Trials@uspto.gov
`571-272-7822
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`Paper # 32
`Entered: June 8, 2020
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`NETAPP, INC.,
`Petitioner,
`
`v.
`KOM SOFTWARE, INC.,
`Patent Owner.
`______________
`
`IRP2019-00598 (Patent 7,076,624 B2)
` IRP2019-00604 (Patent 7,536,524 B2)
`______________
`
`Record of Oral Hearing
`Held virtually: Wednesday, May 27, 2020
`
`
`
`BEFORE: KIMBERLY MCGRAW, DANIEL J. GALLIGAN, and BRENT
`M. DOUGAL, Administrative Patent Judges
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`571-272-7822
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`Paper # 32
`Entered: June 8, 2020
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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`NETAPP, INC.,
`Petitioner,
`
`v.
`KOM SOFTWARE, INC.,
`Patent Owner.
`______________
`
`IRP2019-00598 (Patent 7,076,624 B2)
` IRP2019-00604 (Patent 7,536,524 B2)
`______________
`
`Record of Oral Hearing
`Held virtually: Wednesday, May 27, 2020
`
`
`
`BEFORE: KIMBERLY MCGRAW, DANIEL J. GALLIGAN, and BRENT
`M. DOUGAL, Administrative Patent Judges
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`IRP2019-00598 (Patent 7,076,624 B2)
`IRP2019-00604 (Patent 7,536,524 B2)
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`A P P E A R A N C E S
`
`ON BEHALF OF PETITIONER NETAPP, INC.:
`
`
`ERIKA HARMON ARNER
`FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER
`LLP
`Two Freedom Square
`11955 Freedom Drive
`Reston, Virginia 20190-5675
`571.203.2754
`erika.arner@finnegan.com
`
`JOSHUA L. GOLDBERG, ESQUIRE
`GOLDBERG, FINNEGAN & MESTER
`901 New York Avenue Northwest
`Washington, D.C. 20001
`202.408.6092
`joshua.goldberg@finnegan.com
`
`
`ON BEHALF OF PATENT OWNER:
`
`
`GREGORY S. DONAHUE, ESQUIRE
`GABRIEL GERVEY, ESQUIRE
`DINOVO PRICE
`7000 North MoPac Expressway
`Suite 350
`Austin, Texas 78731
`512.539.2626
`gdonahue@dpelaw.com
`ggervey@dpelaw.com
`
`ALSO PRESENT:
`CHRISTINE LAM, NETAPP
`
`
`The above-entitled matter came on for hearing on Wednesday,
`May 27, 2020, commencing at 11:00 a.m. EDT, by video/by telephone.
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`IRP2019-00604 (Patent 7,536,524 B2)
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` P R O C E E D I N G S
` JUDGE DOUGAL: Good morning. This is the
`joint oral hearing for IPR 2019-00598 and
`IPR 2019-00604, between Petitioner, NetApp,
`Incorporated, and Patent Owner, KOM Software,
`Incorporated, concerning U.S. Patent Nos.
`7,076,624 and 7,536,524. I'm Judge Dougal. With
`me today are Judges McGraw and Galligan.
` We'll start with appearances, beginning
`with Petitioner.
` Who do we have for Petitioner today?
` MR. GOLDBERG: Good morning, Your Honor.
`This is Joshua Goldberg, for Petitioner. With me
`on video I have my counsel, Erika Arner, and then
`also, I believe, on the telephone line, I have
`Christine Lam, who is the director of IP at
`NetApp, the petitioner.
` JUDGE DOUGAL: And for Patent Owner?
` MR. DONAHUE: Yes, this is Greg Donahue
`with DiNovo Price, representing KOM Software,
`Inc., as lead counsel. I also have Gabriel Gervey
`in the room, who will also be arguing. Mostly
`with specifics to the -604 proceeding today, and
`he will replace me in the chair when it's his turn.
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` JUDGE DOUGAL: Thank you. Okay. So for
`this hearing, each side will have 60 minutes of
`total time. We'll start with Petitioner.
` Petitioner, would you like to reserve some
`type for rebuttal?
` MR. GOLDBERG: Yes, Your Honor. I'll
`reserve 15 minutes.
` JUDGE DOUGAL: Okay.
` Mr. Goldberg -- Mr. Donahue, would you
`like to reserve time for rebuttal?
