Case 1:99-mc-09999 Document 1141 Filed 07/22/19 Page 1 of 10 PageID #: 105831
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No.
`
`JURY TRIAL DEMANDED
`
`))))))))))))
`
`SYNKLOUD TECHNOLOGIES, LLC
`
`Plaintiff,
`
`v.
`
`Defendant.
`
`HP INC.
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff SynKloud Technologies, LLC (“SynKloud” or “Plaintiff”), for its Complaint
`
`against HP Inc. (“HP” or “Defendant”) alleges the following:
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action for patent infringement of United States Patent Nos. 9,098,526
`
`(“the ’526 Patent”) and 10,015,254 (“the ’254 Patent” and collectively with the ’526 Patent, the
`
`“Patents-in-Suit”) arising under the Patent Laws of the United States, 35 U.S.C. § 1 et seq.,
`
`seeking damages and other relief under 35 U.S.C. § 281 et seq.
`
`THE PARTIES
`
`2.
`
`Plaintiff is a limited liability company organized under the laws of the State of
`
`Delaware with a place of business at 124 Broadkill Road, Suite 415, Milton, DE 19968.
`
`3.
`
`On information and belief, Defendant is a corporation organized under the laws of
`
`the State of Delaware with a place of business at 1501 Page Mill Road, Palo Alto, CA 94304.
`
`The Delaware Division of Corporations identifies Defendant’s registered agent as the
`
`Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington,
`
`Delaware 19801.
`
`PHIL1 8111465v.1
`
`Exhibit 2015
`
`

`

`Case 1:99-mc-09999 Document 1141 Filed 07/22/19 Page 2 of 10 PageID #: 105832
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`4.
`
`On information and belief, Defendant sells and offers to sell products and services
`
`throughout the United States, including in this District, and introduces products and services into
`
`the stream of commerce and that incorporate infringing technology knowing that it would be sold
`
`in this District and elsewhere in the United States.
`
`5.
`
`On information and belief, Defendant conducts a significant amount of business in
`
`this District through online sales and advertisements directly to consumers and through product
`
`sales by HP’s distributors and resellers.
`
`JURISDICTION AND VENUE
`
`6.
`
`This is an action for patent infringement arising under the Patent Laws of the
`
`United States, Title 35 of the United States Code.
`
`7.
`
`8.
`
`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
`
`Venue is proper in this District under 28 U.S.C. §§ 1391(b), (c) and/or 1400(b).
`
`On information and belief, Defendant has placed, and is continuing to place, infringing products
`
`into the stream of commerce, via an established distribution channel, with the knowledge and/or
`
`understanding that such products are sold in this District. Defendant, directly or through
`
`intermediaries, conducts business in this District, and at least a portion of the acts of
`
`infringement and claims alleged in this Complaint have taken place and are continuing to take
`
`place in this District.
`
`9.
`
`On information and belief, this Court has personal jurisdiction over Defendant
`
`because it is incorporated in Delaware and has purposefully availed itself of the privileges and
`
`benefits of the laws of the State of Delaware. Further, Defendant is subject to this Court’s
`
`general and specific personal jurisdiction because Defendant has sufficient minimum contacts
`
`within the State of Delaware, pursuant to due process and/or the Delaware Long Arm Statute,
`
`
`PHIL1 8111465v.1
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`

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`Case 1:99-mc-09999 Document 1141 Filed 07/22/19 Page 3 of 10 PageID #: 105833
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`because Defendant purposefully availed itself of the privileges of conducting business in the
`
`State of Delaware, and because Plaintiff’s causes of action arise directly from Defendant’s
`
`business contacts and other activities in the State of Delaware, including regularly doing or
`
`soliciting business and deriving substantial revenue from products and services provided to
`
`individuals in this District. The exercise of jurisdiction over Defendant would not offend
`
`traditional notions of fair play and substantial justice.
`
`10.
`
`Plaintiff is the owner of the Patents-in-Suit asserted in this action and has
`
`the exclusive right to sue and collect remedies for past, present, and future infringement
`
`of the patent.
`
`COUNT 1
`INFRINGEMENT OF U.S. PATENT NO. 9,098,526
`
`11. The allegations set forth in the foregoing paragraphs 1 through 10 are
`
`incorporated by reference into this claim for relief.
`
`12. On August 4, 2015, the ’526 Patent, entitled “Method and System for
`
`Wireless Device Access to External Storage,” was duly and legally issued by the United
`
`States Patent and Trademark Office. A true and correct copy of the ’526 Patent is
`
`attached as Exhibit 1.
`
`13. The ’526 Patent issued from United States Patent Application No.
`
`14/150,106 (“the ’106 Application”), filed on January 8, 2014. The ’106 Application is a
`
`Continuation of U.S. Patent Application No. 14/079,831, filed on November 14, 2013,
`
`now U.S. Patent No. 8,868,690, which is a Continuation of U.S. Patent Application No.
`
`10/726,897 filed on December 4, 2003, now U.S. Patent No. 8,606,880.
`
`
`PHIL1 8111465v.1
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`-3-
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`

