EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Microsoft contends that the asserted claims of the ’132 Patent are invalid as anticipated or obvious by “Tivoli Storage Manager: A
`Technical Introduction” (“Tivoli”) prior art reference under various subsections of 35 U.S.C. § 102 and in view of other prior art
`references under 35 U.S.C. § 103 as set forth in Microsoft’s invalidity contentions.
`
`As Tivoli was published or made publicly available by at least June 2001, Microsoft contends that it is prior art to the ’132 Patent
`under at least pre-AIA 35 U.S.C. § 102(b).
`
`Patent No. 8,671,132
`Claim 1
`1[Pre] A policy-based
`data management system
`comprising:
`
`Tivoli
`
`To the extent the preamble is limiting, Tivoli discloses a policy-based data management system.
`Specifically, Tivoli discloses a file management and storage system implementing storage policies.
`For example, Tivoli states:
`
`“Tivoli Storage Manager is the core product of the Tivoli Storage Management product set. It provides
`a solution for distributed data and storage management in an enterprise network environment. It is the
`next generation of the product originally released by IBM as ADSTAR Distributed Storage Manager
`(ADSM). Tivoli Storage Manager protects and manages data on more than 30 operating platforms,
`covering mobile, desktop and server systems over the entire distributed world. It is integrated with
`hundreds of storage devices as well as LAN, WAN and emerging SAN infrastructures.” Tivoli at 7.
`
`“The Tivoli Storage Manager server software builds the data management backbone by managing the
`storage hardware, providing a secure environment, providing automation, reporting and monitoring
`functions, and implementing the storage management policies and by storing all object inventory
`information in the Tivoli Storage Manager database. The Tivoli Storage Manager client software,
`Tivoli Storage Manager storage agent software, and complementary products implement data
`management functions like data backup and recovery, archival, hierarchical space management, or
`disaster recovery.” Tivoli at 8.
`
`“One of the principal architectural components of the Tivoli Storage Manager server software is its in-
`built relational database. The storage manager database was especially designed for the task of
`managing data, and it implements zero-touch administration. All policy information, logging,
`authentication and security, media management and object inventory is managed through this database.
`Most of the fields are externalized through Tivoli Storage Manager high level administration
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 1
`
`commands, SQL SELECT statements or for reporting purposes, by using an ODBC driver.” Tivoli at
`8-9.
`“A data storage management environment consists of three basic types of resources: client systems,
`rules, and data. The client systems contain the data to be managed, and the rules specify how the
`management must occur; for example, in the case of backup, how many versions should be kept, where
`they should be stored, and so on.
`
`Tivoli Storage Manager policies define the relationships between these three resources. Figure 8
`illustrates this policy relationship. Depending on your actual needs for managing your enterprise data,
`these policies can be very simple or very complex.” Tivoli at 20.
`
`To the extent that it is argued that Tivoli does not disclose all or part of this limitation, it would have
`been at least obvious to combine it with any other reference disclosing this limitation as explained in
`Microsoft’s Preliminary Invalidity Contention Cover Pleading.
`Tivoli discloses a policy set comprising at least one service class rule. Specifically, Tivoli discloses a
`policy set executed by the ACS routines to select management classes for files. For example, Tivoli
`states:
`
`“2.2.3 Policy Concepts
`
`“A data storage management environment consists of three basic types of resources: client systems,
`rules, and data. The client systems contain the data to be managed, and the rules specify how the
`management must occur; for example, in the case of backup, how many versions should be kept, where
`they should be stored, and so on.
`
`Tivoli Storage Manager policies define the relationships between these three resources. Figure 8
`illustrates this policy relationship. Depending on your actual needs for managing your enterprise data,
`these policies can be very simple or very complex.
`
`
`1[a] a policy set
`comprising at least one
`service class rule;
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 1
`
`
`
`Tivoli Storage Manager has certain logical entities that group and organize the storage resources and
`define relationships between them. Client systems, or nodes in Tivoli Storage Manager terminology,
`are grouped together with other nodes with common storage management requirements, into a policy
`domain.
