UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2020-01031 and -01032
`Patent 10/015,254
`
`Patent Owner SYNKLOUD LLC’s
`Demonstrative Exhibits
`
`1
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2020-01031 and -01032
`Patent 10/015,254
`
`Patent Owner SYNKLOUD LLC’s
`Demonstrative Exhibits
`
`1
`
`
`
`Institution Decision
`
`• Proposed Grounds Instituted
`– Claims 1-5, 8, and 16-18 are alleged to have been
`obvious over McCown and Dutta
`– Claims 6, 7, 19, and 20 are alleged to have been
`obvious over McCown, Dutta, and Coates
`– Claims 9-13 and 15 are alleged to have been obvious
`over McCown and Dutta; and
`– Claims 9-15 are alleged to have been obvious over
`McCown, Dutta, and Coates
`
`[Institution Decision, IPR2020-01031, Paper No. 16;
`Institution Decision, IPR2020-01032, Paper No. 16]
`
`2
`
`
`
`The ‘254 Patent
`
`•
`
`Independent Claim 1 requires
`– A wireless device accessing a remote storage space, the wireless device comprising:
`– at least one cache storage for caching data received from the Internet, and
`– one computer-readable storage device comprising program instructions which, when
`executed by the wireless device, configure the wireless device accessing the remote storage
`space, wherein the program instructions comprise:
`– program instructions for the wireless device establishing a communication link for accessing
`the remote storage space served by a first server;
`– program instructions for the wireless device displaying the remote storage space upon
`receiving information of the remote storage space from the first server; and
`– program instructions for the wireless device coupling with the first server to carry out a
`requested operation for accessing the remote storage space in response to a user, through the
`remote storage space displayed on the wireless device, performing the operation,
`– wherein the operation being carried out for accessing the remote storage space comprises
`from the wireless device storing data therein or retrieving data therefrom, the storing data
`comprising to download a file from a second server across a network into the remote storage
`space through utilizing information for the file cached in the cache storage in the wireless
`device.
`
`3
`
`
`
`The ‘254 Patent
`
`•
`
`Independent Claim 9 requires
`– A server for delivering storage service, comprising:
`– a plurality of storage spaces residing among a plurality of storage devices; and
`– a computer-readable storage device comprising program instructions that, when executed by
`the server, configure the server to control delivering the storage service; wherein the program
`instructions comprise:
`– program instructions for the server establishing a communication link for a first wireless
`device remotely accessing a first one of the storage spaces;
`– program instructions for the server sending information of the first one of the storage spaces
`to the first wireless device for causing display of the information on the first wireless device;
`and
`– program instructions for the server updating the first one of the storage spaces according to a
`requested operation received from the first wireless device upon a user thereof, through the
`displayed information of the first one of the storage spaces performing the operation for
`remotely accessing the first one of the storage spaces,
`– wherein said operation for remotely accessing the first one of the storage spaces comprises
`from the first wireless device storing data therein or retrieving data therefrom, wherein the
`storing data further comprises program instructions for the server downloading a file from a
`remote server across a network into the first one of the storage spaces through utilizing
`information for the file cached in a cache storage in the first wireless device
`
`4
`
`
`
`The ‘254 Patent
`
`• Dependent Claim 2 requires
`– The wireless device of claim 1, wherein said
`downloading a file from a second server comprises:
`– program instructions for the wireless device obtaining
`the information for the file from the second server,
`and
`– transmitting the information for the file cached in the
`wireless device to the first server to cause the first
`server, in accordance with the information for the file,
`to download the file from the second server into the
`remote storage space.
`
`5
`
`
`
`The ‘254 Patent
`
`• Dependent Claim 10 requires
`– The server of claim 9, wherein said downloading a
`file through utilizing information for the file
`cached in the first wireless device comprises
`– program instructions for the server receiving the
`information for the file from the first wireless
`device, and
`– sending a request of downloading the file to the
`remote server according to the information for
`the file received.
`
`6
`
`
`
`The ‘254 Patent
`
`• Dependent Claim 13 requires
`– The server of claim 9, wherein said program
`instructions configuring the server to control
`delivering the storage service comprise
`– program instructions for the server to send
`information of said plurality of storage devices to
`a web console for partition each of said storage
`devices for creating the storage spaces.
`
`7
`
`
`
`The ‘254 Patent
`
`• None of the prior art, either alone or in
`combination, would have taught all the
`limitations of independent claims 1, 9 or 16,
`or the claims dependent therefrom.
`
`8
`
`
`
`Claim Construction
`
`• “download[ing] a file from a second server
`across a network into the remote storage
`space through utilizing information for the file
`cached in a cache storage in the wireless
`device”
`– Requires information needed to download a file
`from a remote server to be (i) stored in a cache
`storage of a wireless device and (ii) utilized to
`download the file across a network into an
`assigned storage space for the user of the wireless
`device.