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`Case 1:99-mc-09999 Document 1141 Filed 07/22/19 Page 4 of 10 PageID #: 105834
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`14.
`
`Plaintiff is the assignee and owner of the right, title, and interest in and to the ’526
`
`Patent, including the right to assert all causes of action arising under the ’526 Patent and the right
`
`to any remedies for infringement of the ’526 Patent.
`
`15. Defendant has infringed and continues to infringe the ’526 Patent under 35 U.S.C.
`
`§ 271, literally or under the doctrine of equivalents, by making, using, selling, and/or offering for
`
`sale in the United States, and/or importing into the United States, infringing products without
`
`authorization (hereafter “Infringing Instrumentalities”). At a minimum, Infringing
`
`Instrumentalities include all HP Laptops and 2-in-1s (e.g., Business, Premium, Gaming, Laptops,
`
`ZBook Workstations, Convertibles and Detachables), Desktops (e.g., Business, Immersive,
`
`Gaming, Towers, Z Workstations, All-in-Ones), and/or the HP Products identified in Exhibit 5
`
`that use cloud services like Microsoft One Drive (“Cloud Services”). This includes products like
`
`the HP 14” Laptop (“HP Laptop”) that use Cloud Services.
`
`16. Defendant directly infringed and continues to directly infringe at least claim 11 of
`
`the ’526 Patent by making, using, selling, offering to sell, importing and/or providing and
`
`causing to be used the HP Laptop which satisfies, literally or under the doctrine of equivalents,
`
`each and every claim limitation of claim 1 of the ’526 Patent. The correspondence between the
`
`limitations of claim 1 of the ’526 Patent and the HP Laptop is shown in the claim chart attached
`
`hereto as Exhibit 2. The claim chart is incorporated by reference as if set forth herein.
`
`Additional details relating to the HP Laptop and their infringement are within the possession,
`
`custody or control of Defendant.
`
`
`1 Plaintiff reserves the right to identify additional asserted claims and accused products as
`this litigation proceeds. For example, Plaintiff expressly reserves the right to identify
`additional asserted claims and accused products in its infringement contentions to be served
`during the discovery process.
`
`
`PHIL1 8111465v.1
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`Case 1:99-mc-09999 Document 1141 Filed 07/22/19 Page 5 of 10 PageID #: 105835
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`17. Defendant provides users with support material for the HP Laptop with
`
`instructions about their use of Cloud Services that practice at least claim 1 of the ’526 Patent.
`
`18. On information and belief, the identified structures and functionalities of the HP
`
`Laptop shown in the claim chart are representative of the structure and functionality present in
`
`all Infringing Instrumentalities including but not limited to HP families of products with the
`
`following designations or trade names: EliteBook laptops, ZBook laptops, ProBook laptops,
`
`Essential laptops, Spectre Folio, Omen laptops, Omen desktops, Pavilion laptop, ENVY laptop,
`
`Chromebook, ZBook, Spectre laptop, ENVY towers, Pavilion desktops, Thin Client, ENVY
`
`desktops, Slimline desktop, EliteDesk Workstation, Z Workstation, HP All-in-One, ENVY All-
`
`in-One Desktop, Sprout Pro, All-in-One Zero Client, and/or the HP Products identified in Exhibit
`
`5. On information and belief, any other product of HP that uses Cloud Services is also an
`
`Infringing Instrumentality. Additional details relating to Infringing Instrumentalities and their
`
`infringement are within the possession, custody or control of Defendant.
`
`19.
`
`Plaintiff offers this preliminary identification and description of infringement
`
`without the benefit of discovery or claim construction in this action, and expressly reserves the
`
`right to augment, supplement, and revise its identification and description of infringement based
`
`on additional information obtained through discovery or otherwise.
`
`20. On information and belief, Defendant had knowledge and became aware that its
`
`products that use Cloud Services infringe the ’526 Patent prior to the filing of this Complaint.
`
`By way of example, prior to the filing of this Complaint, HP received a letter from SynKloud in
`
`June 2019 stating that the ’526 Patent was being practiced in cloud service-enabled products that
`
`were being used, offered for sale and sold by HP. Discovery in this matter may reveal that
`
`Defendant has induced others to infringe the ’526 Patent.
`
`
`PHIL1 8111465v.1
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`Case 1:99-mc-09999 Document 1141 Filed 07/22/19 Page 6 of 10 PageID #: 105836
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`21. Defendant had pre-suit knowledge that it was using the ‘526 Patent and has
`
`knowingly made, used, offered to sell, sold, and/or imported into the United States the Infringing
`
`Instrumentalities that infringed and continue to infringe the ‘526 Patent under 35 U.S.C. § 271.
`
`Because Defendant did so with such knowledge of the ‘526 Patent, Defendant is liable for willful
`
`infringement
`
`22. Defendant’s acts of infringement have caused damage to Plaintiff, and Plaintiff is
`
`entitled to recover from Defendant the damages it has sustained as a result of Defendant’s
`
`wrongful acts in an amount subject to proof at trial.
`
`COUNT 2
`INFRINGEMENT OF U.S. PATENT NO. 10,015,254
`
`23. The allegations set forth in the foregoing paragraphs 1 through 10 are
`
`incorporated by reference into this claim for relief.
`
`24. On July 3, 2018, the ’254 Patent, entitled “System and Method for
`
`Wireless Device Access to External Storage,” was duly and legally issued by the United
`
`States Patent and Trademark Office. A true and correct copy of the ’254 Patent is
`
`attached as Exhibit 3.
`
`25. The ’254 Patent issued from United States Patent Application No.
`
`14/977,509 (“the ’509 Application”), filed on December 21, 2015. The ’509 Application
`
`is a Continuation of U.S. Patent Application No. 14/036,744, filed on September 25,
`
`2013, now U.S. Patent No. 9,239,686, which is a Continuation of U.S. Patent Application
`
`No. 10/726,897, filed on December 4, 2003, now U.S. Patent No. 8,606,880.
`
`26.
`
`Plaintiff is the assignee and owner of the right, title, and interest in and to the ’254
`
`Patent, including the right to assert all causes of action arising under the ’254 Patent and the right
`
`to any remedies for infringement of the ’254 Patent.
`
`
`PHIL1 8111465v.1
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`
`

