U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`
`
`Springpath, Inc.
`Petitioner
`
`v.
`
`SimpliVity Corporation,
`Patent Owner
`
`Case IPR2016-01779
`
`
`
`
`
`DECLARATION OF DARRELL D. E. LONG, PH.D. REGARDING
`U.S. PATENT NO. 8,478,799
`CLAIMS 1–2, 7–13, 17–20, 27, and 33–35
`
`
`
`SPRINGPATH
`EXHIBIT 1002
`
`
`
`
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`TABLE OF CONTENTS
`
`
`
`I.(cid:1) RELEVANT LAW ........................................................................................... 4(cid:1)
`A.(cid:1) Claim Construction ....................................................................................... 4(cid:1)
`B.(cid:1) Anticipation ................................................................................................... 4(cid:1)
`C.(cid:1) Obviousness .................................................................................................. 5(cid:1)
`II.(cid:1) Summary of Opinions ....................................................................................... 7(cid:1)
`III.(cid:1)
`Introduction to the ’799 patent ...................................................................... 7(cid:1)
`IV.(cid:1)
`Brief Description of Technology .................................................................. 9(cid:1)
`A.(cid:1) Overview of Computer File Systems ............................................................ 9(cid:1)
`1.(cid:1) Basic Components of File Systems ........................................................... 9(cid:1)
`2.(cid:1) Files ........................................................................................................... 9(cid:1)
`3.(cid:1) Directories ............................................................................................... 10(cid:1)
`4.(cid:1)
`Inodes ...................................................................................................... 10(cid:1)
`5.(cid:1) Content-Addressable File System ........................................................... 11(cid:1)
`B.(cid:1) Overview of the ’799 Patent ....................................................................... 11(cid:1)
`1.(cid:1) Alleged Problem ...................................................................................... 12(cid:1)
`2.(cid:1) Summary of Alleged Invention of the ’799 Patent ................................. 12(cid:1)
`3.(cid:1) The Challenged Claims ........................................................................... 18(cid:1)
`4.(cid:1) Prosecution History ................................................................................. 19(cid:1)
`V.(cid:1) Overview of the Primary Prior Art Reference ................................................ 23(cid:1)
`A.(cid:1) Overview of Li ............................................................................................ 23(cid:1)
`VI.(cid:1)
`Claim Construction ..................................................................................... 25(cid:1)
`A.(cid:1) “fingerprint” ................................................................................................ 25(cid:1)
`B.(cid:1)
`“namespace file system” ............................................................................. 26(cid:1)
`VII.(cid:1) Level of Ordinary Skill In The Art ............................................................. 27(cid:1)
`VIII.(cid:1) Specific Grounds for Petition ...................................................................... 27(cid:1)
`A.(cid:1) Ground I: Claims 1-2, 7-9, 11-12, 17-20, 27, and 33-35 are anticipated by
`Li 27(cid:1)
`
`i
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`Independent Claim 1 ............................................................................... 27(cid:1)
`1.(cid:1)
`2.(cid:1) Claim 2: “The file system of claim 1, wherein: object references are
`mapped by the object fingerprints.” ................................................................ 39(cid:1)
`3.(cid:1) Claim 7: “The file system of claim 1, wherein: the file object mapping
`comprises a linear list, a tree structure or an indirection table.” ..................... 39(cid:1)
`4.(cid:1) Claim 8: “The file system of claim 1, wherein: the file objects include a
`root object having its own object fingerprint derived from all of the objects in
`the file system such that every object in the file system is accessible through
`the root object.” ............................................................................................... 40(cid:1)
`5.(cid:1) Claim 9: The file system of claim 8, wherein a change of content of any
`file system object changes the root object and tracking changes in the root
`object provides a history of file system activity. ............................................ 41(cid:1)