` MR. DONAHUE: Yes, we would like to
`reserve 10 minutes for sur-rebuttal.
` JUDGE DOUGAL: Okay. Some procedural
`things, we want to thank everyone for your
`flexibility for joining us on this video call.
`Our primary concern is that you're heard, so at
`anytime during the proceeding, if you encounter
`technical or other difficulties that you feel
`undermine your ability to adequately represent
`your client, please let us know immediately. For
`example, you may need to contact the team who
`provided you with the connection information
`today. When not speaking, please mute yourself.
`Please identify yourself each time you speak. As
`you know, we have the entire record, including
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`your demonstratives. Please be clear and explicit
`when you refer to your demonstratives. Please
`pause for a few seconds after you give us what
`page you're on, so that we can find where you're
`at and follow along. And also know that there may
`be members of the public listening in to the audio
`line today.
` So does either party have any questions
`before we begin?
` MR. GOLDBERG: None for Petitioner, Your Honor.
` MR. DONAHUE: None for Patent Owner,
`either. Thank you.
` JUDGE DOUGAL: Okay. All right. With
`that, Mr. Goldberg, if you'd like to start for
`Petitioner.
` MR. GOLDBERG: Yes, Your Honor. So I'd
`like to start with our slide 4 -- and the
`demonstratives that were filed in both proceedings
`are identical, so whichever ones you'd prefer to
`look at. There are three main disputes across the
`two proceedings. I'm going to mainly focus on the
`'524 today, because the disputes from the '624 are
`only a subset of the disputes for the '524.
` The three main disputes are whether the
`references teach the claimed operation access
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`privilege. We can see that in the pinkish color
`in the slides, whether their references teach the
`claimed associating of the privilege with the
`portion of the storage medium, we can see that in
`the blue on the slides. And then, finally, with
`respect to a dependent claim 24 in the '524
`patent, whether it forces the claimed security
`erasure, which comprises overwriting the portion
`of the storage medium, would have been obvious.
` I'll start with the claimed operation
`access privilege and associating. Instead of
`directly addressing whether the Nagar and Vossen
`references teach what the claims recite, KOM
`attempts adds requirements to the claims by
`pointing to various parts of the specifications of
`the '524 and '624 patents, in the prosecution
`history of the '624 patent, then, KOM argues the
`references don't teach their additional
`requirements.
` For example, they complain that Nagar and
`Vossen don't teach the claimed privileges because
`the allowance or denial of operations in the
`references is also based on things like data or
`the calling process, and they complain that Nagar
`and Vossen don't teach the claimed associating,
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`because they don't teach that the storage mediums
`have the privileges before they were mounted and
`after they were dismounted.
` The problem for KOM is, that they didn't
`perform a proper Phillips analysis, and the record
`not only fails to support their additional
`requirements, it also shows why they aren't
`requirements of the claims of the '524 and '624
`patents at all. We can see that everything that
`KOM cited from the intrinsic record is irrelevant
`to the disputes here by walking through each of
`the citations. I'll do that, going to slide 6.
` We can see the first part of the
`prosecution history that KOM cites on this slide,
`the prosecution history, at page 43, KOM says a
`lot of things about what the claimed operation
`access privilege is and the associating require,
`and their arguments vary from reference to
`reference and paper to paper in these proceedings,
`but we can dispense with all their arguments and
`requirements by looking directly to the intrinsic
`record.
` KOM points to what's shown in red on this
`slide 6, arguing that this somehow creates
`requirements for the operation access privilege in
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`associating terms, but it doesn't. We can see
`here, in red, the statement that, "... the trap
`layer of the present invention allowed or denied
`an operation based solely on the operation, and
`regardless of the user." This is a summary of
`what happened during a telephonic interview with
`the examiner. And we can see at the end of the
`summary, in green, that it was agreed that
`clarifications to the claims would better
`distinguish the claimed invention from Orita.
` So essentially, what we have here is the
`summary of some differences that were discussed
`during the interview, and then the examiner, not
`finding that good enough, and indicating that
`there were going to have to be some claim
`amendments.
` If we move to slide 7, we can see the only
`other part of the prosecution history that KOM
`cites to, again at page 43, in red, where it says,
`"Enforcement of the operation access privilege
`allows enabled operations or denies restricted
`operations."