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`Case 1:99-mc-09999 Document 1141 Filed 07/22/19 Page 7 of 10 PageID #: 105837
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`27. Defendant has infringed and continues to infringe the ’254 Patent under 35 U.S.C.
`
`§ 271, literally or under the doctrine of equivalents, by making, using, selling, and/or offering for
`
`sale in the United States, and/or importing into the United States, infringing products without
`
`authorization (hereafter “Infringing Instrumentalities”). At a minimum, Infringing
`
`Instrumentalities include all HP Laptops and 2-in-1s (e.g., Business, Premium, Gaming, Laptops,
`
`ZBook Workstations, Convertibles and Detachables), Desktops (e.g., Business, Immersive,
`
`Gaming, Towers, Z Workstations, All-in-Ones), and/or the HP Products identified in Exhibit 5
`
`that use Cloud Services. This includes products like the HP Laptop that use Cloud Services.
`
`28. Defendant directly infringed and continues to directly infringe at least claim 12 of
`
`the ’254 Patent by making, using, selling, offering to sell, importing and/or providing and
`
`causing to be used the HP Laptop which satisfies, literally or under the doctrine of equivalents,
`
`each and every claim limitation of claim 1 of the ’254 Patent. The correspondence between the
`
`limitations of claim 1 of the ’254 Patent and the HP Laptop is shown in the claim chart attached
`
`hereto as Exhibit 4. The claim chart is incorporated by reference as if set forth herein.
`
`Additional details relating to the HP Laptop and their infringement are within the possession,
`
`custody or control of Defendant.
`
`29. Defendant provides users with support material for the HP Laptop with
`
`instructions about their use of Cloud Services that practice at least claim 1 of the ’254 Patent.
`
`30. On information and belief, the identified structures and functionalities of the HP
`
`Laptop shown in the claim chart are representative of the structure and functionality present in
`
`
`2 Plaintiff reserves the right to identify additional asserted claims and accused products as
`this litigation proceeds. For example, Plaintiff expressly reserves the right to identify
`additional asserted claims and accused products in its infringement contentions to be served
`during the discovery process.
`
`
`PHIL1 8111465v.1
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`-7-
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`

