Paper No. 1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MICROSOFT CORPORATION and HP INC.
`Petitioners,
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`v.
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`SYNKLOUD TECHNOLOGIES, LLC,
`Patent Owner.
`
`Patent No. 9,239,686
`Issued: January 19, 2016
`Filed: September 25, 2013
`
`Inventor: Sheng Tai Tsao
`
`METHOD AND APPARATUS FOR WIRELESS DEVICE ACCESS
`TO EXTERNAL STORAGE
`________________________
`Inter Partes Review No. IPR2020-01271
`________________________
`PETITION
`REGARDING U.S. PATENT NO. 9,239,686
`________________________
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`Title:
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`
`
`
`MICROSOFT CORPORATION and HP INC.
`Petitioners,
`
`v.
`
`SYNKLOUD TECHNOLOGIES, LLC,
`Patent Owner.
`
`Patent No. 9,239,686
`Issued: January 19, 2016
`Filed: September 25, 2013
`
`Inventor: Sheng Tai Tsao
`
`METHOD AND APPARATUS FOR WIRELESS DEVICE ACCESS
`TO EXTERNAL STORAGE
`________________________
`Inter Partes Review No. IPR2020-01271
`________________________
`PETITION
`REGARDING U.S. PATENT NO. 9,239,686
`________________________
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`Title:
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`Petition for Inter Partes Review of U.S. Patent No. 9,239,686
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`TABLE OF CONTENTS
`INTRODUCTION ........................................................................................... 1
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`COMPLIANCE WITH REQUIREMENTS FOR INTER PARTES
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`I.
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`II.
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`REVIEW .......................................................................................................... 1
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`A.
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`B.
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`Certification the 686 Patent May Be Contested by Petitioners ............. 1
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`Fee for Inter Partes Review (§ 42.15 (a)) .............................................. 2
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`C. Mandatory Notices (§ 42.8(b)) .............................................................. 2
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`III.
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`IDENTIFICATION OF CHALLENGED CLAIMS ....................................... 3
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`IV. RELEVANT INFORMATION CONCERNING THE CONTESTED
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`PATENT .......................................................................................................... 3
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`A.
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`B.
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`C.
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`D.
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`Effective Filing Date ............................................................................. 3
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`Level of Ordinary Skill ......................................................................... 4
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`Overview of 686 Patent ......................................................................... 4
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`Claim Construction................................................................................ 6
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`1.
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`2.
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`3.
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`“cached” ...................................................................................... 6
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`“utilizing download information . . .” ....................................... 10
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`“folder structure”....................................................................... 11
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`V. OVERVIEW OF THE PRIOR ART ............................................................. 12
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`A. McCown (EX1005) ............................................................................. 12
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`B.
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`Dutta (EX1006) ................................................................................... 13
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`Petition for Inter Partes Review of U.S. Patent No. 9,239,686
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`C.
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`Coates (EX1007) ................................................................................. 13
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`VI. PRECISE REASONS FOR REQUESTED RELIEF .................................... 14
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`A.
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`The Challenged Claims Are Unpatentable Over McCown in View of
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`Dutta .................................................................................................... 15
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`Claim 1 ...................................................................................... 15
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`Claim 2 ...................................................................................... 46
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`Claim 3 ...................................................................................... 49
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`Claim 4 ...................................................................................... 50
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`Claim 8 ...................................................................................... 51
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`Claim 9 ...................................................................................... 52
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`Claim 10 .................................................................................... 53
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`Claim 11 .................................................................................... 53
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`B.
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`The Challenged Claims Are Unpatentable Over McCown in View of
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`Dutta, in Further View of Coates ........................................................ 60
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`1.
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`2.
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`3.
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`4.
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`5.
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`Claim 1 ...................................................................................... 60
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`Claims 2-4 and 8-11 .................................................................. 68
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`Claim 5 ...................................................................................... 68
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`Claim 6 ...................................................................................... 69
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`Claim 7 ...................................................................................... 71
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`Petition for Inter Partes Review of U.S. Patent No. 9,239,686
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`6.
