary for the comparison of segments to determine
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`which segments have been altered. Examiner agrees that Dickinson is silent regarding "a fi1'st
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`sync engine on the first system interfacing with data on the first system to provide difference
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`Application.r"Control Number: 95:"002,339
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`information in a difference transaction;
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`and a second sync engine on the second system
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`coupled to receive the difference information in the difference transaction f1'om the data store via
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`the network, and interfacing with data on the second system to update said data on the second
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`system with said difference information; wherein each said sync engine comprises a data
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`interface, a copy of a previous state of said data, and a difference transaction generator." It
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`appears that the Dickinson reference shows the client computer 210 (the second system) receives
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`information related to any changes in network drive 202's (the data store) files via an update file
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`801 from server computer 203 (the first system) and not from the “data store” as claimed. See
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`Request at 56 and 57. Dickinson is silent regarding the contents of each sync engine (a data
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`interface, a copy of a previous state of said data, and a difference transaction generator) Whereas
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`the second system is shown to generate a copy of a current version, it is not shown to necessarily
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`contain circuitry andfor software to act as a second sync engine.
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`Arguments directed to the combination of Dickinson and Mendez ‘Z21 (regarding claims 3,
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`24, 25 and 27; claims 25 and 27 are dependent on claim 24; claim 3 ("first system and second
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`system a1'e coupled to the server via an Internet connection) is dependent on claim 1)
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`PO argues (p. 11): Dickinson, Mendez '221 and their combination do not teach "wherein each
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`said sync engine comprises a data interface, a copy of a previous state of said data, and a
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`difference transaction generator" of claim 24 (claims 25 and 27 are dependent on claim 24).
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`However, as discussed above, Dickinson does not teach that each of the asserted sync engines
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`includes a difference transaction generator. PO argues (p. 12): Dickinson, Mendez '221 and
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`their combination do not teach "wherein data transfer between the first device, the second device
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`and the storage server compri ses difference transactions" of claim 2?‘.
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`Examiner agrees that Dickinson fails to show that each of the asserted sync engines includes a
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`difference transaction generator. The server computer 203 (first device) includes a Delta engine
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`that detects and provides changes or modifications in a data file. The changed segments are
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`packaged fo1' transmission to the client computer 201. Dickinson is silent regarding a difference
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`transaction generator on a second sync engine in a second system. Dickinson teaches a second
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`client computer 201 builds a copy of the current version. The build functionality does not read
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`on a "difference transaction generator.”
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`Examiner notes that PO fails to address the rejection of claim 3 (“wherein the first system and
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`second system are coupled to the server via an Internet connection"). However, neither
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`Dickinson nor Mendez ‘221 is found to teach the limitations of claim 1, from which claim 3
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`depends.
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`Arguments directed to Mendez ‘S90 (regarding claims 1, 3, l I, 24, 25 and 27)
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`PO argues (p. 13): Mendez '590 does not teach "a data store coupled to the network and
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`in communication with the first and second systems" of claim 1. The Requester characterizes a
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`client's workspace data 136 or 1 16 as a data store and the server's workspace data 120 also as a
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`data store. See, Request at 82-33. However, workspace data is not the same as a data store. One
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`skilled in the art understands that data is a body of information, whereas a data sto1'e is a
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`repositoiy for storing data and is not the data itself. P0 argues (pp. 13-15): Mendez '590 does
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`not teach "a second sync engine on the second system coupled to receive the difference
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`information in the difference transaction from the data store via the network, and interfacing with
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`data on the second system to update said data on the second system with said difference
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`information" of claim I.
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`The Requester characterizes a client's base system 1 18 or 146 as a sync engine and the
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`server's synchronization agent 124 also as a sync engine. See, Request at 79-81. Also, the
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`Requester characterizes a client's workspace data I36 or I 16 as a data store and the server's
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`workspace data 120 also as a data sto1'e. See, Request at 82-83. ("Since "the same system [is] fo1'
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`use specifically with e—mail data in Fig. 8," the following Mendez '590 remarks pertain to
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`components discussed with respect to Figures 1-7, while remarks pertaining to Figure 8 are
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`omitted for sake of brevity and clarity.) Based on such characterizations, neither of the asserted
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`sync engines receives any data from an amerred data store.
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`Even if somehow workspace data can be considered the same as a data store (which we do not
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`admit), Mendez '590 does not teach that difference information in a difference transaction is
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`retrieved f1'om its workspace data. . .Instead, Mendez ‘S90 teaches that the general
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`synchronization module 515 in the server forwards translated changes to the general
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`synchronization module 425 in the client for updating outdated workspace element in the
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`Application.r"Control Number: 95:"002,339
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`Workspace data 136 or 1 16. Mendez '22 "I [Request, p. 14, last paragraph, typo presumed intent to
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`recite Mendez ‘590] also teaches that the general synchronization module 425 sends changes in
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`the workspace data 136 or 1 16 to the global translator 122 in the server for translation and then
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`to the general synchronization module SIS for updating the outdated workspace element in the
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`workspace data 120. The general synchronization module 515 in the server is separate and
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`different f1'om the workspace data 120 in the server. See, Figures 2 and S of Mendez ‘S90.
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`Similarly, the general synchronization module 425 in the client is separate and different from the
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`workspace data 136 01' 116 in the client. See, Figures 1 and 4 of Mendez ‘590.
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`PO argues (p. 15): Mendez ‘S90 does not teach "a storage server having an [ntemet connection"
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`of claim 24. The Requester characterizes the server's workspace data 120 as a storage server and
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`the client's workspace data 136 or 116 also as a storage server. See, Request at 100-101. As
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`discussed above, data is a body of information. Data is not the same as a storage server. Further,
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`based on the Requester‘s characterizations, Mendez ‘S90 does not teach that its workspace data
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`(i.e., storage server) has an Intemet connection.