`6.(cid:1) Claim 11: “The file system of claim 1, wherein: the fingerprint is an
`cryptographic hash digest of the object content.” ........................................... 41(cid:1)
`7.(cid:1) Claim 12: “The file system of claim 1, wherein: the object size is
`variable. ........................................................................................................... 42(cid:1)
`8.(cid:1) Claim 17: The file system of claim 1, including: a stack wherein the
`object store comprises a lower portion of the stack and the file system
`comprises an upper portion of the stack. ........................................................ 42(cid:1)
`9.(cid:1) Claim 18: The file system of claim 1, wherein: the namespace file system
`and the object store are implemented in one or more of digital electronic
`circuitry, computer hardware, firmware, a computer program in a non-
`transitory machine readable storage device, or combinations thereof. ........... 43(cid:1)
`10.(cid:1)
`Independent Claim 19 .......................................................................... 44(cid:1)
`11.(cid:1) Claim 20: The method of claim 19, comprising: maintaining a location
`index for mapping object fingerprints and physical locations of the objects. 45(cid:1)
`12.(cid:1) Claim 27: A computer program embodied in a non-transitory machine
`readable storage device comprising program code means which, when
`executed by a process, performs the steps of method claim 19. ..................... 45(cid:1)
`13.(cid:1) Claim 33: The method of claim 19, including: maintaining in the object
`store a location index of object names and physical object locations. ............ 46(cid:1)
`14.(cid:1) Claim 34: The method of claim 19, wherein: the file object mapping is
`indexed by an offset into the content of the file, and comprises a linear list, a
`tree structure, or an indirection table. ............................................................. 47(cid:1)
`
`ii
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`15.(cid:1) Claim 35: The method of claim 19, including: adding, modifying or
`deleting an object of the file and generating a new file object fingerprint. .... 47(cid:1)
`B.(cid:1) Ground II: Claim 10 is obvious over Li in view of Sandberg ................... 48(cid:1)
`1.(cid:1) Claim 10: The file system of claim 1, wherein: the namespace file system
`is provided as a layer in a storage stack between a virtual file system layer and
`a block storage abstraction layer. .................................................................... 49(cid:1)
`2.(cid:1) Motivation to Combine ........................................................................... 50(cid:1)
`C.(cid:1) Ground III: Claim 13 is obvious over Li ................................................... 52(cid:1)
`1.(cid:1) Claim 13: The system of claim 1, wherein: the file system is a POSIX
`standard compliant file system. ....................................................................... 53(cid:1)
`Availability for Cross-Examination ............................................................ 53(cid:1)
`IX.(cid:1)
`X.(cid:1) Right to Supplement ....................................................................................... 54(cid:1)
`XI.(cid:1)
`Jurat ............................................................................................................. 55(cid:1)
`
`
`
`
`iii
`
`

`
`I, Darrell D. E. Long, declare as follows:
`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`1.(cid:1) My name is Darrell D. E. Long.
`
`2.(cid:1)
`
`I am a Professor of Computer Science at University of California,
`
`Santa Cruz. I hold the Kumar Malavalli Endowed Chair of Storage Systems
`
`Research and I am the Director of the Storage Systems Research Center.
`
`3.(cid:1)
`
`I received my B.S. degree in Computer Science from San Diego State
`
`University in 1984, and my M.S. and Ph.D. degrees from the University of
`
`California, San Diego, in 1986 and 1988, respectively.
`
`4.(cid:1)
`
`I am a Fellow of the Institute of Electrical and Electronics Engineers
`
`and the American Association for the Advancement of Science. I am a member of
`
`the IEEE Computer Society for Engineering Education, the Usenix Association
`
`and the Association for Computing Machinery.
`
`5.(cid:1)
`
`I have broad research interests in the area of computer science
`
`including data storage systems, operating systems, distributed computing,
`
`reliability and fault tolerance, and computer security. My research has been
`
`supported by the National Science Foundation, the Department of Energy,
`
`Lawrence Livermore, Los Alamos and Sandia National Laboratories, the Office of
`
`Naval Research, and a number of industrial sponsors that include IBM, Microsoft,
`
`NetApp, Symantec, LSI Logic, Hewlett-Packard and Data Domain.