`
`[Patent Owner Response, IPR2020-01031, 18-21; Sur-Replies
`
`9
`
`
`
`The Claims Would Not Have Been Obvious Over McCown and Dutta
`
`– The Combination of McCown/Dutta Would Not
`Have Taught:
`• “download[ing] a file from a second server across a
`network into the remote storage space through utilizing
`information for the file cached in a cache storage in the
`wireless device.”
`
`[PO Response, IPR2020-01031, 18-30; Sur-Replies, Jawadi Declarations Exs. 2001, 2003 ]
`
`10
`
`
`
`The Claims Would Not Have Been Obvious Over McCown and Dutta
`
`– The Combination of McCown/Dutta Would Not
`Have Taught:
`• “transmitting the information for the file cached in the
`wireless device to the first server to cause the first
`server, in accordance with the information for the file,
`to download the file from the second server into the
`remote storage space”
`
`[PO Response, IPR2020-01031, 31-37; Sur-Reply, Jawadi Declarations Exs. 2001, 2014]
`
`11
`
`
`
`The Claims Would Not Have Been Obvious Over McCown and Dutta
`
`– The Combination of McCown/Dutta Would Not
`Have Taught:
`• “receiving the information for the file from the first
`wireless device, and sending a request of downloading
`the file to the remote server according to the
`information for the file received”
`
`[PO Response, IPR2020-01032, 30-34; Sur-Reply, Jawadi Declarations Exs. 2001, 2003]
`
`12
`
`
`
`The Claims Would Not Have Been Obvious Over McCown and Dutta
`
`– The Combination of McCown/Dutta Would Not
`Have Taught:
`• “send[ing] information of said plurality of storage
`devices to a web console for partition each of said
`storage devices for creating the storage spaces”
`
`[PO Response, IPR2020-01032, 34-39; Sur-Reply, Jawadi Declarations Exs. 2001, 2003]
`
`13
`
`
`
`The Claims Would Not Have Been Obvious Over McCown and Dutta
`
`– A POSITA Would Not Have and Could Not Have
`Combined McCown and Dutta and Reasonably
`Expect Success:
`• Petitioners’ “readily accessible” theory would not have
`motivated a POSITA to modify McCown to include a
`cache and to store download information in the
`cached.
`• Petitioners’ theory of why a POSITA would have been
`motivated to modify McCown to include a cache and to
`store download information in the cache is inconsistent
`with Petitioners’ own description of McCown.
`
`[PO Response, IPR2020-01031, 37-47; Sur-Replies; Jawadi Declarations Exs 2001, 2003]
`
`14
`
`
`
`The Claims Would Not Have Been Obvious Over McCown and Dutta
`
`– A POSITA Would Not Have and Could Not Have
`Combined McCown and Dutta and Reasonably
`Expect Success:
`• A POSITA would not have been motivated to modify
`McCown to include a cache and to store download
`information in the cache because McCown stores the
`files at the storage site.
`• Petitioners’ argument about “re-opening the web
`page” would not have motivated a POSITA to modify
`McCown to include a cache and to store download
`information in the cache.
`
`[PO Response, IPR2020-01031, 37-47; Sur-Replies; Jawadi Declarations Exs 2001, 2003]
`
`15
`
`
`
`The Claims Would Not Have Been Obvious Over McCown and Dutta
`
`– A POSITA Would Not Have and Could Not Have
`Combined McCown and Dutta and Reasonably
`Expect Success:
`• there is a difference between retrieving from cache as
`claimed by the ‘254 Patent and retrieving from a
`displayed web page
`
`[PO Response, IPR2020-01031, 37-47; Sur-Replies; Jawadi Declarations Exs 2001, 2003]
`
`16
`
`
`
`Objective indicia confirm non-obviousness
`
`• Licenses
`• Commercial Success
`– Microsoft OneDrive
`– Google Drive
`
`[PO Response, IPR2020-01031, 47-79 and Sur-Replies
`
`17
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2020-01031 and -01032
`Patent 10,015,254
`
`END
`
`18
`
`
`
`IPR2020-01031 and 01032
`U.S. Patent No. 10,015,254
`
`CERTIFICATE OF SERVICE
`
`Under 37 C.F.R. §§ 42.6(e), this is to certify that an electronic copy of
`
`the PATENT OWNER’S DEMONSTRATIVE EXHIBITS FOR IPRS 2020-01031 AND
`
`2020-01032 were served on the Petitioners’ lead and backup counsel listed
`
`below by email to the following email addresses:
`
`Lead Counsel
`
`Joseph A. Micallef
`Reg. No. 39,772
`iprnotices@sidley.com
`jmicallef@sidley.com
`Sidley Austin LLP
`1501 K Street, N.W.
`Washington, D.C. 20005
`(202) 736-8492
`
`Backup Counsel
`
`Scott M. Border
`Reg. No. 77,744
`sborder@sidley.com
`Sidley Austin LLP
`1501 K Street, N.W.
`Washington, D.C. 20005
`(202) 736-8818
`
`Date: August 25, 2021
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`By: _/Gregory Gonsalves_____
`Dr. Gregory Gonsalves
`
`1
`
`
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