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`7.
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`8.
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`9.
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`Claim 12 .................................................................................... 71
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`Claim 13 .................................................................................... 76
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`Claim 14 .................................................................................... 77
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`Claim 15 .................................................................................... 78
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`10. Claim 16 .................................................................................... 79
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`11. Claim 17 .................................................................................... 79
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`12. Claim 18 .................................................................................... 79
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`13. Claim 19 .................................................................................... 79
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`14. Claim 20 .................................................................................... 79
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`VII. CONCLUSION .............................................................................................. 79
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`Petition for Inter Partes Review of U.S. Patent No. 9,239,686
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`I.
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`INTRODUCTION
`U.S. Patent No. 9,239,686 (“the 686 Patent”) claims a system and method
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`for a wireless device to interact with a remote storage server for remote storage of
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`files. McCown, a PCT application published before the priority date of the 686
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`Patent, describes exactly such a system and method. In particular, McCown
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`discloses a user site, which can be, for example, an enhanced cellular telephone,
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`that can manipulate a remote site and a storage site in order to cause a file to be
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`downloaded from the remote site and thereby stored in the storage site.
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`While a Skilled Artisan would understand McCown’s Internet-based system
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`to employ a cache storage, to remove any doubt and to simplify the issues before
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`the Board, this petition is based on the obvious combination of McCown and
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`Dutta, a prior art published patent application directed to the capture and
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`subsequent remote storage of web content using a web cache.
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`Finally, several dependent claims are drawn to certain low-level
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`functionality for manipulating files stored remotely, such as moving, copying or
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`deleting. A prior art patent to Coates discloses exactly that functionality in great
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`detail. As demonstrated, the combination of these prior art references renders
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`claims 1-20 of the 686 Patent unpatentable for obviousness.
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`II. COMPLIANCE WITH REQUIREMENTS FOR INTER PARTES
`REVIEW
`A. Certification the 686 Patent May Be Contested by Petitioners
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`1
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`Petition for Inter Partes Review of U.S. Patent No. 9,239,686
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`Petitioners certify that the 686 Patent for which review is sought is available
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`for inter partes review and Petitioners are not barred or estopped from requesting
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`inter partes review of the 686 Patent (EX1001) on the grounds identified in this
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`Petition. 37 C.F.R. § 42.104 (a). Petitioners also certify this petition for inter
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`partes review is not being filed more than one year from the date of service of a
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`complaint on Petitioners alleging infringement of a patent. Petitioners also certify
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`that they have not filed a civil action challenging the validity of a claim of the 686
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`Patent.
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`B.
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`Fee for Inter Partes Review (§ 42.15 (a))
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`The Director is authorized to charge the fee specified by 37 CFR § 42.15 (a)
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`to Deposit Account No. 50-1597.
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`C. Mandatory Notices (§ 42.8(b))
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`The real parties-in-interest of this petition are Microsoft Corporation
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`(“Microsoft”), located at One Microsoft Way, Redmond, WA 98052, and HP
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`Inc. (“HP”), located at 1501 Page Mill Road, Palo Alto, CA 94304.
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`Lead counsel and backup lead counsel are as follows:
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`Lead Counsel
`Joseph A. Micallef
`Reg. No. 39,772
`jmicallef@sidley.com
`(202) 736-8492
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`Backup Lead Counsel
`Scott M. Border
`Reg. No. 77,744
`sborder@sidley.com
`(202) 736-8818
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`Petition for Inter Partes Review of U.S. Patent No. 9,239,686
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`Service on Petitioners may be made by email (iprnotices@sidley.com), mail
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`or hand delivery to: Sidley Austin LLP, 1501 K Street, N.W., Washington, D.C.
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`20005. The fax number for lead and backup counsel is (202) 736-8711.
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`The 686 Patent is or has been the subject to, or relates to, the following
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`proceedings:
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`• SynKloud Technologies, LLC v. Dropbox Inc., 6-19-cv-00526 (W.D.
`Tex.)
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`• SynKloud Technologies, LLC v. Adobe Inc., 6-19-cv-00527 (W.D.