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`Case 1:99-mc-09999 Document 1141 Filed 07/22/19 Page 8 of 10 PageID #: 105838
`
`all Infringing Instrumentalities including but not limited to HP families of products with the
`
`following designations or trade names: EliteBook laptops, ZBook laptops, ProBook laptops,
`
`Essential laptops, Spectre Folio, Omen laptops, Omen desktops, Pavilion laptop, ENVY laptop,
`
`Chromebook, ZBook, Spectre laptop, ENVY towers, Pavilion desktops, Thin Client, ENVY
`
`desktops, Slimline desktop, EliteDesk Workstation, Z Workstation, HP All-in-One, ENVY All-
`
`in-One Desktop, Sprout Pro, All-in-One Zero Client, and/or the HP Products identified in Exhibit
`
`5. On information and belief, any other product of HP that uses Cloud Services is also an
`
`Infringing Instrumentality. Additional details relating to Infringing Instrumentalities and their
`
`infringement are within the possession, custody or control of Defendant.
`
`31.
`
`Plaintiff offers this preliminary identification and description of infringement
`
`without the benefit of discovery or claim construction in this action, and expressly reserves the
`
`right to augment, supplement, and revise its identification and description of infringement based
`
`on additional information obtained through discovery or otherwise.
`
`32. On information and belief, Defendant had knowledge and became aware that its
`
`products that use Cloud Services infringe the ’254 Patent prior to the filing of this Complaint.
`
`By way of example, prior to the filing of this Complaint, HP received a letter from SynKloud in
`
`June 2019 stating that the ’254 Patent was being practiced in cloud service-enabled products that
`
`were being used, offered for sale and sold by HP. Discovery in this matter may reveal that
`
`Defendant has induced others to infringe the ’254 Patent.
`
`33. Defendant had pre-suit knowledge that it was using the ‘254 Patent and has
`
`knowingly made, used, offered to sell, sold, and/or imported into the United States the Infringing
`
`Instrumentalities that infringed and continue to infringe the ‘254 Patent under 35 U.S.C. § 271.
`
`
`PHIL1 8111465v.1
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`-8-
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`

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`Case 1:99-mc-09999 Document 1141 Filed 07/22/19 Page 9 of 10 PageID #: 105839
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`Because Defendant did so with such knowledge of the ‘254 Patent, Defendant is liable for willful
`
`infringement
`
`34. Defendant’s acts of infringement have caused damage to Plaintiff, and Plaintiff is
`
`entitled to recover from Defendant the damages it has sustained as a result of Defendant’s
`
`wrongful acts in an amount subject to proof at trial.
`
`JURY DEMAND
`
`35.
`
`Plaintiff requests a jury trial of all issues in this action so triable.
`
`WHEREFORE, Plaintiff prays for judgment as follows:
`
`PRAYER FOR RELIEF
`
`A.
`
`B.
`
`Declaring that Defendant has infringed the Patents-in-Suit.
`
`Awarding damages arising out of Defendant’s infringement of the Patents-
`
`in-Suit to SynKloud, including enhanced damages pursuant to 35 U.S.C. § 284, together
`
`with prejudgment and post-judgment interest, in an amount according to proof.
`
`C.
`
`Awarding attorneys’ fees to SynKloud pursuant to 35 U.S.C. § 285 or as
`
`otherwise permitted by law.
`
`D.
`
`Awarding such other costs and further relied as the Court may deem just
`
`and proper.
`
`
`
`
`
`
`
`
`
`
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`PHIL1 8111465v.1
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`Case 1:99-mc-09999 Document 1141 Filed 07/22/19 Page 10 of 10 PageID #: 105840
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`DATED: July 22, 2019
`
`
`
`
`
`
`
`
`OF COUNSEL:
`
`Daniel S. Carlineo, Esq.
`(pro hac vice motion to be filed)
`Nelson M. Kee, Esq.
`(pro hac vice motion to be filed)
`CARLINEO KEE, PLLC
`1517 17th Street, NW; 3rd Floor
`Washington, DC 20036
`Telephone: (202) 780-6109
`dcarlineo@ck-iplaw.com
`
`
`
`
`
`
`
`KLEHR HARRISON
`HARVEY BRANZBURG LLP
`
`/s/ Sean M. Brennecke
`David S. Eagle (#3387)
`Sean M. Brennecke (#4686)
`919 Market Street, Suite 1000
`Wilmington, Delaware 19801
`Telephone: (302) 552-5518
`Facsimile: (302) 426-9193
`deagle@klehr.com
`sbrennecke@klehr.com
`
`Attorneys for Plaintiff
`SynKloud Technologies, LLC
`
`
`PHIL1 8111465v.1
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`-10-
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`