`
`The policy domain links the nodes to a policy set, a collection of storage management rules for
`different storage management activities. A policy set consists of one or more management classes. A
`management class contains the rule descriptions called copy groups, and links these to the data objects
`to be managed. A copy group is the place where all the storage management parameters, such as
`number of stored copies, retention period, storage media, and so on, are defined. When the data is
`linked to particular rules, it is said to be bound to the management class that contains those rules.
`
`
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 1
`
`Another way to look at the components that make up a policy is to consider them in the hierarchical
`fashion in which they are defined. That is to say, consider the policy domain containing the policy set,
`the policy set containing the management classes, and the management classes containing the copy
`groups and the storage management parameters.” Tivoli at 20.
`
`To the extent that it is argued that Tivoli does not disclose all or part of this limitation, it would have
`been at least obvious to combine it with any other reference disclosing this limitation as explained in
`Microsoft’s Preliminary Invalidity Contention Cover Pleading.
`Tivoli discloses a file evaluation module configured to apply the service class rule to assign a service
`class to a file. Specifically, Tivoli discloses software programs to apply rules to assign a management
`class to a file. For example, Tivoli states:
`
`“2.2.3 Policy Concepts
`
`“A data storage management environment consists of three basic types of resources: client systems,
`rules, and data. The client systems contain the data to be managed, and the rules specify how the
`management must occur; for example, in the case of backup, how many versions should be kept, where
`they should be stored, and so on.
`
`Tivoli Storage Manager policies define the relationships between these three resources. Figure 8
`illustrates this policy relationship. Depending on your actual needs for managing your enterprise data,
`these policies can be very simple or very complex.
`
`
`1[b] a file evaluation
`module configured to
`apply the service class rule
`to assign a service class to
`a file;
`
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 1
`
`
`
`Tivoli Storage Manager has certain logical entities that group and organize the storage resources and
`define relationships between them. Client systems, or nodes in Tivoli Storage Manager terminology,
`are grouped together with other nodes with common storage management requirements, into a policy
`domain.
`
`The policy domain links the nodes to a policy set, a collection of storage management rules for
`different storage management activities. A policy set consists of one or more management classes. A
`management class contains the rule descriptions called copy groups, and links these to the data objects
`to be managed. A copy group is the place where all the storage management parameters, such as
`number of stored copies, retention period, storage media, and so on, are defined. When the data is
`linked to particular rules, it is said to be bound to the management class that contains those rules.
`
`
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 1
`
`Another way to look at the components that make up a policy is to consider them in the hierarchical
`fashion in which they are defined. That is to say, consider the policy domain containing the policy set,
`the policy set containing the management classes, and the management classes containing the copy
`groups and the storage management parameters.” Tivoli at 20.
`
`To the extent that it is argued that Tivoli does not disclose all or part of this limitation, it would have
`been at least obvious to combine it with any other reference disclosing this limitation as explained in
`Microsoft’s Preliminary Invalidity Contention Cover Pleading.
`Tivoli discloses a file usage module configured to conduct operations on the file in a manner directed
`by the service class. Specifically, Tivoli discloses that the Tivoli Storage Manager uses management
`classes to manage files, such as allocating the file to a storage location or performs migration, backup,
`and retention. For example, Tivoli states:
`
`“2.2.3 Policy Concepts
`
`“A data storage management environment consists of three basic types of resources: client systems,
`rules, and data. The client systems contain the data to be managed, and the rules specify how the
`management must occur; for example, in the case of backup, how many versions should be kept, where
`they should be stored, and so on.
`
`Tivoli Storage Manager policies define the relationships between these three resources. Figure 8
`illustrates this policy relationship. Depending on your actual needs for managing your enterprise data,
`these policies can be very simple or very complex.