`Tex.)
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`• Microsoft Corp. v. Synkloud Technologies, LLC, 1-20-cv-00007 (D.
`Del.)
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`III.
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`IDENTIFICATION OF CHALLENGED CLAIMS
`Claims 1-20 of the 686 Patent are unpatentable over the prior art as follows:
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`i. Claims 1-4 and 8-11 are Obvious under §103 Based on McCown in
`View of Dutta;
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`ii. Claims 1-20 are Obvious under §103 Based on McCown in View of
`Dutta, and in Further View of Coates;
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`IV. RELEVANT INFORMATION CONCERNING THE CONTESTED
`PATENT
`Effective Filing Date
`A.
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`3
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`The 686 Patent claims and Petitioners assume a priority date of December 4,
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`2003. EX1001, Face.
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`Level of Ordinary Skill
`B.
`A person of ordinary skill in the art in the field of the 686 Patent in the 2003
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`time frame (“a Skilled Artisan”) would have been someone with a bachelor’s
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`degree in electrical, computer engineering, computer science, or related field with
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`two years of experience in a relevant technical field, such as remote storage
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`systems, with related experience in wireless technologies and wireless devices. As
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`evidenced by the prior art cited below, such a person would have been
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`knowledgeable about memory structures in both mobile and computer
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`technologies, techniques for remotely accessing and manipulating databases and
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`computer files, and communications over computer networks such as the Internet.
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`EX1003,¶47.
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`C. Overview of 686 Patent
`The 686 Patent is entitled “Method and Apparatus for Wireless Devices
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`Access to External Storage,” EX1001, Face, and describes a device interacting
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`with a remote storage server for remote storage of data. Id., Abstract. The primary
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`focuses of the 686 Patent are the transfer of data objects to and from a remote site
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`to an allocated storage space on a remote server under control of a wireless device.
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`Id., 5:16-47.
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`In the system described in the 686 Patent, a user can employ a web browser
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`on a user device to setup folder structures in the file system of an assigned storage
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`space and perform data management operations. Id., 4:45-53. Upon receiving the
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`data management request from the user device, the storage server’s software
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`modules perform the requested operation on the assigned file system of the
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`assigned external storage volume of the server. Id., 4:66-5:3. The 686 patent
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`depicts the steps required to complete the process to download data from a remote
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`web server into allocated storage volume in Figure 3 (below).
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`Id., Fig. 3.
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`D. Claim Construction
`Claims in an inter partes review proceeding are construed according to their
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`ordinary and customary meaning in light of the specification and file history of the
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`patent in which those claims appear.
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`1.
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`“cached”
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`The 686 Patent uses the word “cache,” or conjugations thereof, only once in
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`the specification, in its description of Figure 3. EX1001, 5:29-33. The 686 Patent
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`discloses that the user accesses a web page via a web browser “to obtain
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`information for the downloading.” EX1001, 5:23-25. The downloading
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`information “becomes available in the cached web-pages on the wireless device
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`after the web-browser (8) accessing the web site (15).” EX1001, 5:29-33;
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`EX1003,¶61.
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`Figure 3 shows the data path (a) through which the wireless device accesses
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`the download website through the use of a web browser to obtain the download
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`information as seen below:
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`Id., Fig. 3 (annotated); EX1003,¶62.
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`The 686 Patent further explains that the download information is then sent
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`by other software modules in the system to the storage server to indicate what
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`information should be downloaded and stored. Id., 5:34-43; EX1003,¶63.
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`Dr. Houh explains that this description indicates that the disclosed wireless
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`device accesses the remote server site via a web browser to obtain information for
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`the data to be downloaded. The wireless device then stores this download
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`information into a cache in the form of a web page, and later retrieves it from the
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`cache and sends it to the storage server, in order to indicate what information
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`should be downloaded or stored. From this disclosure, particularly its use of the
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`word “cache,” a Skilled Artisan would understand that the download information
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`is stored on the wireless device in some convenient memory location of that
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`device, so that it can be more readily accessed, without having to make another
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`request to the remote server site for the information, when the user makes a
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`selection of what information should be downloaded and stored. E.g., EX1010,
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`¶¶[0002]-[0003]; EX1003,¶64.
