EXHIBIT C-7
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`Microsoft contends that the asserted claims of the ’132 Patent are invalid as obvious by Callaghan, “NFS Illustrated” (Addison-
`Wesley Ed. 2000) (Callaghan), Rodriguez-Martinez, “Automatic Deployment of Application-Specific Metadata and Code in
`MOCHA” (“Rodriguez-Martinez”), and Lomb, “Storage Management Solutions for Distributed Computing Environments” (“Lomb”)
`prior art references under various subsections of 35 U.S.C. § 102 in view of other prior art references under 35 U.S.C. § 103 as set
`forth in Microsoft’s invalidity contentions.
`
`As Callaghan was published as early as 2000 and no later than 2001, Microsoft contends that it is prior art to the ’132 Patent under at
`least pre-AIA 35 U.S.C. § 102(b).
`
`As Rodriguez-Martinez was published in 1999, Microsoft contends that it is prior art to the ’132 Patent under at least pre-AIA 35
`U.S.C. § 102(b).
`
`As Lomb was published in 1996, 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 Limitation(s)
`“wherein the method
`further comprises
`translating the one or more
`attributes” (Claim element
`22[a])
`
`Disclosures
`
`Callaghan, “NFS Illustrated” (Addison-Wesley Ed. 2000) (“Callaghan”)
`
`Callaghan discloses translating the one or more attributes. For example, Callaghan states:
`
`“The NFS protocol allows files to be named by a sequence of names that make up a path. The protocol
`is careful not to require that pathnames be supported as entities within the protocol itself. A pathname
`is evaluated with a sequence of LOOKUP requests. Component-by-component evaluation make it
`unnecessary for the protocol to reserve a character to separate the components in a pathname. It is
`fortunate for PC-UNIX interoperability because UNIX uses a forward slash separator, a/b/c, whereas
`PC clients use a backslash, a\b\c.
`
`UNIX servers are case-sensitive and case-preserving. This means that a UNIX server sees ABC123
`and abc123 as two different filenames – it is sensitive to differences in case. When a name is assigned
`to a new file, the UNIX server will preserve the cases of the characters in the filename; it will not map
`to uppercase or lowercase. DOS clients are case-insensitive and are not case-preserving. This means
`that a DOS client cannot distinguish the name ABC123 from abc123. If the file Abc123 is created,
`instead of preserving the cases, it will map all characters to uppercase—ABC123. A Windows client
`is case-insensitive and case-preserving. Like a DOS client, it cannot tell the difference between
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`Disclosures
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`ABC123 and abc123, but it will preserve the cases in a filename—it will not map lowercase to
`uppercase.
`
`The names within a UNIX or Windows path can be any sequence of up to 255 characters excluding the
`separator slash. DOS clients are restricted in their choice of names to an ‘8.3’ format: the name is
`limited to 8 characters plus a dot and an extension of up to 3 characters. In addition, the characters
`.,+[]*?:\/;=<> are ruled illegal. These restrictions can create problems for DOS clients that access files
`on a UNIX or Windows server. How can long names be represented in 8.3 format and what can be
`done about the characters that are legal for UNIX but illegal for DOS or Windows? The DOS client
`uses an algorithm to map UNIX names to DOS equivalents, as follows:
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`Disclosures
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`
`The making of a unique name in step 6 through addition of XX characters presents an interesting
`challenge. The two uniqueness characters must not be randomly chosen because the name must persist
`from one day to the next, even if the client is rebooted and the mapping table is lost. The Beame and
`Whiteside (now Hummingbird, Inc.) PCNFS client solved the problem neatly by using the READDIR
`cookie value associated with the directory entry as the basis for generating the XX characters.
`
`The DOS-mapped name and the NFS name are stored in a mapping table. If a user types a DOS-
`mapped name, the client will translate it to the NFS name via the mapping table before sending a
`LOOKUP request to the server.” Callaghan at 379-381.
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`EXHIBIT C-7
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`Disclosures
`
`
`“14.2 File Attributes. DOS supports only a small set of file attributes compared with the POSIX set
`of 13 or so file attributes provided in the NFS fattr structure returned by the GETATTR request (Table
`14.2). Some of the NFS attributes like file size and mtime have DOS equivalents. Others have no
`mapping or an indirect mapping.”
`
`
`Callaghan at 381-382.
`
`Rodriguez-Martinez, “Automatic Deployment of Application-Specific Metadata and Code in
`MOCHA” (“Rodriguez-Martinez”)
`
`Rodriguez-Martinez discloses translating the one or more attributes. For example, Rodriguez-Martinez
`states:
`
`
`
`
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`Disclosures
`
`“Database middleware systems, such as database gateways and mediator systems, are used to integrate
`heterogeneous data sources dispersed over a computer network. In order to achieve data integration,
`the middleware layer imposes a global data schema on top of the individual schema used by each
`source. Through this mechanism, the client applications been serviced by the middleware system are
`provided with a uniform view and uniform access interface to the data sets stored by each data source.