`
`
`1[c] a file usage module
`configured to conduct
`operations on the file in a
`manner directed by the
`service class; and
`
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 1
`
`
`
`Tivoli Storage Manager has certain logical entities that group and organize the storage resources and
`define relationships between them. Client systems, or nodes in Tivoli Storage Manager terminology,
`are grouped together with other nodes with common storage management requirements, into a policy
`domain.
`
`The policy domain links the nodes to a policy set, a collection of storage management rules for
`different storage management activities. A policy set consists of one or more management classes. A
`management class contains the rule descriptions called copy groups, and links these to the data objects
`to be managed. A copy group is the place where all the storage management parameters, such as
`number of stored copies, retention period, storage media, and so on, are defined. When the data is
`linked to particular rules, it is said to be bound to the management class that contains those rules.
`
`
`
`
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`1[d] a communication
`module operable to
`communicate between the
`file evaluation module and
`a plurality of remote
`clients and configured to
`communicate with clients
`comprising at least two
`different computing
`platforms.
`
`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 1
`
`Another way to look at the components that make up a policy is to consider them in the hierarchical
`fashion in which they are defined. That is to say, consider the policy domain containing the policy set,
`the policy set containing the management classes, and the management classes containing the copy
`groups and the storage management parameters.” Tivoli at 20.
`
`To the extent that it is argued that Tivoli does not disclose all or part of this limitation, it would have
`been at least obvious to combine it with any other reference disclosing this limitation as explained in
`Microsoft’s Preliminary Invalidity Contention Cover Pleading.
`Tivoli discloses a communication module operable to communicate between the file evaluation
`module and a plurality of remote clients. Specifically, Tivoli discloses software programs such as the
`Tivoli Storage Manager backup/archive client, communicating with end users on different operating
`systems via a graphical user interface. For example, Tivoli states:
`
`“Data management functions are implemented using Tivoli Storage Manager client software and
`complementary Tivoli and non-Tivoli products, which work together with the Tivoli Storage Manager
`server backbone product.
`
`The Tivoli Storage Manager backup/archive client, included with the server program, provides the
`operational backup and archival function. The software implements the patented progressive backup
`methodology, adaptive sub-file backup technology and unique record retention methods as described
`in 2.2.1, “Backup, and archival concepts” on page 16.
`
`All version 3.7 and above backup/archive clients are implemented as multi-session clients, which
`means that they are able to exploit the multi-threading capabilities of modern operating systems. This
`enables the running of backup and archive operations in parallel to maximize the throughput to the
`server system. Full exploitation of multi-threading on the client also requires a 3.7 or higher Tivoli
`Storage Manager server.
`
`Depending on the client platform the backup/archive client may provide a graphical, command line or
`Web user interface (see Figure 3).” Tivoli at 10.
`
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 1
`
`
`Tivoli at 11 (Fig. 3):
`
`
`
`9
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 1
`
`“Tivoli Storage Manager server and client software is available on many different operating system
`platforms and can exploit different communication protocols. Figure 7 gives an overview of the
`supported environment.” Tivoli at 14.
`
`Tivoli at 14 (Fig. 5)
`
`
`
`Tivoli at 15-16:
`
`
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 1
`
`
`
`
`
`“Whenever a client (backup/archive or administrative) wants to communicate with the server, an
`authentication has to take place. This authentication contains both-sides verification, which means that
`the client has to authenticate itself to the server, and the server has to authenticate itself to the client.
`
`To do this, all clients have a password, which is stored at the server side as well as at the client side. In
`
`
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 1
`
`the authentication dialog these passwords are used to encrypt the communication. The passwords are
`not sent over the network, to prevent hackers from intercepting them. A communication session will be
`established only if both sides are able to decrypt the dialog. If the communication has ended, or if a
`timeout period without activity is passed, the session will be automatically terminated and a new
`authentication will be necessary.
`
`In mobile computing environments, files are often sent to the Tivoli Storage Manager server system
`using a modem connection, and so they are exposed to the security hazards of public telephone lines.
