UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2019-01655
`Patent 9,098,526
`
`Patent Owner SYNKLOUD LLC’s
`Demonstrative Exhibits
`
`1
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2019-01655
`Patent 9,098,526
`
`Patent Owner SYNKLOUD LLC’s
`Demonstrative Exhibits
`
`1
`
`
`
`Institution Decision
`
`• Proposed Grounds Instituted
`– Claims 1-3, 5-11, 13-20 as obvious over Prust and
`Major
`– Claims 1-20 as obvoius over Chaganti and Major
`
`[Institution Decision, Paper No. 13]
`
`2
`
`
`
`The ‘526 Patent
`
`•
`
`Independent Claim 1 requires
`– A wireless device comprising:
`– at least one cache storage, one wireless interface, and program code
`configured to cause the wireless device to:
`– establish a wireless link for the wireless device access to a storage space of a
`predefined capacity assigned exclusively to a user of the wireless device by a
`storage server, and
`– couple with the storage server across the wireless link to carry out a requested
`operation for remote access to the assigned storage space in response to the
`user from the wireless device performed the operation,
`– wherein the operation for the remote access to the assigned storage space
`comprises storing a data object therein or retrieving a data object therefrom,
`the storing of a data object including to download a file from a remote server
`across a network into the assigned storage space through utilizing download
`information for the file stored in said cache storage in response to the user
`from the wireless device performed the operation for downloading the file
`from the remote server into the assigned storage space.
`
`3
`
`
`
`The ‘526 Patent
`
`•
`
`Independent Claim 11 requires
`– A non-transitory computer-readable medium comprising program code that,
`being executed by a wireless device, causes the wireless device to:
`– establish a wireless link for the wireless device access to a storage space of
`predefined capacity assigned exclusively by a storage server to a user of the
`wireless device;
`– couple with the storage server through the wireless link to carry out a
`requested operation for remote access to the assigned storage space in
`response to the user from the wireless device performed the operation,
`– wherein the operation for the remote access to the assigned storage space
`comprises storing a data object therein or retrieving a data object therefrom,
`the storing of the data object including to download a file from a remote
`server on a network into the assigned storage space through utilizing
`download information for the file stored in a cache storage of the wireless
`device in response to the user from the wireless device performed the
`operation for downloading the file from the remote server into the assigned
`storage space.
`
`4
`
`
`
`The ‘526 Patent
`
`• None of the prior art, either alone or in
`combination, would have taught all the
`limitations of independent claims 1 or 11, or
`the claims dependent therefrom.
`
`5
`
`
`
`Claim Construction
`
`• “a storage space of a predefined capacity
`assigned exclusively to the user of a wireless
`device by a storage server”
`– requires that “the server assigns an amount of
`storage, storage to be assigned exclusively for one
`user, that amount having been set in advance of
`any interaction or negotiation between the server
`and the user.”
`
`[Patent Owner Response and Sur-Reply, Paper Nos. 16 and 32
`
`6
`
`
`
`Claim Construction
`
`• “coupling” (claims 1, 11, 13, 14, and 15)
`– “linking of a system’s components to form a
`relationship.”
`
`[Patent Owner Response and Sur-Reply, Paper Nos. 16 and 32]
`
`7
`
`
`
`Claim Construction
`
`• “storing a data object therein or retrieving an
`object therefrom”
`– Requires the device or software to provide for
`storage and retrieval.
`
`[Patent Owner Response and Sur-Reply, Paper Nos. 16 and 32]
`
`8
`
`
`
`None of the Claims Would Have Been Obvious Over Prust and Major
`
`– The Combination of Prust/Major Would Not Have
`Taught:
`• “download[ing] a file utilizing download information for
`the file stored in said cache storage.”
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs. 2001, 2007 ]
`
`9
`
`
`
`None of the Claims Would Have Been Obvious Over Prust and Major
`
`– The Combination of Prust/Major Would Not Have
`Taught:
`• “a storage space of a predefined capacity assigned
`exclusively to a user of the wireless device by a storage
`server.”
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs. 2001, 2007]
`
`10
`
`
`
`None of the Claims Would Have Been Obvious Over Prust and Major
`
`– The Combination of Prust/Major Would Not Have
`Taught:
`• “coupling of the wireless device with the storage
`server.”
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32 and Jawadi Declarations Exs. 2001, 2007]
`
`11
`
`
`
`None of the Claims Would Have Been Obvious Over Prust and Major
`
`– The Combination of Prust/Major Would Not Have
`Taught:
`• “a plurality of storage devices, one of the storage
`devices being configured with the storage space
`assigned exclusively to the user.”
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs 2001, 2007]
`
`12
`
`
`
`None of the Claims Would Have Been Obvious Over Prust and Major
`
`– A POSITA Would Not Have and Could Not Have
`Combined Prust and Major and Reasonably Expect
`Success:
`• Prust does not teach cache and there is no reason to
`add cache to Prust.