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`That reading is consistent with the understanding of the word “cache” in this
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`technological field. For example, when used as a noun the word “cache” is
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`generally understood to mean “[a] special memory subsystem in which frequently
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`used data values are duplicated for quick access,” EX1030, 72, and it is also used
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`as a verb to mean “storing data close to the user or user application so that it can be
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`more readily and speedily accessed than the original storage location.” EX1008,
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`114; EX1003,¶65.
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`The claims of the 686 Patent recite “transmitting the cached downloading
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`information,” and “cached in the first wireless device” (i.e., they use the word
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`“cached” as an adjective modifying the noun “downloading information” or as a
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`verb modifying “in the first wireless device.” Dr. Houh explains such a claim term
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`should be interpreted consistent with its grammatical usage, i.e., to mean a type of
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`“downloading” modified by the adjective “cached” or the process of storing data in
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`such a storage. EX1003,¶66.
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`Accordingly, the ordinary meaning in the context of the 686 Patent of
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`“cached” is stored in storage that is more readily accessible by the user or user
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`application than the original storage location. EX1003,¶67.
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`“utilizing download information . . .”
`2.
`In context, this claim language relates to a storage operation that causes a
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`
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`file from a remote server to be stored into an assigned storage space.
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`Id., 6:31-38; EX1003,¶69.
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`Dr. Houh notes that, viewed in isolation, however, this phrase is ambiguous
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`as to what information is “cached in the wireless device,” i.e., the “download
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`information” or the “file”? EX1003,¶70.
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`The specification of the 686 Patent explains that the file being downloaded
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`is never sent to the wireless device, but is instead transferred directly from the
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`remote site to the assigned storage location. Id., 5:38-43. Moreover, it is the
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`download information that gets stored in the cache of the wireless device.
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`EX1001, 5:29-33; EX1003,¶71.
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`Claims 1 and 13 disclose that the process occurs “through utilizing
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`download information for the file cached in the first wireless device.” EX1001,
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`6:35-37, 8:5-10. Claim 2 discloses “the first wireless device…transmitting the
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`cached downloading information to the server.” EX1001, 6:42-43. Thus, “the first
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`wireless device” must be correlated with the first storage space. EX1003,¶72.
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`The ordinary meaning in the context of the 686 Patent of “utilizing
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`download information for the file cached in the first wireless device” is broad
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`enough to cover using information stored in the cache storage of the first wireless
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`device to download a file from a remote server. EX1003,¶73.
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`“folder structure”
`3.
`The 686 Patent explains that “the user on the web-browser (8) is facilitated
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`to perform creating structured layered file directories or folders.” Id., 3:22-23;
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`EX1003,¶75.
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`A “folder” is “a means of organizing programs and documents on a disk and
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`can hold both files and additional folders.” EX1030, 202-203; EX1003,¶76.
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`“Structure” is defined as “the arrangement or organization of parts in a
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`system.” See, e.g., EX1023, 2; EX1003,77.
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`In this instance, the term “folder” modifies the term “structure.” Thus, when
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`combined, a “folder structure” is a structure of folders. That correlates to the
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`description in the 686 Patent at EX1001, 3:22-23. EX1003,¶78.
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`Accordingly, when read in the context of the 686 Patent specification and
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`the understood meanings, the ordinary meaning of a “folder structure” is an
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`arrangement of folders and subfolders for holding files. EX1003,¶79.
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`V. OVERVIEW OF THE PRIOR ART
`A. McCown (EX1005)
`International Publication No. WO 01/67233 to McCown was published on
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`September 13, 2001, from a PCT Application filed on March 3, 2000. EX1005,
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`Face. McCown is prior art to the 686 Patent under at least §§102(a), (b) and (e).