` Moving to slide 8, we can see on the
`prosecution history, pages 43 and 44, what KOM
`actually did, based on the interview with the
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`examiner, and we can see that, when we look at the
`green parts, "Applying operation access
`privilege," "Providing an operation access
`privilege," "Associating said operation access
`privilege," that these are the parts that KOM is
`trying to say that, somehow, the prosecution
`history impacts their meaning, but there's no
`changes to the claims here.
` Instead, based on the interview, KOM ended
`up only changing the claims with respect to the
`intercepting step. And we can see that
`highlighted in red here, and also the original
`from the prosecution history, bolding and
`italicizing of the intercepting step. This is the
`only place where they actually made any
`amendments.
` But regardless of what they discussed with
`the examiner, the prosecution history shows that
`the only changes that were made to the claims were
`made with the respect to the intercepting step,
`which has nothing to do with the claimed operation
`access privilege or the claimed associating.
` And if we move to slide 9, we can see that
`this is proven out by what KOM said to the
`examiner during prosecution. This is on page 44
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`of the prosecution history. KOM, explaining to
`the examiner why it is that the claims are now
`good enough over the prior art, they say that,
`"Orita failed to teach why intercepting an
`attempted operation occurs regardless of the
`identity of the user, and transparently to the
`user and transparently to a computer application
`invoking said application."
` So again, we're focusing on the
`intercepting, not on the operation access
`privilege, and not on the associating. And they
`say that, "Orita did not specifically teach that
`interception of an attempted operation occurs
`transparently to the user and transparently to the
`application invoking the attempted operation."
`Again, we're talking about interception.
` And finally, they say, "In contrast, the
`invention, as claimed in claim 36, intercepts all
`operations regardless of the user's identity, and
`does not require that a user log in." So all of
`their arguments during prosecution are just about
`the intercepting stuff. They, in no way, support
`any restrictions on the operation access privilege
`or on the associating, because that's not what was
`at issue during prosecution and what was being
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`amended and what was being argued by KOM in their
`Patent Owner response.
` Moving to claim 10, we can see that KOM
`itself recognizes, in its sur-replies, that the
`allowance or denial that they want, to say, "Needs
`to be based only on the operation and it can't be
`based on anything else." They, themselves,
`recognize, based on some dependent claims, that,
`in the '524 sur-reply, "...the allowance or denial
`of the operation to be based on more than the type
`of operation."
` And in the '624 sur-reply, page 3, "...the
`allowance or denial of the operation to be based
`on more than just the type of operation. The
`dependent claims make the allowance or denial of
`an operation based on the type of operation, as
`recited in the independent claims, and, then,
`further based on the content of the data, the
`process or application requesting the operation."
` It's not surprising that KOM recognizes
`that there really can't be any restriction on the
`claim that forces the operation to be the only
`thing that's with that, because, if we turn to
`slide 11, we can see dependent claims 18 and 28,
`from the '524 patent. Claim 18, recognizing that,
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`"...wherein the allowing or denying of said
`attempted operation further comprises identifying
`an attribute of the data associated with said
`attempted operation."
` And looking at claim 28, "...associating
`an application with said at least a portion of the
`storage medium and determining the application is
`permitted to attempt operations on said at least a
`portion of the storage medium." So here we have,
`looking at data, looking at applications in the
`dependent claims of the '524 patent.
` And in the KOM sur-replies, they tried to
`somehow evade this by saying the claim
`"differentiation"; this means this information
`isn't in the independent claim, but they're
`approaching the doctrine of claim differentiation
`wrong. The fact that these dependent claims exist
`means that the independent claims have to at least
`be broad enough to cover these additional types of
`comparisons and these additional types of things
`that are looked at beyond just the operation.
` Turning to slide 12, we can see that it's
`not just the dependent claims that show this, it's
`also the specification of the '524 patent, where
`it says that, "The access privilege policy have
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`been extended to...prohibit the creation of
`certain types of files or allow them."
` And then it goes on to give examples of
`looking at whether it's an mp3 or an mpg file to
`determine whether you're going to be doing
`screening or not. So again, you can't just have
`the operation access privilege be only an
`operation that is, in no way, impacted by data or
`by a process or by anything else.
` Turning to slide 13, we can see more
`examples from other patents in the same family as
`the '624 and '524 patents, that is, on side 13,
`showing that it can be based on application or a
`process, slide 14 showing that it could be based
`on the content of the data.