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`Case 1:99-mc-09999 Document 1141-1 Filed 07/22/19 Page 1 of 12 PageID #: 105841
`Case 1:99-mc-09999 Document 1141-1 Filed 07/22/19 Page 1 of 12 PageID #: 105841
`
`
`
`
`
`EXHIBIT 1
`
`EXHIBIT 1
`
`

`

`Case 1:99-mc-09999 Document 1141-1 Filed 07/22/19 Page 2 of 12 PageID #: 105842
`
`US009098526B1
`
`(12) United States Patent
`Tsao
`
`(10) Patent No.:
`(45) Date of Patent:
`
`US 9,098,526 B1
`* Aug. 4, 2015
`
`(54) SYSTEMAND METHOD FOR WIRELESS
`DEVICE ACCESS TO EXTERNAL STORAGE
`
`(71) Applicant: sy Tai (Ted) Tsao, Fremont, CA
`
`(58) Field of Classification Search
`USPC .......... 709/219, 203,226, 220, 200; 455/412,
`455/899
`See application file for complete search history.
`
`(72) Inventor: Sheng Tai Tsao, Fremont, CA (US)
`(73) Assignee: Sheng Tai (Ted) Tsao, Fremont, CA
`(US)
`
`- r
`( c ) Notice:
`
`Subject tO any disclaimer, the term of this
`patent is extended or adjusted under 35
`U.S.C. 154(b) by 0 days.
`This patent is Subject to a terminal dis-
`claimer.
`
`(21) Appl. No.: 14/150,106
`
`(22) Filed:
`
`Jan. 8, 2014
`
`Related U.S. Application Data
`(63) Continuation of application No. 14/079,831, filed on
`Nov. 14, 2013, which is a continuation of application
`No. 10/726,897, filed on Dec. 4, 2003, now Pat. No.
`8,606,880.
`(51) Int. Cl.
`G06F 15/16
`G06F 7/30
`(52) U.S. Cl.
`CPC ................................ G06F 17/30194 (2013.01)
`
`(2006.01)
`(2006.01)
`
`(56)
`
`References Cited
`
`U.S. PATENT DOCUMENTS
`
`8,606,880 B2 * 12/2013 Tsao ............................. TO9,219
`2001/0052073 A1* 12/2001 Kern et al. .........
`... 713, 161
`2002/0104080 A1* 8, 2002 Woodard et al. ...
`717, 176
`2002/0133597 A1 ck
`9, 2002 Jhingan et al. .
`.
`.
`.
`.
`. TO9,228
`.
`.
`.
`.
`.
`.
`.
`.
`.
`2003/0072031 A1* 4/2003 Kuwata et al. ............... 358,115
`2004/0033821 A1
`2/2004 Slesak et al. .......
`455,575..1
`2004/0186750 A1* 9/2004 Surbey et al. ..................... 705/4
`2014/0089360 A1
`3/2014 Tsao ............................. 707/827
`* cited by examiner
`Primary Examiner — El Hadji Sall
`
`ABSTRACT
`(57)
`To meet the needs for storing larger Volume personal infor
`mation for user of wireless device, it is desire to provide extra
`storage space to the wireless device such as for cellphone or
`personal assistant device (PDA) etc due to the limited storage
`space that the wireless device has. Instant application dis
`closed a system and method for the wireless device to effi
`ciently and effectively use remotely located storage space
`provided by a server for storing message or multimedia data
`Such as videos, digital music, digital photo/picture.
`
`20 Claims, 5 Drawing Sheets
`
`Wireless devices supports in a simple environment
`
`
`
`Web server Software
`
`Web Server interface
`
`Other service modules
`
`Wireless device
`
`Other software modules
`
`