`The Tivoli Storage Manager backup/archive client implements (in addition to the end-point security
`concept outlined above) a data encryption function, which allows for encrypting data before it is sent
`to the Tivoli Storage Manager server, and which protects the data while it is being transferred to the
`server and also while it resides in the storage repository.” Tivoli at 21.
`
`To the extent that it is argued that Tivoli does not disclose all or part of this limitation, it would have
`been at least obvious to combine it with any other reference disclosing this limitation as explained in
`Microsoft’s Preliminary Invalidity Contention Cover Pleading.
`
`Patent No. 8,671,132
`Claim 2
`The policy-based data
`management system of
`claim 1, wherein the file
`evaluation module is
`further configured to
`automatically assign the
`file to a storage pool.
`
`Tivoli
`
`Tivoli discloses that the file evaluation module is further configured to automatically assign the file to
`a storage pool. For example, Tivoli states:
`
`“All Tivoli Storage Manager-managed client data are stored in the Tivoli Storage Manager storage
`repository, which can consist of different storage devices, such as disk, tape, or optical devices, and
`controlled by the Tivoli Storage Manager server. To do this, Tivoli Storage Manager uses its own
`model of storage to view, classify, and control these storage devices, and to implement its storage
`management functionality (see Figure 7).
`
`12
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 2
`
`
`
`The main difference between the storage management approach of Tivoli Storage Manager and other
`commonly used systems is that Tivoli Storage Manager storage management concentrates on
`managing data objects instead of managing and controlling backup tapes. Data objects can be sub-file
`components, files, directories or raw logical volumes that are backed up from the client systems; they
`can be objects like tables or records from database applications, or simply a block of data that a client
`system wants to store on the server storage.
`
`
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 2
`
`To store these data objects on storage devices and to implement storage management functions, Tivoli
`Storage Manager has defined some logical entities to classify the available storage resources. Most
`important is the logical entity called a storage pool. A storage pool describes a storage resource for one
`single type of media; for example, a disk partition or a set of tape cartridges. Storage pools are the
`place where data objects are stored.
`
` A
`
` storage pool is built up from one or more storage pool volumes. For example, in the case of a tape
`storage pool, this would be a single physical tape cartridge. To describe how Tivoli Storage Manager
`can access those physical volumes to place the data objects on them, Tivoli Storage Manager has
`another logical entity called a device class. A device class is connected to a storage pool and specifies
`how volumes of this storage pool can be accessed.
`
`Tivoli Storage Manager organizes storage pools in one or more hierarchical structures. This storage
`hierarchy can span over multiple server instances and is used to implement management functions to
`migrate data objects automatically—completely transparent to the client—from one storage hierarchy
`level to another; or in other words, from one storage device to another. This function may be used, for
`example, to cache backup data (for performance reasons) onto a Tivoli Storage Manager server disk
`space before moving the data to tape cartridges. The actual location of all data objects is automatically
`tracked within the server database.
`
`Tivoli Storage Manager has implemented additional storage management functions for moving data
`objects from one storage volume to another. As discussed in the previous section, Tivoli Storage
`Manager uses the progressive backup methodology to backup files to the Tivoli Storage Manager
`storage repository. The reorganization of the data and storage media for fast recovery happens
`completely within the server. For this purpose, Tivoli Storage Manager has implemented functions to
`relocate data objects from one volume to another and to collocate data objects that belong together,
`either at the client system level or at the data group level.” Tivoli at 18-19.
`
`14
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 3
`
`The policy-based data
`Tivoli discloses that the file evaluation module is configured to assign the storage pool to the file based
`management system of
`on the service class. Specifically, Tivoli discloses software program that is configured to assign the
`claim 1, wherein the file
`storage group based on management classes. For example, Tivoli states:
`evaluation module is
`
`configured to assign the
`“2.2.3 Policy Concepts
`storage pool to the file
`
`based on the service class.