` KOM, does, in passing, make some point
`that these are CIP applications and, therefore,
`they should be ignored. I think that that's a
`fringe argument for them to be making, given that
`the '524 is actually a CIP of the '624, and their
`view is that the claims need to be construed
`exactly the same way between those two, and that
`they can even point to the prosecution history of
`the '624, because [indiscernible] in the '524.
` Turning to slide 15, KOM also tries to
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`argue that, in the '524 disk, the portion of the
`storage medium can't be a logical portion of the
`storage medium in their Patent Owner response.
`This is just an incorrect argument and it runs
`directly counter to what they admitted previously
`in the case. And the preliminary response in the
`'524 recognized that the '524 patent relates to
`associating access privileges with a logical
`portion of up to the entire logical storage
`medium, and you can see the underlining in red,
`that they also talked about being a logical
`portion of the storage medium.
` And even if it wasn't enough that they
`admitted this, and we think that that is, I point
`you to IPR 2018-00343, paper number 56, at
`pages 72 and 73, finding that you can't walk back
`admissions that have been in the actual case
`that's at issue.
` Even if that wasn't enough, we can look to
`the '524 patent itself, at column 4, lines 13
`to 15, where it says that, "According to an
`exemplary aspect of the present invention, the
`method may include wherein the storage medium is a
`logical storage medium." So in the specification
`of the very patent at issue, it's recognizing that
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`logical is really just a subset there.
` Turning to slide 16, the next portion of
`the specification that KOM cites to is shown on
`the left-hand side here, which is talking about,
`generally, a -- one of the goals of the '524 and
`'624 patents, that's saying that they want to
`avoid alteration of data. This isn't in the
`claims, but even if it was, it can't differentiate
`over the prior art at issue in this case.
` We can see from Nagar at the top right,
`approximately five lines down: "If any virus
`signature is detected, the filter driver can
`reject the write request, protecting the user's
`physical discs from possible corruption." So
`we're avoiding an undesirable alteration of data
`here in Nagar.
` With respect to Vossen, we can see, at the
`bottom right, approximately six lines down into
`the first paragraph for Vossen, that the,
`"...processes providing access to the information
`can be useful in reducing the danger of such
`inappropriate disclosure or modification." And
`further, that, "The virtual memory space of each
`process is protected from arbitrary modification
`by other processes." So they're both
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`accomplishing that same goal of avoiding
`undesirable alteration of data.
` Moving to slide 17, we can see the next
`portion of the specification that KOM cites, the
`abstract of the '524 and '624 patents. Again,
`what's described in the abstract is not claimed
`anywhere in the '524 and '624 patents. We can
`see, matching up the purple and the blue here,
`this is something, rather than being claimed in
`the '524 and '624, it was actually claimed in the
`'175 patent, which is, again, in the same family
`as the '524 and '624. It's apparent it's way up
`the chain, KOM knew how to claim these things in
`the specification, and it chose to do so in a
`patent. It just wasn't the '524/'624 patents, it
`chose to do that in the '175 patent.
` Going to slide 18, we can see here the
`green part of the abstract corresponding to
`claim 2 of the '175 patent, not the patent at
`issue here.
` Slide 19, the orange and pinkish color in
`the abstract corresponding to the orange and pink
`in claims of the '175 patent, again, not anywhere
`found in the claims of the '524 or '624 patent.
` Side 20, we can see the yellow in the
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`abstract corresponding to a portion of claim 1 of
`the '175 patent. Again, not showing up in the
`'524 or '624 claims and, therefore, having no
`ability to impact the meaning of those claims.
` Moving to slide 21, we can see the next
`portion of the specifications that KOM cites to on
`the left-hand side, and you can see the purple and
`the green corresponding not to the claims in the
`'524 and '624 patent, but instead to the claim in
`the '864 patent. What is in the specification
`that they're citing to, again, showing up nowhere
`in the '524 and '624.
` Same thing if we go to slide 22, another
`part of the specification that they cited, not
`showing up in the '524 and '624 claims, instead
`corresponding to the '864 patent.
` Slide 23, again, the purple and green not
`corresponding to anything in the claims of the
`'524 and '624 patents, but, instead, just
`corresponding to the claims in the '864 patent.