`

`Case 1:99-mc-09999 Document 1141-1 Filed 07/22/19 Page 3 of 12 PageID #: 105843
`
`U.S. Patent
`
`Aug. 4, 2015
`
`Sheet 1 of 5
`
`US 9,098,526 B1
`
`Wireless devices supports in a simple environment
`
`
`
`Web server Software
`
`Console Support software
`
`Web server interface
`
`Other Service modules
`
`Wireless device
`'eb-browser
`
`Other software modules
`
`Fig. 1
`
`

`

`Case 1:99-mc-09999 Document 1141-1 Filed 07/22/19 Page 4 of 12 PageID #: 105844
`
`U.S. Patent
`
`Aug. 4, 2015
`
`Sheet 2 of 5
`
`US 9,098,526 B1
`
`Wireless devices access external storage through Web browser
`1.
`
`12
`
`Wireless devices (1)
`
`8
`
`Other Software
`
`Web-console host
`
`Web-console (browser
`
`Other software Module
`
`13
`
`14
`
`
`
`Web server Software
`
`Console support software
`
`Web Server interface
`
`Other Service modules
`
`
`
`Storage System
`4G 4G
`4G
`p2
`p3
`pl
`Sn n
`N.
`
`
`
`11
`
`3
`
`4
`
`2
`
`net
`
`5
`6
`
`7
`
`10
`
`p(n)
`
`Fig. 2
`
`Wireless devices (2)
`
`Other Software
`
`Wireless devices (3)
`
`Other Software
`
`
`
`Wireless devices (n)
`Web-browser
`
`Other Software
`
`

`

`Case 1:99-mc-09999 Document 1141-1 Filed 07/22/19 Page 5 of 12 PageID #: 105845
`
`U.S. Patent
`
`Aug. 4, 2015
`
`Sheet 3 of 5
`
`US 9,098,526 B1
`
`Wireless out-band download
`
`ISP/ASP----Down Load Web Site
`
`15
`
`Storage System
`
`
`
`4G 4G 4G
`pl
`pS
`p3
`
`
`
`1
`
`Fig. 3
`
`

`

`Case 1:99-mc-09999 Document 1141-1 Filed 07/22/19 Page 6 of 12 PageID #: 105846
`
`U.S. Patent
`
`Aug. 4, 2015
`
`Sheet 4 of 5
`
`US 9,098,526 B1
`
`The CCDSVM Support External Device for Huge Number of Wireless Device
`
`Storage server
`
`Storage server
`
`Storage server
`
`NET
`
`Control Management
`Station
`
`
`
`Storage server
`k
`
`Storage server
`
`Storage server
`
`Wireless device
`
`Wireless device
`
`Wireless device
`
`Wireless device
`
`Wireless device
`
`Wireless device
`
`Wireless device
`
`Fig. 4
`
`Wireless device
`
`

`

`Case 1:99-mc-09999 Document 1141-1 Filed 07/22/19 Page 7 of 12 PageID #: 105847
`
`U.S. Patent
`
`Aug. 4, 2015
`
`Sheet 5 of 5
`
`US 9,098,526 B1
`
`A typical Computer system connected to network
`
`Cursor Control
`Device
`116
`
`Input Device
`
`Display
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`Storage Devices
`110
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`
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`
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`16
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`idco card
`90
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`One or more
`CPU 104
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`Communication
`Interface devices 11
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`cb
`rowser 8
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`
`
`
`
`
`
`
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`Console system 12
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`1
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`Server unit 3
`
`Scrwcr unit
`3
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`
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`3
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`Server unit
`3 Sparc
`
`Fig. 5
`
`