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`McCown describes a system in which ‘[s]elected files are downloaded
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`across a network from a remote site into a client’s storage space account
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`established within a storage site.” EX1005, Face. McCown explains that as part of
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`the remote storage process, a client, operating from a user site (e.g., a wireless
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`device) on a network, selects files for downloading through use of an input device.
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`EX1005, 11:4-11. The user site generates a data request that is “sent across the
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`Internet” and received by the storage site’s software application which, in turn,
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`generates a download request based on user selections. EX1005, 11:20-22, 12:24-
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`25. The download request is sent to the remote site’s server. EX1005, 12:25-27.
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`The remote site’s server receives the download request and responds by
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`downloading the files to the storage site and storing them into the client’s storage
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`space account. EX1005, 12:27-13:2.
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`B. Dutta (EX1006)
`U.S. Publication No. 2002/0078102 to Dutta (“Dutta”) was filed on
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`December 18, 2000 and was published on June 20, 2002. EX1006, Face. Dutta is
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`prior art to the 686 Patent under at least §§102(a), (b) and (e).
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`Dutta primarily describes the capture and subsequent storage of web content.
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`EX1006, Abstract. The client receives a file, generally in a Web page, in response
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`to a request by the user to browse the web page. EX1006, ¶[0010]. The captured
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`data of the displayed web page and user parameters are sent to the server from the
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`client which stores the captured data. EX1006, ¶¶[0010]-[0011].
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`The client maintains local storage for use by the browser application and
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`other applications. EX1006, ¶[0029]. The browser may store bookmarked files,
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`browser cache, and various other types of files. EX1006, ¶[0029].
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`C.
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`Coates (EX1007)
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`Petition for Inter Partes Review of U.S. Patent No. 9,239,686
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`US Patent No. 7,266,555 to Coates was filed on December 8, 2000 and
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`published on September 4, 2007. EX1007, Face. Coates is prior art to the 686
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`Patent under at least §102(e).
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`Coates discloses a storage port that interfaces a client computer, such as a
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`web or application server, to a network storage system. EX1007, 3:7-8. The
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`network storage system stores files at one or more storage centers, remote from the
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`client site. EX1007, 3:8-10. To gain access to content stored at the remote storage
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`center, the client computer mounts the storage port as a storage device for the
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`client computer. EX1007, 3:10-13. The client computer issues local file system
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`requests to conduct network storage system operations. EX1007, 3:13-14. In
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`response, the storage port translates local file system requests to network storage
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`system requests. EX1007, 3:14-16.
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`VI. PRECISE REASONS FOR REQUESTED RELIEF
`Petitioners demonstrate below that the challenged claims are obvious in
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`view of McCown in view of Dutta for claims 1-4 and 8-11 and McCown in view of
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`Dutta in further view of Coates for claims 1-20. In order to improve the clarity of
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`the analysis, the obviousness grounds set out below incorporate and build upon the
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`basic comparison of the challenged claims to McCown or McCown in view of
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`Dutta.
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`Petition for Inter Partes Review of U.S. Patent No. 9,239,686
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`A.
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`The Challenged Claims Are Unpatentable Over McCown in
`View of Dutta
`1.
`Claim 1
`a.
`Preamble
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`The preamble of claim 1 recites “[a] server for delivering storage service,
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`comprising:”
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`McCown discloses network-based storage spaces having client accounts and
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`methods for downloading client-selected files from remote sites into client
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`accounts. EX1005, 1:3-5. A web server operates in the storage space to provide
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`web pages, directories, and other information to aid the client. EX1005, 9:9-11.
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`The storage site’s web server is also capable of communicating with, and
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`downloading files to and from other internet sites. EX1005, 9:11-13;
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`EX1003,¶105.
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`Therefore, McCown satisfies the claim element. EX1003,¶106.
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`b.
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`Plurality of Storage Spaces
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`Claim 1 further recites “[a] server for delivering storage service,
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`comprising: a plurality of storage spaces”
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`McCown discloses that storage space “accounts” (“a plurality of storage
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`spaces”) are implemented on a storage medium. EX1005, 8:17-18. McCown
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`further discloses that the storage medium “usually comprises magnetic hard drives
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`but may also include other types such as “optical disks, and solid state memory
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`devices.” EX1005, 8:20-21. McCown therefore discloses embodiments in which
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`multiple storage devices are employed (e.g., “hard drives”), and therefore
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`discloses “a plurality of storage spaces.” EX1005, 8:19-20 (emphasis added);
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`EX1003,¶108.