` Moving to the final part for the
`specification that they cited to, slides 24 and
`25, points to figures 5 and 6, who tried to argue
`that somehow the support is required by the
`storage medium itself, and that the privileges
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`IRP2019-00598 (Patent 7,076,624 B2)
`IRP2019-00604 (Patent 7,536,524 B2)
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`need to be stored on the storage medium and taken
`off of it, and that's why they can have this
`mounting and dismounting argument that they make.
` What I want to note on slide 24, here,
`toward about the middle of the paragraph, it says
`that, "The trap layer intercepts the request and
`the data and determines whether the storage medium
`selected supports the operation." And, "When the
`storage medium supports the operation, the request
`and the data is passed on to the file system
`layer."
` Now, KOM, sometimes in their papers, it
`seems like they're trying, maybe, to argue that
`this is dealing with some type of physical level,
`is the medium able to do the operation, or is
`there something that physically prevents that from
`happening. And I want to be clear that that's not
`the type of privilege that is being claimed in the
`'524 and '624 patents. And we know that because,
`if we look at slide 25, we can see here that,
`around the seventh line down, it says, "Upon
`mounting a storage medium, data relating to
`physical limitations of the read/write device are
`loaded into the device driver for that device
`within the file system layer."
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`IRP2019-00598 (Patent 7,076,624 B2)
`IRP2019-00604 (Patent 7,536,524 B2)
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` So that's the actual physical issues that
`are on the storage medium, but it goes on to say
`that, "Also upon mounting the storage medium, the
`data relating to access privileges for the storage
`medium are loaded into the trap layer." These
`access privileges, the operation access
`privileges, that's what's at issue in the '524 and
`'624 patents.
` Now, KOM wants to try to somehow import
`into the claims this very specific exemplary
`embodiment of figure 6, and say that the claims
`somehow require that you store information onto
`the storage medium and, therefore, it can be
`mounted or dismounted and taken away, and the
`privileges are still on the storage medium.
` Now, first, I want to point out that even
`this portion of the specification, and the
`figure 6, say nothing about putting information on
`to the storage medium. They don't say, "Taking
`privileges and putting them onto the storage
`medium."
` And to the extent that there's discussion
`here about loading privileges into the storage
`medium, that, again, is something that is not
`claimed in the '524 or '624 patents. Again,
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`IRP2019-00598 (Patent 7,076,624 B2)
`IRP2019-00604 (Patent 7,536,524 B2)
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`that's actually something that is claimed in the
`'175 patent, specifically claim 1 of the '175
`patent, Exhibit 1012, in the '524 case, at column
`10, lines 29 to 31. That's where they claimed the
`loading step. There's no loading step in the
`claims of the '524 or '624 patent.
` One other point that I want to make here
`is that, the claims of the '524 and '624 patent
`don't occur on the storage medium. If we flip
`back to slide 4 for a moment, we can see that the
`independent claim 29, is, "A computer program
`product for applying an operation access privilege
`to a storage medium," and, "The computer program
`product includes program logic, which, when
`executed on a computer, performs a method, the
`method comprising." So the steps that we're
`discussing here in independent claim 29, and
`there's not really a difference when you look at
`independent claim 1, in terms of the disputes
`between the parties, are all about a method that
`is being carried out by the computer. It's not
`anything about something happening on the storage
`medium.
` This associating happens within the
`computer itself. It can't be something that
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`requires storage on the storage medium and the
`ability to mount or dismount the storage medium.
`That's just not in the claims and it's not even
`compatible with the claims of the '524 patent.
` Just very quickly, on slide 5, we can see
`the same issue arises in the '624 patent. If you
`look at independent claim 22, again, it's a
`computer program product, and it has the same
`issue that it's associating with something
`happening on the computer and not something that's
`happening in the storage medium itself.
` JUDGE DOUGAL: Counsel, this is Judge Dougal.
`So isn't there a slight difference with the patent
`claims for the '624 patent? I mean,
`claim 1 there does say, "Applying an operation
`access privilege to at least a logical portion of
`the logical storage medium."
` MR. GOLDBERG: Yeah. The claim of the
`'624 patent is a little bit more detailed in some
`ways, but I think it's important to recognize that
`that is really just the preamble of the claim, and
`this applying is the method that's being discussed
`in the claim. And we can see at the end of the
`preamble, it says, "...the method comprising the
`steps of:" and then it goes on to discuss the
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`IRP2019-00604 (Patent 7,536,524 B2)
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`providing and associating and intercepting.