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`PO argues (pp. 15-16): Mendez ‘S90 does not teach “wherein each said sync engine comprises
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`a data interface, a copy of a previous state of said data, and a difference transaction generator" of
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`claims 1 and 24. As mentioned above, the Requester characterizes a client's base system 118 or
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`I46 as a sync engine and the server's synchronization agent 124 also as a sync engine. Based on
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`Application.r"Control Number: 95:"002,339
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`Art Unit: 3992
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`these Requester characterizations, each of the asserted sync engines does not include all of the
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`following: a data interface, a copy of a previous state of said data and a difference transaction
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`generator.
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`In regards to the synchronization agent 124 in the server, which is shown in Figure 5,
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`Mendez '590 teaches that the synchronization agent 124 merely includes a communications
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`module 505 and a general synchronization module 515. The synchronization agent 124 in the
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`server does not include a copy of a previous state of said data. Mendez ‘S90 teaches that data is
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`Stored Separctteb‘ from the synchronization agent I24. Figure l explicitly shows the
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`synchronization agent 124 being separate from the workspace data 120.
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`In regards to the base system 1 I8 or 146 in the client, which is shown as base system 400
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`in Figure 4, Mendez ‘S90 teaches that the base system 400 merely includes a communications
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`module 405, a user interface module 410, locator modules 415, a synch—start module 420, a
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`general synchronization module 425 and a content-based synchronization module 430. The base
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`system 400 ( l 18 or 146) in the client does not include a copy of a previous state of said data.
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`Mendez '590 teaches that data is stored .vepamtel'_v from the base system 146. Figure 3 explicitly
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`shows the base system 146 being separate from the workspace data 144.
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`Examiner notes that the Request has proposed three scenarios of a first I second system, first!
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`second sync engine (client to client, client to server, or server to client). Examiner cites to the
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`Request at p. 76. Remote terminal 102 is identified as a first I second system (o1' alternately
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`client 89? and LAN 1 10 as first / second systems), and global server 830 as a storage server (data
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`store) 01' alternately a remote terminal 102 as a first system and global server 830 as a second
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`system (o1' vice versa). The Request cites to the base system (146 or 1 18) of the first system as
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`reading on a first sync engine, which includes a general sync module 425 and a content-based
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`sync module 430. Alternately FIG. 8 shows global server 830, sync agent 885 (first system) and
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`a second system (LAN 810 and I or client 89?‘).
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`While it may be broadly found that workspace data must be sourced from some type of data
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`store, and be temporarily sto1'ed in a workspace, workspace data 136, per se, is data and fails to
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`clearly read on a "data store." Examiner agrees that Mendez ‘S90 fails to disclose a second sync
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`engine that receives difference information in the difference transaction from the data store via
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`the network. Examiner agrees that the alleged data store is not disclosed as coupled to the
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`network ("or Internet as claimed in claim 24). Examiner agrees that Mendez ‘590 is not shown
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`to teach wherein each said sync engine comprises a data interface, a copy ofa previous state of
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`said data, and a difference transaction gene1'ato1"' of claims 1 and 24. See FIGS. 1, 3, and 4. At
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`best similar elements are suggested to be found separately within a Global Server 106 or Base
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`System 400. FIG. 5 illustrates a “synchronization agent”, but fails to expressly disclose a sync
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`engine comprising a data interface, a copy of a previous state of said data, and a difference
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`transaction generator. Examiner is persuaded by P0 arguments.
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`Arguments directed to Bauer (regarding claims 1 and l 1)
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`PO argues (pp.
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`l7—l8): Bauer does not teach "a second sync engine on the second system
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`coupled to receive the difference infonnation in the difference transaction f1'om the data store via
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`the network, and interfacing with data on the second system to update said data on the second
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`system with said difference information" of claim 1.
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`The Requester characterizes a client's database synchronizer 27x as a sync engine and the
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`server's database synchronizer 17 also as a sync engine. Also, the Requester characterizes the
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`client's local database 22x as a data store and the server's central database 12 also as a data store.
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`See, Request at 118-119. Based on such characterizations, neither of the asserted sync engines
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`receives any datafmm an asserted data store.
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`Bauer teaches that a database synchronize1', which performs database synchronization
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`between the client database and the server database in a three—step process. Bauer teaches the
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`database s ynch1'onizer is divided between the server and the client. First, the client determines
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`what modifications to the client data have taken place since the last time of synchronization. The
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`modifications detected are the creation of a new data item, an update to the value of an existing
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`data item, and the deletion of a data item. Under one approach, the client detects modifications
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`by comparing the client data with a before-image of the client data. The before-image is
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`effectively a copy of the client data as of the last time it was synchronized. Second, the
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`modifications are propagated to the server, which has determined what changes have taken place
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`to the sewer data since the last time of synchronization. Finally, the sewer detects data conflicts,
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`resolves them, and propagates modifications back to the client as refresh data. See, Bauer, col. 2,
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`lines 7-45. Nowhere within Bauer does Bauer teach that difference information in a difference
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`transaction is retrieved from either the client's local database 22x or the server's central database
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`12. Instead, Bauer teaches that client catalog structure and before—image logs associated with the
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`local database 22);, server catalog structure, server update log and last confrmed refresh table
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`associated with the central database 12 are used by the database synchronizer to propagate
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`modifications between the server and the client.
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`Examiner is persuaded by P0 arguments that Bauer fails to teach “a second sync engine on the
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`second system coupled to receive the difference information in the difference transaction from
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`the data store via the network...” as claimed in claim 1.
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`It fol