`
`1
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`I have served as the Vice Chair and Chair of the University of
`
`6.(cid:1)
`
`California Committee on Research Policy. I have served as the Associate Dean for
`
`Research and Graduate Studies in the Jack Baskin School of Engineering. I served
`
`on the University of California President's Council on the National Laboratories,
`
`on the Science and Technology, National Security and Intelligence committees,
`
`and on the Science and Technology Committee. I served on the National Research
`
`Council Standing Committee on Technology Insight-Gauge, Evaluate and Review.
`
`I was a member of the United States Army Laboratory Assessment Group. I have
`
`served on numerous committees and advisory panels for various government
`
`agencies.
`
`7.(cid:1) My qualifications to render an expert opinion in the matter are set
`
`forth in my Curriculum Vitae, which is attached as Appendix A. My C.V. also
`
`contains a list of publications authored in at least the last 10 years.
`
`8.(cid:1)
`
`I have reviewed the specification, claims and file history of U.S.
`
`Patent No. 8,478,799. I understand that the ’799 patent was filed on June 25, 2010,
`
`and claims priority, as a continuation-in-part application, to U.S. Application No.
`
`12/823,452, filed on June 25, 2010, which claims priority to U.S. Provisional
`
`Application No. 61/269,633, filed on June 26, 2009. I understand that, for
`
`purposes of determining whether a publication will qualify as prior art, the earliest
`
`date that the ’799 patent could be entitled to is June 26, 2009.
`
`2
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`I have reviewed the following patents in preparing this declaration:
`
`9.(cid:1)
`
`•(cid:1) Secure Untrusted Data Repository (SUNDR), to Li et al. (“Li” (Ex.
`
`1003)), published in 2004. I have been informed that Li is prior art
`
`under 35 U.S.C. §102(b).
`
`•(cid:1) Design and implementation of the Sun network filesystem, to Sandberg
`
`et al. (“Sandberg” (Ex. 1004)), published in 1995. I have been
`
`informed that Sandberg is prior art under 35 U.S.C. §102(b).
`
`10.(cid:1)
`
`I have reviewed the above publications and any other publication and
`
`exhibit cited in this Declaration.
`
`11.(cid:1)
`
`I have considered certain issues from the perspective of a person of
`
`ordinary skill in the art as described below at the time the ’799 patent application
`
`was filed. In my opinion, a person of ordinary skill in the art for the ’799 patent
`
`would have found the ’799 patent invalid.
`
`12.(cid:1)
`
`I have been retained by the Petitioner as an expert in the field of data
`
`storage systems and operating systems. I am working as an independent consultant
`
`in this matter and am being compensated at my normal consulting rate of $650 per
`
`hour for my time. My compensation is not dependent on and in no way affects the
`
`substance of my statements in this Declaration.
`
`3
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`I have no financial interest in the Petitioner. I similarly have no
`
`13.(cid:1)
`
`financial interest in the ’799 patent, and have had no contact with the named
`
`inventor of the ’799 patent.
`
`I.(cid:1) RELEVANT LAW
`14.(cid:1)
`I am not an attorney. For the purposes of this declaration, I have been
`
`informed about certain aspects of the law that are relevant to my opinions. My
`
`understanding of the law is as follows:
`
`A.(cid:1)Claim Construction
`15.(cid:1)
`I have been informed that claim construction is a matter of law and
`
`that the final claim construction will ultimately be determined by the Board. For
`
`the purposes of my analysis in this proceeding and with respect to the prior art, I
`
`have applied what is known as the “broadest reasonable interpretation” standard.
`
`16.(cid:1)
`
`I have been informed and understand that a claim in inter partes
`
`review is given the “broadest reasonable construction in light of the specification.”
`
`37 C.F.R. § 42.100(b). I have also been informed and understand that any claim
`
`term that lacks a definition in the specification is therefore also given a broad
`
`interpretation.
`
`B.(cid:1)Anticipation
`17.(cid:1)
`I have been informed and understand that a patent claim may be
`
`“anticipated” if each element of that claim is present either explicitly, implicitly, or
`
`4
`
`

`
`inherently in a single prior art reference. I have also been informed that, to be an
`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`inherent disclosure, the prior art reference must necessarily disclose the limitation,
`
`and the fact that the reference might possibly practice or contain a claimed
`
`limitation is insufficient to establish that the reference inherently teaches the
`
`limitation.