` So this applying is not an independent
`limitation, it is just the intended use, the
`purpose, and it is something that is necessarily
`met by meeting the body of the claim because that
`is what the applying method is by definition when
`you look at the claim language.
` If there's no other questions on this,
`I'll move on to the Nagar reference on slide 26.
`I want to, again, note that KOM didn't dispute
`that the Nagar and Vossen references teach what
`the claims actually say, but even if the claims
`include their additional requirements, which they
`don't, as we just discussed, the references do
`teach those additional requirements.
` Starting with Nagar, we can see here the
`read request, and this is shown on the figure on
`the left-hand side of slide 26, in the red box.
`The filter driver will forward write requests if
`no virus is found, and, in parentheses,
`"(typically read requests are immediately
`forwarded)."
` So there's no additional analysis that
`happens when we're talking about a read request.
`It just determines this is a read, and when it's a
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`read, it doesn't matter whether there's any data
`because there's not any data when you're doing a
`read. It doesn't matter what a user is, it
`doesn't matter what a process is, if it's a read,
`it's allowed. And that right there would meet
`even KOM's requirement that the operation access
`privilege doesn't relate to any of these other
`things, like data or like processes or anything
`like that.
` If we go to slide 29, KOM tries to make an
`argument in its sur-replies, that somehow the read
`is also having additional checks on the data done
`as the read moves back up the stack. So their
`view would be, you do a read, it goes and it gets
`some data, and then on the way back up, when it
`again passes through the filter driver, it somehow
`gets checked again, and that creates a problem
`there.
` The first issue with KOM's arguments is
`that, even if that was the case, the read has
`already been allowed. It's already gone down to
`the disk and done what it needs to do. But more
`importantly, KOM is just flat-out wrong when it
`argues that these additional checks happen on read
`requests. They point to, on the right-hand side
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`of figure -- on slide 29, they point to the red
`box, and they say that, because there's some
`double-ended arrows next to it, that that means
`the reads are going to be checked on the way up.
` But that's not what it says. If you read
`what's in the red box, the, "Filter driver will
`intercept all I/O to the logical volume." So it's
`only intercepting the I/O on the way down. It
`does not intercept it on the way back up and check
`it again.
` KOM also tries to point to the Nagar
`reference, at page 499, to argue this.
`Specifically, in the second paragraph on the
`slide, it says that, "Virus-detection software
`must also be able to automatically check for
`viruses that might be present on existing media,
`(especially on removable media)." And they take
`this to mean that, when you're doing the read and
`write operations, that you're going to have to be
`doing an additional check on the way back up.
` That is not what the Nagar reference is
`talking about on page 499. We can see in the very
`next sentence, it says, "In most cases,
`virus-detection software will also provide
`functionality that will scan removable media
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`IRP2019-00604 (Patent 7,536,524 B2)
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`whenever they are reinserted into a drive on the
`machine."
` So what Nagar is talking about, at 499, is
`not the filter driver checking reads and writes
`when they go down and up, what it's talking about
`is doing the general scan of the media to see if
`there's any viruses. This would be like, back in
`the day, if you used McAfee or Norton antivirus or
`anything like that, where you tell it to scan for
`viruses, and then you just sit there for a couple
`of hours while it does the scan. It is not the
`filter driver discussion of you're going to open a
`file, read a file, write to a file.
` Going to slide 28, we can see here that
`the filter driver and, thus, the privileges in it,
`are associated with a portion of the storage
`medium. At the top part of the slide, it,
`"Intercepts all user write requests and encrypted
`data being stored to disk for targeted files,
`directories, and complete mounted logical
`volumes."
` If we go to slide 30, we can see that this
`is the very same type of associating that's
`happening in the '524 and '624 patents. On the
`right-hand side, we have the figure from the '524
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`IRP2019-00604 (Patent 7,536,524 B2)
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`and '624 patents, showing the trap layer being
`located directly in between the application layer
`and the file system layer and connected by the
`double-ended arrows in both places.
` On the left-hand side, we have the Nagar
`system showing, again, the filter driver, the
`equivalent of the trap layer in Nagar, being
`located between the application layer and the file
`system layer. It's the very same type of
`association that is happening in Nagar and in the
`'524 and '624 patents.
` This is again
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