`

`Case 1:99-mc-09999 Document 1141-1 Filed 07/22/19 Page 8 of 12 PageID #: 105848
`
`US 9,098,526 B1
`
`1.
`SYSTEMAND METHOD FOR WIRELESS
`DEVICE ACCESS TO EXTERNAL STORAGE
`
`CROSS REFERENCE TO PRIORAPPLICATION
`
`This invention is a continuation application of the U.S.
`patent application Ser. No. 14/079,831 filed on Nov. 14, 2013
`and now a U.S. Pat. No. 8,868,690, which in turn itself is a
`continuation application of U.S. patent application Ser. No.
`10/726,897 filed on Dec. 4, 2003 and now a U.S. Pat. No.
`8,606,880, which is referenced to a prior application No.
`60/401.238 of “Concurrent Web Based Multi-task Support
`for Control Management System filed on Aug. 6, 2002 and
`converted to application Ser. No. 10/713.904 which now is an
`U.S. Pat. No. 7,418,702. This application also referenced to
`an prior application No. 60/402,626 of “IP Based Distributed
`Virtual SAN' filed on Aug. 12, 2002 and converted to appli
`cation Ser. No. 10/713,905 which now is an U.S. Pat. No.
`7.379,990. All mentioned prior applications are herein incor
`porated by reference in their entirety for all purpose.
`
`FIELD OF THE INVENTION
`
`This invention focuses on how a wireless device can actu
`ally use external storage provided by a storage server.
`
`BACKGROUND INFORMATION
`
`Terminology:
`The terminologies described in next few sections reflect the
`Scope and are part of present invention.
`The Internal Storage of a System:
`The storage media Such as hard disk drives, memory Sticks,
`memory etc. is connected to a system directly through bus or
`a few inches of cable. Therefore, the storage media actually is
`a component of the system in an enclosure.
`The External Storage of a System:
`The external storage media is not a component of the
`system in a same enclosure. Therefore, they have to be con
`nected through a connecting medium (e.g. a cable) Such as
`Ethernet cable for IP based storage, Fiber channel cable for
`fiber channel storage, or Such as wireless medium and etc.
`The storage media of an external storage could be magnetic
`hard disk drives, Solid state disk, optical storage drives,
`memory card, etc. and could be in any form Such as Raid
`which usually consists of a group of hard disk drives.
`The Storage Partition, its Volumes, and the Corresponding
`File System:
`To effectively use storage system, each storage device usu
`ally needs to be partitioned into small volumes. After the
`partition, each of the volumes can be used to establish a file
`system on it. To simplify the discussion herein, the term of the
`storage Volume, its corresponding file system, and the term of
`the partition of the storage device are often used without
`differentiation.
`CCDSVM:
`It is an abbreviation for a central controlled distributed
`scalable virtual machine system. The CCDSVM allows a
`control management station to control agroup of systems and
`provide distributed services to a client system on the Internet,
`the Intranet, and an LAN environment.
`ISP & ASP:
`The ISP refers to Internet service provider and the ASP
`refers to application service provider.
`
`FIGURES
`
`FIG. 1 illustrates an embodiment of the instant application,
`the FIG. 1 is the same as FIG. 1 of the prior application of the
`
`2
`“Concurrent Web Based Multi-task Support for Control Man
`agement System’ with an exception of replacing a console
`host with a wireless device.
`FIG. 2 is the same as FIG. 1 of the above except that it
`shows a more detailed storage system controlled by a server.
`In addition, multiple wireless devices are presented for access
`to the storage system.
`FIG. 3 shows a scheme of a wireless device downloading
`contents from an ISP/ASP or other web sites to an external
`storage allocated for the wireless device.
`FIG. 4 is similar to the FIG. 1 of the prior application of the
`“IP Based Distributed Virtual SAN” with exception that each
`IP storage server provides file system as external storage for
`each of the wireless devices instead of providing IP based
`virtual SAN service. Also, each host in said FIG. 1 actually is
`replaced by a wireless device of FIG. 4.
`Unless specified, the programming languages and the pro
`tocols used by each software modules of instant application,
`and the computing systems used in this invention areassumed
`to be the same as described in the mentioned prior patent
`applications.
`In addition, in the drawing, like elements are designated by
`like reference numbers. Further, when a list of identical ele
`ments is present, only one element will be given the reference
`number.
`
`BRIEF DESCRIPTION OF THE INVENTION
`
`Today users commonly face a problem of lack of storage
`capacity configured on their wireless devices such as cell
`phone or PDA, which are usually limited to 256 MB for the
`PDA and much less for the cell phone. To effectively solve
`this problem and let users own multiple gigabytes (GB) of
`storage for their wireless devices as well as allowing the users
`to use the GB storage for their multimedia applications, the
`storage of a server can be used as the external storage for the
`wireless devices. This technology has been briefly introduced
`in the prior patent applications.
`Now let us examine how can the external storage actually
`be used by the wireless devices. First, let each server unit (e.g.
`the server 3 of the FIG. 2) partitions its storage system into
`volume and each of the volumes will have multiple GB in
`size. Therefore, each user of the wireless devices can be
`exclusively assigned for access to a specific storage Volume
`on a server unit. For example, if we need to provide each user
`a 4GB storage space, then a 160GB disk drive can support 40
`users. Therefore, a 4096 GB storage system on the server unit
`can Support a total of 1024 the users. Further, any data on a
`wireless device of a user can be transmitted to an assigned
`storage volume. In addition, the user of the wireless device
`also can download multimedia data from an ISP or ASP to the
`assigned storage Volume in a designated server unit through
`out-band approach shown in FIG. 3. Finally, for one embodi
`ment, the user can use a web-browser, which has a function
`ality of invoking embedded video or music, to enjoy his/her
`stored multimedia contents.
`These and other futures, aspects and advantages of the
`present invention will become understood with reference to
`the following description, appended claims, and accompany
`ing figures.
`
`DESCRIPTION OF THE DRAWINGS
`
`Referring now to FIG. 1, which demonstrates an example
`of an infrastructure comprising a network interconnecting a
`wireless device and a server. In the FIG. 1, Net (2) represents
`a communication link, which may be combined with wireless
`
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`