`
`C.(cid:1)Obviousness
`18.(cid:1)
`I have been informed and understand that a patent claim can be
`
`considered to have been obvious to a person of ordinary skill in the art at the time
`
`the application was filed. This means that, even if all of the requirements of a
`
`claim are not found in a single prior art reference, the claim is not patentable if the
`
`differences between the subject matter in the prior art and the subject matter in the
`
`claim would have been obvious to a person of ordinary skill in the art at the time
`
`the application was filed.
`
`19.(cid:1)
`
`I have been informed and understand that a determination of whether
`
`a claim would have been obvious should be based upon several factors, including,
`
`among others:
`
`•(cid:1) the level of ordinary skill in the art at the time the application was filed;
`
`•(cid:1) the scope and content of the prior art; and
`
`•(cid:1) what differences, if any, existed between the claimed invention and the prior
`
`art.
`
`5
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`I have been informed and understand that the teachings of two or
`
`20.(cid:1)
`
`more references may be combined in the same way as disclosed in the claims, if
`
`such a combination would have been obvious to one having ordinary skill in the
`
`art. In determining whether a combination based on either a single reference or
`
`multiple references would have been obvious, it is appropriate to consider, among
`
`other factors:
`
`•(cid:1) whether the teachings of the prior art references disclose known concepts
`
`combined in familiar ways, which, when combined, would yield predictable
`
`results;
`
`•(cid:1) whether a person of ordinary skill in the art could implement a predictable
`
`variation, and would see the benefit of doing so;
`
`•(cid:1) whether the claimed elements represent one of a limited number of known
`
`design choices, and would have a reasonable expectation of success by those
`
`skilled in the art;
`
`•(cid:1) whether a person of ordinary skill would have recognized a reason to
`
`combine known elements in the manner described in the claim;
`
`•(cid:1) whether there is some teaching or suggestion in the prior art to make the
`
`modification or combination of elements claimed in the patent; and
`
`•(cid:1) whether the innovation applies a known technique that had been used to
`
`improve a similar device or method in a similar way.
`
`6
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`I understand that one of ordinary skill in the art has ordinary
`
`21.(cid:1)
`
`creativity, and is not an automaton.
`
`22.(cid:1)
`
`I understand that in considering obviousness, it is important not to
`
`determine obviousness using the benefit of hindsight derived from the patent being
`
`considered.
`
`II.(cid:1)SUMMARY OF OPINIONS
`23.(cid:1)
`It is my opinion that every limitation of the file systems and methods
`
`described in claims 1–2, 7–13, 17–20, 27, and 33–35 of the ’799 patent are
`
`disclosed by the prior art, and are anticipated and/or rendered obvious by the prior
`
`art.
`
`III.(cid:1)
`
`INTRODUCTION TO THE ’799 PATENT
`24.(cid:1) The ’799 patent claims a purportedly novel computer file system for
`
`naming and storing of files on computer storage devices. But in fact, the claimed
`
`file system merely combines well known techniques disclosed by Jinyuan Li and
`
`others nearly four years before the alleged invention.
`
`25.(cid:1) The ’799 patent is directed to a stacked file system, comprising two
`
`distinct storage systems: a namespace file system and an underlying object store
`
`(also referred to in the ‘799 patent as an “object file system”). The object store is
`
`used to host the data in the form of objects. The name of the object is derived from
`
`the object’s content using, for example, a strong cryptographic hash, and represents
`
`7
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`a “fingerprint” of the content. These fingerprints of the objects are globally unique
`
`because: (i) no two objects can have the same content (because in that case, they
`
`would by definition have the same fingerprint and therefore be the same object);
`
`and (ii) two objects with different content will always have different fingerprints.
`
`Object stores have an “index” that tracks all of the objects and associates each
`
`object’s name with its location.
`
`26.(cid:1) The ’799 patent describes a “namespace file system” at the top of the
`
`storage stack, which manages the files and directories that are stored within the
`
`object store. This namespace file system uses object fingerprints, instead of logical
`
`block numbers, to access content stored in the object store. All internal data
`
`structures of the ’799 namespace file system are themselves objects.