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`McCown satisfies the claim element. EX1003,¶109
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`c.
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`Non-transitory Computer Readable Medium
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`Claim 1 also recites “one non-transitory computer-readable medium
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`comprising program instructions which, being executed by the wireless device,
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`cause the wireless device remotely access to the storage space. . .”
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`McCown discloses a “storage site software application and a user site
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`software application that may be provided to the storage site and the user site
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`respectively as computer programs recorded on information storage media.”
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`EX1005, 9:23-26. McCown gives examples of “information storage media” as
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`“magnetic disk, magnetic tape, optical disk, non-volatile memory, or other similar
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`information storage media.” EX1005, 9:26-30; EX1003,¶111.
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`Dr. Houh explains that “computer programs recorded on information storage
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`media” at the user site and storage site to encompass “one non-transitory
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`computer-readable medium” at the user site and storage site, respectively.
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`EX1003,¶112 (citing EX1030, 450; EX1009, 8:5-6).
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`Thus, McCown satisfies “[a] server for delivering storage
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`space…comprising…one non-transitory computer-readable medium” elements of
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`the claim. EX1003,¶113.
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`Program Instructions
`(i)
`McCown discloses a preferred embodiment in which “a pair of software
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`application packages are provided to make the storage space account appear as a
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`mounted drive to the user site and client.” EX1005, 9:14-16. A storage site
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`software application is hosted in the storage site and a user site software
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`application is hosted in each user site. EX1005, 9:16-17. McCown discloses the
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`use of “information storage media recording computer programs” employed at the
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`storage site (“a server for delivering storage space”). EX1005, 9:26-27. The
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`computer programs (“program instructions”) are read from the information storage
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`media (“non-transitory computer-readable medium”) and executed by the storage
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`site and the user site. EX1005, 9:28-30. As Dr. Houh explains, those computer
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`programs would implement the remote access techniques described in McCown.
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`EX1003,¶114 (citing EX1005, 5:1-6; EX1030, 450).
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`To the extent one might argue that the remote storage operations disclosed in
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`McCown and relied on here to satisfy the claims are not sufficiently described in
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`McCown as being implemented using “program instructions,” it would have been
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`obvious to implement such operations, including those analyzed below, by
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`including instructions that control such operations in the McCown user site and
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`storage site program instructions. McCown discloses that his system includes
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`software programs (“program instructions”) for providing at least some of the
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`operations described in McCown. EX1005, 9:14-30. A Skilled Artisan would
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`have been motivated from that disclosure to implement the other operations
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`described in McCown, or at least as much of it as possible, using such program
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`instructions because the processing and storage requirements for such instructions
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`already existed in the system and because it was known at the time that controlling
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`functionality through software was an efficient, inexpensive and readily
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`implementable solution. See EX1026, 1:40-46. Indeed, it would have been
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`common sense to implement McCown’s remote storage operations using program
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`instructions in view of such an efficient, inexpensive and readily implementable
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`solution, particularly in view of McCown’s disclosure of the user site and storage
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`site application programs, which already implements at least some of those
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`operations. EX1003,¶115.
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`Therefore, McCown satisfies the claim element.
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`(ii) Cause the Server Delivering the Storage Space
`Claim 1 further recites “a server for delivering storage space
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`comprising…program instructions that, being executed by the server, causes the
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`server delivering the storage service…”
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`
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`McCown discloses that an account manager is provided in the storage site to
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`manage access to the storage space accounts (“causes the server delivering the
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`storage service”). EX1005, 8:28-29. The account manager protects the storage
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`space accounts by implementing password protection. EX1005, 8:30-9:6;
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`EX1003,¶117.