`• Prust and Major does not teach copy-and-paste
`• The steps of performing copy-and-paste from a web
`browser’s cache in a wireless device would not have
`been obvious
`• The user (not the code) performs copy-and-paste
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs 2001, 2007]
`
`13
`
`
`
`None of the Claims Would Have Been Obvious Over Prust and Major
`
`– A POSITA Would Not Have and Could Not Have
`Combined Prust and Major and Reasonably Expect
`Success:
`• URLs of data objects are not displayed by the browser
`and cannot be copied directly using copy-and-paste
`• Not all web pages are cacheable or cached
`• A user cannot tell if a web page displayed by a browser
`is from cache or stored in cache
`• Prust does not teach out-of-band download
`• Prust does not teach where the URL for the purported
`out-of-band download is obtained
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs 2001, 2007]
`
`14
`
`
`
`None of the Claims Would Have Been Obvious Over Prust and Major
`
`– A POSITA Would Not Have and Could Not Have
`Combined Prust and Major and Reasonably Expect
`Success:
`• typing is impractical
`• Petitioner’s theory regarding utilizing download
`information stored in cache is far-fetched
`• The purpose of Major’s cache does not match the
`purpose of the cache of the ‘526 patent.
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs 2001, 2007]
`
`15
`
`
`
`None of the Claims Would Have Been Obvious Over Chaganti/Major
`
`– The Combination of Chaganti/Major Would Not
`Have Taught:
`• “download[ing] a file utilizing download information
`for the file stored in said cache storage.”
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations, Exs. 2001, 2007]
`
`16
`
`
`
`None of the Claims Would Have Been Obvious Over Chaganti/Major
`
`– The Combination of Chaganti/Major Would Not
`Have Taught:
`• “a storage space of a predefined capacity assigned
`exclusively to a user of the wireless device by a storage
`server.”
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs. 2001, 2007]
`
`17
`
`
`
`None of the Claims Would Have Been Obvious Over Chaganti/Major
`
`– The Combination of Chaganti/Major Would Not
`Have Taught:
`• “one of the storage devices being configured with the
`storage space assigned exclusively to the user,” as
`required by dependent claims 3 and 20.
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs. 2001, 2007]
`
`18
`
`
`
`None of the Claims Would Have Been Obvious Over Chaganti/Major
`
`– The Combination of Chaganti/Major Would Not
`Have Taught:
`• “obtaining and transmitting download information from
`the cache of a wireless device,” as recited in dependent
`claims 4 and 12.
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs. 2001, 2007]
`
`19
`
`
`
`None of the Claims Would Have Been Obvious Over Chaganti/Major
`
`– The Combination of Chaganti/Major Would Not
`Have Taught:
`• that the wireless device remotely creates, deletes,
`moves, copies or renames a folder, as required by
`dependent claims 6, 7, 10, 13, 14, and 15.
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs. 2001, 2007]
`
`20
`
`
`
`None of the Claims Would Have Been Obvious Over Chaganti/Major
`
`– A POSITA Would Not Have and Could Not Have
`Combined Chaganti and Major and Reasonably
`Expect Success:
`• Chaganti does not teach drag-and-drop or copy-and-
`paste using cache for out-of-band downloads.
`• The steps of performing drag-and-drop or copy-and-
`paste from a web browser’s cache in a wireless device
`would not have been obvious
`• The user (not the code) performs the drag-and-drop,
`and the copy-and-paste
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs 2001, 2007]
`
`21
`
`
`
`None of the Claims Would Have Been Obvious Over Chaganti/Major
`
`– A POSITA Would Not Have and Could Not Have
`Combined Chaganti and Major and Reasonably
`Expect Success:
`• URLs of data objects are not displayed by the browser
`and cannot be copied directly using drag-and-drop or
`copy-and-paste
`• Not all web pages are cacheable or cached
`• A user cannot tell if a web page displayed by a browser
`is from cache or stored in cache
`• Chaganti does not teach drag-and-drop or copy-and-
`paste for out-of-band downloads
`• Chaganti does not teach where the URL for the
`purported out-of-band download is obtained
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs 2001, 2007]
`
`22
`
`
`
`None of the Claims Would Have Been Obvious Over Chaganti/Major
`
`– A POSITA Would Not Have and Could Not Have
`Combined Chaganti and Major and Reasonably
`Expect Success:
`• Major’s teachings discourage wireless device access to
`external storage
`• Combining two different cache implementations is
`difficult
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32; Jawadi Declarations Exs 2001, 2007]
`
`23
`
`
`
`Objective indicia confirm non-obviousness
`
`• License
`– Nexus to the ‘526 patent
`
`[PO Response and Sur-Reply, Paper Nos. 16 and 32]
`
`24
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2019-01655
`Patent 9,098,526
`
`END
`
`25
`
`
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