`
`27.(cid:1) Long before the ’799 patent’s June 26, 2009 priority date, others had
`
`already developed and used the same file system architecture. Secure Untrusted
`
`Data Repository (SUNDR), to Li et al. (“Li”) (Ex. 1003), for instance, which was
`
`published on 2004, describes a storage system that is constructed as a file system
`
`that is layered over an underlying content addressable block store. Specifically, as
`
`shown in Li’s drawings and corresponding description, Li discloses data structures
`
`that are identical to the ones claimed in the ’799 patent in the form of files,
`
`directories, inodes, and i-tables.
`
`8
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`IV.(cid:1) BRIEF DESCRIPTION OF TECHNOLOGY
`28.(cid:1) The ’799 patent generally relates to the field of computer file system
`
`data structures and claims particular computer file systems for naming and storing
`
`of files on one or more computer storage devices, as well as related methods for
`
`naming and storing of files.
`
`A.(cid:1)Overview of Computer File Systems
`1.(cid:1) Basic Components of File Systems
`29.(cid:1) File systems include several data structures. For example, file
`
`systems have user visible structures, such as files and directories, as well as
`
`internal structures, such as superblocks, inodes, allocation maps, and transaction
`
`logs.
`
`2.(cid:1) Files
`30.(cid:1) A file is a named collection of related data that appears to the user as a
`
`single, contiguous set of information that is retained in storage. To a user, a file is
`
`seen as a unit of logical storage where each file is identified by a name that is
`
`unique within the directory in which the file is located. To the computer, however,
`
`individual files are identified by numbers, rather than by their names and
`
`directories. Typically, individual files are not stored as contiguous blocks of data,
`
`but rather they are stored as multiple fragments scattered in various locations in
`
`storage.
`
`9
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`3.(cid:1) Directories
`31.(cid:1) Directories are data structures that include references to files and/or
`
`other directories. Directories can be considered a particular type of a file.
`
`4.(cid:1)
`Inodes
`32.(cid:1) An inode is a data structure that is used to represent a file. In the
`
`UNIX operating system, for example, the data structure has a number of fields,
`
`including a reference count, permissions (user, group, other), additional bits, all of
`
`which comprise metadata about the file, and a number of pointers that reference
`
`the actual data blocks that compose the file. Typically there are a number of
`
`pointers that point directly to data blocks. A pointer can also point to a block of
`
`pointers known as a “single indirect block,” wherein each pointer in the single
`
`indirect block points to other data blocks. A pointer can also point to a block of
`
`pointers, known as a “double indirect block,” wherein each pointer in the double
`
`indirect block points to a single indirect block, which in turn has pointers to
`
`specific data blocks. Each additional layer of indirection increases the size of the
`
`file that can be represented by the inode. Over time, the term “inode” has come to
`
`mean any root data structure that provides basic access information to metadata
`
`and data blocks that represent a file.
`
`10
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`5.(cid:1) Content-Addressable File System
`33.(cid:1)
`
`In a content-addressable file system, each file is internally represented
`
`by a name (i.e., fingerprint), rather than by a pointer representing its location.
`
`Each file is assigned an integer number derived by a hash function, e.g., a
`
`cryptographic hash function, of the file’s contents. A cryptographic hash function
`
`maps data of arbitrary size (e.g., contents of a file), to a data of fixed size (e.g., an
`
`integer number). Human-readable names can then be associated to the integer
`
`number and be used to access the file. An advantage of this approach is that
`
`identical data will be stored only once, because two data objects that have the same
`
`content will end up having the same name, i.e., they will end up being represented
`
`as a single copy of the same object.
`
`B.(cid:1)Overview of the ’799 Patent
`34.(cid:1)
`I understand that the ’799 patent issued from U.S. App. No.