`“A data storage management environment consists of three basic types of resources: client systems,
`rules, and data. The client systems contain the data to be managed, and the rules specify how the
`management must occur; for example, in the case of backup, how many versions should be kept, where
`they should be stored, and so on.
`
`Tivoli Storage Manager policies define the relationships between these three resources. Figure 8
`illustrates this policy relationship. Depending on your actual needs for managing your enterprise data,
`these policies can be very simple or very complex.
`
`
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 3
`
`
`
`Tivoli Storage Manager has certain logical entities that group and organize the storage resources and
`define relationships between them. Client systems, or nodes in Tivoli Storage Manager terminology,
`are grouped together with other nodes with common storage management requirements, into a policy
`domain.” Tivoli at 20.
`
`To the extent that it is argued that Tivoli does not disclose this limitation, this would have at least been
`inherent because Tivoli discloses rules that assign management classes also determines where the data
`will be stored. Furthermore, to the extent that it is argued that Tivoli does not disclose all or part of
`this limitation, it would have been at least obvious to combine it with any other reference disclosing
`this limitation as explained in Microsoft’s Preliminary Invalidity Contention Cover Pleading.
`
`16
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 4
`
`4[Pre] The policy-based
`Tivoli discloses that the policy set further comprises at least one storage pool rule. Specifically, Tivoli
`data management system
`discloses rules to assign a storage pool to certain data based on the classification of storage resources.
`of claim 2, wherein the
`For example, Tivoli states:
`policy set further
`
`comprises at least one
`“All Tivoli Storage Manager-managed client data are stored in the Tivoli Storage Manager storage
`storage pool rule,
`repository, which can consist of different storage devices, such as disk, tape, or optical devices, and
`controlled by the Tivoli Storage Manager server. To do this, Tivoli Storage Manager uses its own
`model of storage to view, classify, and control these storage devices, and to implement its storage
`management functionality (see Figure 7).
`
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 4
`
`
`
`The main difference between the storage management approach of Tivoli Storage Manager and other
`commonly used systems is that Tivoli Storage Manager storage management concentrates on
`managing data objects instead of managing and controlling backup tapes. Data objects can be sub-file
`components, files, directories or raw logical volumes that are backed up from the client systems; they
`can be objects like tables or records from database applications, or simply a block of data that a client
`system wants to store on the server storage.
`
`
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 4
`
`To store these data objects on storage devices and to implement storage management functions, Tivoli
`Storage Manager has defined some logical entities to classify the available storage resources. Most
`important is the logical entity called a storage pool. A storage pool describes a storage resource for one
`single type of media; for example, a disk partition or a set of tape cartridges. Storage pools are the
`place where data objects are stored.
`
` A
`
` storage pool is built up from one or more storage pool volumes. For example, in the case of a tape
`storage pool, this would be a single physical tape cartridge. To describe how Tivoli Storage Manager
`can access those physical volumes to place the data objects on them, Tivoli Storage Manager has
`another logical entity called a device class. A device class is connected to a storage pool and specifies
`how volumes of this storage pool can be accessed.
`
`Tivoli Storage Manager organizes storage pools in one or more hierarchical structures. This storage
`hierarchy can span over multiple server instances and is used to implement management functions to
`migrate data objects automatically—completely transparent to the client—from one storage hierarchy
`level to another; or in other words, from one storage device to another. This function may be used, for
`example, to cache backup data (for performance reasons) onto a Tivoli Storage Manager server disk
`space before moving the data to tape cartridges. The actual location of all data objects is automatically
`tracked within the server database.
`
`Tivoli Storage Manager has implemented additional storage management functions for moving data
`objects from one storage volume to another. As discussed in the previous section, Tivoli Storage
`Manager uses the progressive backup methodology to backup files to the Tivoli Storage Manager
`storage repository. The reorganization of the data and storage media for fast recovery happens
`completely within the server. For this purpose, Tivoli Storage Manager has implemented functions to
`relocate data objects from one volume to another and to collocate data objects that belong together,
`either at the client system level or at the data group level.” Tivoli at 18-19.