`The translation of the data items to the global schema is performed by either a wrapper or database
`gateway. Wrappers are used when integration is achieved through a mediator system, such as
`TSIMMIS [CGMH +94], DISCO [TRV96] or Garlic [RS97]. On the other hand, gateways are used
`when integration is realized by importing the data into a commercial DBMS, such as Oracle [Cor99] or
`Informix [Cor97]. Typically, these applications use a connectivity API such as ODBC or JDBC to
`extract the data from the sources. The wrapper or gateway can either be run on a machine near the data
`source (e.g. on the same Local Area Network) or at the site where the integration server runs.”
`Rodriguez-Martinez at 1.
`
`“In order to access the wealth of information stored in a particular data source, the QPC connects to the
`Data Access Provider (DAP) associated with the source. The DAP is a server application which
`extracts data from a source on behalf of the QPC. For each data source, there is at least one DAP, and
`each DAP in the system can be located by QPC through a URL. There are two essential services
`provided by a DAP: a) data translation, and b) query execution. The DAP extracts requested items
`from the data source, and translates them from the local schema used by the source into the global
`schema used by QPC. Also, the DAP is capable of executing query operators that generate new
`abstractions from the data. In particular, the DAP is designed to execute those operators that filter out
`the data sets (e.g. a predicate) to produce smaller values. For this reason, the DAP should be run at the
`data source site or in close proximity to it (e.g. on another host in the same LAN). The QPC delivers
`all the code for the data types and operators used by each DAP. Similarly, all results produced by each
`DAP are sent to QPC for further processing until the final answer to the query is fabricated.”
`Rodriguez-Martinez at 5.
`
`“The first resources that must be made available to MOCHA are the tables to be used by the
`application. For each table, metadata indicating its name, the database in which it is stored, the
`columns names and the middleware types needed to represent each column must be added to the
`
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`Patent No. 8,671,132
`Claim Limitation(s)
`
`“data management system
`for an open systems
`environment” (Claim
`element 26[pre])
`
`EXHIBIT C-7
`
`Disclosures
`
`catalog. This information will enable MOCHA to access each table, retrieve its tuples, project one or
`more of its columns and translate each column value into a middleware data type.” Rodriguez-
`Martinez at 7.
`
`Lomb, “Storage Management Solutions for Distributed Computing Environments” (“Lomb”)
`
`Lomb discloses a storage management system in an open systems environment. For example, Lomb
`states:
`
`“As customers reengineer their businesses, many are choosing to migrate away from the mainframe via
`‘mainframe downsizing.’ Mission-critical applications are moving to open systems, and the
`management of client-server workgroups is being consolidated across LANs and WANs. An
`enormous amount of company-sensitive data, which used to be under central control and located in the
`data center, is now distributed and available on the network (Fig. 2). Published market numbers show
`that the average amount of distributed data has surpassed the average amount of data in the data center.
`Companies must begin viewing storage management as integral to their network and system
`management solutions.” Lomb at 1.
`
`“However, each customer’s needs for storage management solutions are different. No one vendor can
`provide a single solution for every environment. Rather than create a monolithic, proprietary solution,
`HP is working closely with third-party partners and many diverse HP divisions to create an open,
`standardized environment in which many vendors can participate in creating solutions.” Lomb at 4.
`
`“The second disk array offering is EMC’s Symmetrix 3000. The Symmetrix 3000 is a high-
`performance integrated-cache disk array designed for online storage. As such, the Symmetrix 3000
`provides a high level of online performance, an online capacity of up to 1.1 terabyte, and
`manageability and high availability to HP 9000 business servers. The result is a mainframe-class data
`storage solution that is simple to manage and is delivered in a high-performing, scalable, protected,
`and open architecture.” Lomb at 7.
`
`
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`Patent No. 8,671,132
`Claim Limitation(s)
`
`EXHIBIT C-7
`
`Disclosures
`
`“Today’s open systems for critical business computing environments require three essential elements.
`First, they must provide the storage management, data integrity, security, and manageability that
`information technology managers have come to expect in running business-critical applications on
`centralized processing systems. Second, they must provide connectivity and compatibility with the
`growing base of PC desktop users. Finally, they must offer flexibility, performance scalability, and
`technical innovation to keep up with emerging application demands.
`
`As the leading open systems platform, HP 9000 business servers offer the benefits of all three elements
`in a single, unified, UNIX-based platform. The HP 9000 server platform is able to support
`environments of all sizes, ranging from workgroups and replicated sites to the departments and data
`centers of large enterprises. For storage management, the HP 9000 business servers offer the following
`features:
` Highly available and reliable systems environment
` Excellent data-movement management
` A dedicated storage server architecture that is designed for optimal database and file
`management
` Scalable from desktop to data center
` Hundreds of partners that ensure customizable solutions.”
`Lomb at 9.
`
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