`
`12/823,922, which was filed on June 25, 2010, and claims priority, as continuation-
`
`in-part application, to U.S. App. No. 12/823, 452 filed also on June 25, 2010, and
`
`to U.S. Provisional App. No. 61/269,633, filed on June 26, 2009. ’799 patent at
`
`cover page (Ex. 1001). The purported invention of the ’799 patent relates to
`
`computer file system data structures and to methods and apparatus for the naming
`
`and storing of files. ’799 patent at 1:6-8 (Ex. 1001).
`
`11
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`1.(cid:1) Alleged Problem
`35.(cid:1) The ’799 patent purports to address inefficiencies of legacy file
`
`systems. Specifically, the ’799 patent concludes, without providing any particular
`
`explanation, that “legacy file systems have tight control of the what (content) and
`
`the where (placement of data). This co-mingling of what and where, largely an
`
`artifact of history, results in an architecture that is difficult to extend to modern
`
`storage needs.” See ’799 patent at 6:57-61 (Ex. 1001).
`
`2.(cid:1) Summary of Alleged Invention of the ’799 Patent
`36.(cid:1) The ’799 patent’s claimed file system includes components that are
`
`identical to those in the prior art. Specifically, both the claimed and prior art file
`
`systems have content addressable file systems implemented as a stack, where the
`
`stack is comprised of a file system layered over an underlying content addressable
`
`object store.
`
`37.(cid:1) Fig. 1 of the ’799 patent illustrates various storage components in an
`
`operating system kernel. ’799 patent at 10:25-26 (Ex. 1001). The claimed file
`
`system is composed of namespace file system 107 that is stacked on top of a
`
`lightweight object file system 108 (also referred to as an “Object Store”). ’799
`
`patent at 10:48-49 (Ex. 1001). An annotated Fig. 1 of the ’799 patent is
`
`reproduced below.
`
`12
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`’799 Patent: Fig. 1 (Ex. 1001)
`
`
`
`38.(cid:1)
`
`“The namespace file system […] has files, a directory structure,
`
`links, a superblock, and so forth. The namespace file system doesn’t contain data
`
`directly, instead all data is stored in objects.” ’799 patent at 8:48-51 (Ex. 1001).
`
`39.(cid:1)
`
`“An object store […] is a flat collection of opaque data (objects).
`
`Each object is unique, and has reference counts […]. An object’s name is a
`
`cryptographic hash of the object’s content, i.e., change the content and the name
`
`must change. Any sufficiently strong cryptographic hash is acceptable for
`
`generating object names (fingerprints).” ’799 patent at 8:9-16 (Ex. 1001).
`
`13
`
`

`
`40.(cid:1) An annotated Fig. 2, reproduced below, shows components of the
`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`object store. Specifically, “[o]bject store 108 contains binary, opaque objects,
`
`examples of which are P 201, Q 202 and R 203. […] Each object has a name
`
`(fingerprint), which is a cryptographic digest (hash) of the object’s entire content,
`
`plus some site specific salt. In FIG. 2, the object names are denoted by H(p),
`
`H(q) and H(r).” ’799 patent at 11:1-13 (Ex. 1001).
`
`
`
`’799 Patent: Fig. 2 (Ex. 1001)
`
`41.(cid:1)
`
`“An index structure 204 keeps track of object names, object
`
`locations, and object references. An object’s reference is incremented every time
`
`the object is written. The namespace file system 107 may generate what it thinks
`
`14
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`are many copies of the same object; the object store 108 only stores one, but keeps
`
`track of how many the namespace actually thinks it has.” ’799 patent at 11:14-19
`
`(Ex. 1001).
`
`42.(cid:1) According to the ’799 patent, “[o]bjects are relatively small, and
`
`frequently larger data structures are needed. The structure that aggregates objects
`
`is called an hnode.” ’799 patent at 8:51-53 (Ex. 1001). “An hnode, in the present
`
`embodiment, is a data structure that ties together content, such as a file.” Id, at
`
`8:58-59. FIG. 4, which is reproduced below, illustrates components of an hnode
`
`structure 401. “The hnode uses object identifiers (fingerprints) to identify content,
`
`rather than physical/logical block addressing that legacy inodes use. An hnode is a
`
`sequence of content, like a file, that can be randomly read, written, appended to,
`
`created, deleted and truncated.” ’799 patent at 12:52-57 (Ex. 1001).