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`The storage site software application (“program instructions”)
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`communicates with the account manager to send and receive files from the client’s
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`storage space account (“which, being executed by the server, causes the server
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`delivering the storage service”). EX1005, 10:2-4. Where the user passes
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`authentication, the URLs within the data request are used to generate a download
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`request which is then provided to the storage site’s web server. EX1005, 12:23-26.
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`The web server sends the data request to the remote site, continuing the download
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`process. EX1005, 12:26-27; EX1003,¶118.
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`If the user fails authentication, then an error message is generated by the
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`account manager and sent back to the user site “via the web browser 148 or the
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`storage site software application 150.” EX1005, 12:14-16 (emphasis added);
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`EX1003,¶119.
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`Therefore, McCown satisfies the claim element. EX1003,¶120.
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`d.
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`Program Instructions
`
`As demonstrated above, McCown discloses or renders obvious “program
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`instructions” employed at the storage site (“a server for delivering storage
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`service”) to implement McCown’s remote storage techniques. See §VI.A.1.c(i),
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`above. EX1003,¶¶121-123.
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`(i) Allocate Exclusively
`Claim 1 recites that the program instructions of the server comprise
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`“program instructions for allocating exclusively a first one of the storage spaces to
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`a user of a first wireless device.”
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`McCown discloses the use of “storage space accounts” provided by the
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`storage space (“allocating exclusively a first one of the storage spaces”) to
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`individual users (“to a user of a first wireless device”) and implemented on a
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`storage medium with an account manager at the storage site to manage access to
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`the storage space accounts. EX1005, 8:15-18, 27-28. “The client 120 [“user of a
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`first wireless device”] may access his storage space account 120 from multiple
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`other user site connected to the Internet.” EX1005, 8:15-16. The storage space
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`accounts are implemented on a storage medium. EX1005, 8:14-24. The account
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`manager serves to protect the storage space accounts, requiring clients to provide a
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`user identification and password in order to log into their respective accounts.
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`EX1005, 8:27-9:2. The account manager authenticates the user identification and
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`password against registered user identifications and their respective passwords.
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`EX1005, 9:2-4. If successful, the account manager unlocks the client’s storage
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`space account. EX1005, 9:4-5. After the client logs out, the account manager locks
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`the client’s storage space account. EX1005, 9:5-6; EX1003,¶125.
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`
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`McCown also details a browser at the user site through which the client
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`transfers login data between the user site and a web server. EX1005, 9:7-9. The
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`user site software application may be implemented as part of a browser and
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`communicates with the storage site software application via the Internet. EX1005,
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`9:22-23, 10:1-2. The storage site software application can send information about
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`the storage space account to the user site software application. EX1005, 15:29-
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`16:1. The user site software application uses the storage site’s information to
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`emulate a mounted disk containing the files stored in the storage space. EX1005,
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`16:2-4; EX1003,¶126.
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`The disclosure of the storage space provisioned into accounts assigned to
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`respective users would be understood by a Skilled Artisan to include the
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`partitioning of storage volumes and allocation of said partitioned memory to
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`specific users. E.g., EX1031,¶[0010]. The disclosure that the user must enter
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`preexisting authentication information that the details of the account, including the
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`details of the user’s ability to store information in the system, demonstrated the
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`accounts, and therefore their capacities, were already partitioned and allocated.
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`EX1003,¶127.
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`
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`Dr. Houh explains that the account manager in the storage site would be
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`managed by an administrator in a remote site for account and security
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`maintenance, i.e. account accessibility. E.g., EX1021, ¶[0409]. Indeed, the
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`disclosure that the user must enter preexisting authentication information that the
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`details of the account, including the details of the user’s ability to store information
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`in the system, demonstrated the accounts, and therefore their capacities, were
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`already partitioned. EX1003,¶128.
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`Therefore, McCown satisfies the claim. EX1003,¶129.
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`
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`To the extent one might argue that the disclosures noted above do not or
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`sufficiently disclose the claim element, it would have been obvious to modify the
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`system of McCown to include that functionality. Memory partitioning and
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`Petition for Inter Partes Review of U.S.
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