`
`To the extent that it is argued that Tivoli does not disclose this limitation, this would have at least been
`inherent because Tivoli discloses automatically assigning a storage pool to data and automatically
`relocating data to another storage pool based on certain criteria. Furthermore, to the extent that it is
`
`
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`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 4
`
`argued that Tivoli does not disclose all or part of this limitation, it would have been at least obvious to
`combine it with any other reference disclosing this limitation as explained in Microsoft’s Preliminary
`Invalidity Contention Cover Pleading.
`Tivoli discloses that the file evaluation module further configured to automatically apply the storage
`pool rule to assign the storage pool to the file. For example, Tivoli states:
`
`“All Tivoli Storage Manager-managed client data are stored in the Tivoli Storage Manager storage
`repository, which can consist of different storage devices, such as disk, tape, or optical devices, and
`controlled by the Tivoli Storage Manager server. To do this, Tivoli Storage Manager uses its own
`model of storage to view, classify, and control these storage devices, and to implement its storage
`management functionality (see Figure 7).
`
`4[a] the file evaluation
`module further configured
`to automatically apply the
`storage pool rule to assign
`the storage pool to the file.
`
`
`
`20
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`IPR2021-00831
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`Daedalus EX2009
`Page 20 of 49
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`

`

`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 4
`
`
`
`The main difference between the storage management approach of Tivoli Storage Manager and other
`commonly used systems is that Tivoli Storage Manager storage management concentrates on
`managing data objects instead of managing and controlling backup tapes. Data objects can be sub-file
`components, files, directories or raw logical volumes that are backed up from the client systems; they
`can be objects like tables or records from database applications, or simply a block of data that a client
`system wants to store on the server storage.
`
`
`
`
`21
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`IPR2021-00831
`
`Daedalus EX2009
`Page 21 of 49
`
`

`

`EXHIBIT C-6
`IBM Tivoli Series, “Tivoli Storage Manager: A Technical Introduction” (“Tivoli”)
`Patent No. 8,671,132
`Tivoli
`Claim 4
`
`To store these data objects on storage devices and to implement storage management functions, Tivoli
`Storage Manager has defined some logical entities to classify the available storage resources. Most
`important is the logical entity called a storage pool. A storage pool describes a storage resource for one
`single type of media; for example, a disk partition or a set of tape cartridges. Storage pools are the
`place where data objects are stored.
`
` A
`
` storage pool is built up from one or more storage pool volumes. For example, in the case of a tape
`storage pool, this would be a single physical tape cartridge. To describe how Tivoli Storage Manager
`can access those physical volumes to place the data objects on them, Tivoli Storage Manager has
`another logical entity called a device class. A device class is connected to a storage pool and specifies
`how volumes of this storage pool can be accessed.
`
`Tivoli Storage Manager organizes storage pools in one or more hierarchical structures. This storage
`hierarchy can span over multiple server instances and is used to implement management functions to
`migrate data objects automatically—completely transparent to the client—from one storage hierarchy
`level to another; or in other words, from one storage device to another. This function may be used, for
`example, to cache backup data (for performance reasons) onto a Tivoli Storage Manager server disk
`space before moving the data to tape cartridges. The actual location of all data objects is automatically
`tracked within the server database.
`
`Tivoli Storage Manager has implemented additional storage management functions for moving data
`objects from one storage volume to another. As discussed in the previous section, Tivoli Storage
`Manager uses the progressive backup methodology to backup files to the Tivoli Storage Manager
`storage repository. The reorganization of the data and storage media for fast recovery happens
`completely within the server. For this purpose, Tivoli Storage Manager has implemented functions to
`relocate data objects from one volume to another and to collocate data objects that belong together,
`either at the client system level or at the data group level.” Tivoli at 18-19.
`
`To the extent that it is argued that Tivoli does not disclose this limitation, this would have at least been
`inherent because Tivoli discloses automatically assigning a storage pool to data an