`
`15
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`’799 Patent: Fig. 4 (Ex. 1001)
`
`
`
`43.(cid:1) As the ’799 patent explains, “[a] data sequence is broken into discrete
`
`objects, for example, S 410, T 411 and U 412 in FIG. 4. The names of each object
`
`[comprising the content of the object represented by the hnode] are stored in a
`
`mapping table 402, which records the fingerprints of each of S, T and U.” ’799
`
`patent at 12:63-66 (Ex. 1001).
`
`16
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`
`
`’799 Patent: Fig. 5 (Ex. 1001)
`
`44.(cid:1)
`
`“A file 504 may be a thin wrapper that makes an hnode appear as a
`
`normal […] file that can be opened, closed, read, written, and so forth. A
`
`directory 505 is another interpretation of an hnode 401. A directory 505 is a
`
`mapping 501 of inode numbers (an integer) to file names (a string).” ’799 patent at
`
`13:28-33 (Ex. 1001).
`
`45.(cid:1)
`
`“An imap (“inode map”) 502 translates inode numbers (from
`
`directory 501) into an object digest (fingerprint). The object may represent an
`
`hnode (and therefore by extension, a file, directory or other imap), a structure
`
`such as a superblock, or other data.” ’799 patent at 13:37-41 (Ex. 1001).
`
`17
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`46.(cid:1) According to the ‘799 patent, an imap “converts an inode number into
`
`an object fingerprint (name),” ’799 patent at 9:9-10 (Ex. 1001) and “enables the
`
`rest of the namespace file system to deal with inode numbers, which is essential, as
`
`many user level utilities need to see such a construct. In some sense, this provides
`
`an additional layer of indirection (or virtualization) over a traditional static inode
`
`table.” Id. at 9:13-17 (Ex. 1001).
`
`47.(cid:1) But as explained below, there is nothing novel about a content
`
`addressable file system, implemented as a stack of two file systems, that provide
`
`mappings of fingerprints to file system structures.
`
`3.(cid:1) The Challenged Claims
`
`48.(cid:1) Petitioner’s petition challenges claims 1-2, 7-13, 17-20, 27, and 33-35
`
`of the ’799 patent. Independent claim 1 describes a computer file system for
`
`naming and storing of files on one or more computer storage devices. ’799 patent
`
`at claim 1 (Ex. 1001). Claim 1 also specifies additional well known features,
`
`including an object store holding objects having object fingerprints derived from
`
`the content of the object, as noted below.
`
`1. A computer file system for naming and storing of files on
`one or more computer storage devices, the system comprising:
`a namespace file system accessing an object store, the system
`including a memory and a hardware processor in communication with
`the memory, the processor for executing program instructions for
`
`18
`
`

`
`U.S. Patent No. 8,478,799
`Declaration of Darrell D. E. Long, Ph.D.
`
`
`accessing the object store using object fingerprints, the object store
`holding files, data and metadata as objects, each object having a
`globally unique object fingerprint derived from the content of the
`object and used to access the object store, wherein:
`each file object comprising a mapping of object fingerprints for
`the data objects or metadata objects of the file and the file object
`having its own object fingerprint derived from the fingerprints of the
`objects in the file, and wherein the object store further includes:
`an inode map object comprising a mapping of file system inode
`numbers and object fingerprints enabling the inode numbers to stay
`constant while the object fingerprints change as the file content
`changes; and
`directory objects, each directory object comprising a mapping
`of inode numbers and file names;
`wherein each of the inode map object and directory object has
`its own object fingerprint derived from the content of the respective
`object.
`49.(cid:1) The dependent claims add well-known details such as a root object, a
`
`tree structure, an indirection table, and a virtual file system layer.
`
`4.(cid:1) Prosecution History
`50.(cid:1)
`
`I understand that the ’799 patent issued from U.S. App. No.
`
`12/823,922, which was filed on June 25, 2010. The ’799 patent is a continuation-
`
`in-part application, to U.S. App. No. 12/823, 452 filed also on June 25, 201