`

`Case 1:99-mc-09999 Document 1141-1 Filed 07/22/19 Page 9 of 12 PageID #: 105849
`
`US 9,098,526 B1
`
`3
`and wired connection media and guarantee that the commu
`nication packets can be sent/received between the wireless
`device and the server. It is also assumed that the net (2)
`representing a communication infrastructure is built up in
`Such way that a user of a wireless device can access and
`browse any web-site on the Internet, the Intranet.
`In the FIG. 1, the console support software (5) on the server
`(3) can be configured to support web-based multi-tasks for a
`user of the wireless device (1) using a web browser 8. Further,
`the user of the wireless device is facilitated to perform creat
`ing structured layered file directories or folders, and perform
`data management operations, such as delete, move, copy,
`rename for data files or folders/directories and etc. on an
`assigned storage Volume configured in the server (3).
`In addition, the other software modules (9) of the wireless
`device (1) is also configured capable to send data to or receive
`data from the other service modules (7) running on the server
`(3) via communication link (2) through a suitable IP or non-IP
`based protocol. The data being sent or received cold be a
`digital photo picture, a message etc., in respect to a user's
`request.
`Also, the console supporting software (5) of the server (3)
`and the other software modules (9) of the wireless device (1)
`can be implemented with any Suitable languages such as C.
`C++, Java, etc. depending on the implementation.
`Besides, the web-browser (8) of the wireless device (1) can
`be any suitable software, which, is capable to communication
`with web server software (4) on the server (3) or with any
`other web server through the HTTP protocol.
`On the other hand, FIG.2 has demonstrated that the storage
`system (10) of a server 3 can be allocated to multiple wireless
`devices as followings: First, the storage system (10) of the
`server (3) can be partitioned into multiple storage Volumes
`(11) by administration staff through a web-console (13) of a
`console host (12).
`Second, the storage system (10) of the server (3) can be
`partitioned in such way that a user of each of the wireless
`devices can be assigned with a storage Volume having a
`desired size, so that the server 3 can Support maximum num
`40
`bers of the wireless devices.
`In addition, the storage connection media could be any
`kind of cables, such as SCSI cable, IP cable, Fiber cable etc.
`or could be wireless communication media. The storage sys
`tem itself could be various types.
`45
`Finally, the storage system (10) can be accessed by each of
`the wireless devices through IP or non-IP based network and
`protocols.
`FIG.3 has demonstrated that a user from a web-browser (8)
`on a wireless device (1) can download data from a known
`web-site (15) to his/her assigned external storage (10) on the
`server (3). The dash-lined path (a) represents a co