Trials@uspto.

gov
571-272-7822

Paper 9
Entered: January 11, 2017

UNITED STATES PATENT AND TRADEMARK OFFICE

____________
BEFORE THE PATENT TRIAL AND APPEAL BOARD
____________
UNIFIED PATENTS INC.,
Petitioner,
v.
INTELLECTUAL VENTURES II, LLC,
Patent Owner.
____________
Case IPR2016-01404
Patent 6,968,459 B1
____________

Before THOMAS L. GIANNETTI, PETER P. CHEN, and

KAMRAN JIVANI, Administrative Patent Judges.
JIVANI, Administrative Patent Judge.

DECISION
Institution of Inter Partes Review
37 C.F.R. 42.108

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Patent 6,968,459 B1
I.

INTRODUCTION

Petitioner Unified Patents Inc. requested, on July 11, 2016, inter

partes review of claims 1, 2, 1315, 18, 33, 34, 39, 46, and 48 (the
Challenged Claims) of U.S. Patent No. 6,968,459 B1 (the 459 patent).
Paper 2 (Petition or Pet.). On October 19, 2016, Patent Owner
Intellectual Ventures II, LLC filed a Preliminary Response. Paper 8
(Prelim. Resp.).
Under 35 U.S.C. 314(a), an inter partes review may not be instituted
unless it is determined that there is a reasonable likelihood that the
petitioner would prevail with respect to at least 1 of the claims challenged in
the petition. Based on the information presented in the Petition and
Preliminary Response, we are persuaded that there is a reasonable likelihood
Petitioner would prevail with respect to claims 1, 2, 13, 14, 33, 34, 39, 46,
and 48. We are not persuaded, however, that there is a reasonable likelihood
Petitioner would prevail with respect to claims 15 and 18.
Accordingly, we institute inter partes review of claims 1, 2, 13, 14,
33, 34, 39, 46, and 48 on the grounds specified below. Our factual findings
and conclusions at this stage of the proceeding are based on the evidentiary
record developed thus far. This is not a final decision as to patentability of
claims for which inter partes review is instituted. Further, we decline to
institute inter partes review of claims 15 and 18 for the reasons set forth
below.

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II.
A.

BACKGROUND

The 459 patent (Ex. 1001)

The 459 patent seeks to create a highly secure computing

environment . . . preventing the appropriation of sensitive data. Ex. 1001,
1:1331. The 459 patent describes a secure computing environment in
which a computer automatically operates in a secure full access data
storage mode when the computer detects the presence of a secure removable
storage device. Id. at 1:3539. If, however, the computer detects the
presence of a removable storage device that is not secure, then the
computer automatically operates in a restricted-access mode. Id. at 1:39
42. Figure 1 of the 459 patent is reproduced below.

Figure 1 of the 459 patent depicts a block diagram of a secure

computing environment, including computer 100 that senses whether storage
device 151 is secure. Id. at 1:3033. To determine whether a removable
storage device is secure, the 459 patent describes attempting to read
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device-specific security information from the storage device. Id. at 5:7
10. The device-specific security information is derived from the unique
format information of the removable storage device. Id. at 3:654:1.
The459 patent elaborates:
In one embodiment, the device-specific security
information is a function of the low-level format
information and, therefore, uniquely identifies the
underlying media of storage device 151. For example, in
one embodiment the device-specific security information
is a hash of the addresses of the bad sectors for storage
device 151. Because it is a function of the physical
characteristics of the actual storage medium within
storage device 151, the format information is inherently
unique to each storage device 151. In other words, the
addresses of the bad sectors change from device to
device.
Id. at 4:919.
According to the 459 patent, when a computer operates in a secure
full access data storage mode, storage management software encrypts and
decrypts data transmitted between the computer and the removable storage
device using a cryptographic key. Id. at 3:6164. The system of the 459
patent generates this cryptographic key by combining any number of the
following types of information: (1) device-specific security information
. . . , (2) manufacturing information that has been etched onto the storage
device, (3) drive-specific information, such as drive calibration parameters,
retrieved from the storage drive, and (4) user-specific information such as a
password or biometric information. Id. at 3:654:5.
When a computer operates in a restricted-access data storage mode,
the computer operates the storage device as read-only such that the user

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Patent 6,968,459 B1
may read data from the device but may not write any data to the device. Id.
at 1:6366. Alternatively, the user may be permitted to write the nonsensitive data to the removable storage device in an unencrypted format.
Id. at 1:662:2.
B.

Illustrative Claim

Claims 1, 15, 18, 33, and 39 are independent claims. Claim 1 is

reproduced below.
1.

A method comprising:

sensing whether a storage device has device-specific

security information stored thereon;
operating a computer in a full-access mode when the
storage device has the device-specific security information,
wherein in the full-access mode the computer permits both read
and write access to the storage device; and
operating the computer in a restricted-access mode when
the storage device does not have the device-specific security
information, wherein in the restricted-access mode the
computer permits read access to the storage device and prevents
write access to the storage device.
C.

Evidence Relied Upon

Petitioner relies on the following references:

1. Bensimon et al., U.S. Patent No. 5,553,125, issued July 2, 1996
(Ex. 1004, Bensimon).
2. Takahashi et al., U.S. Patent No. 5,825,878, issued Oct. 20, 1998
(Ex. 1005, Takahashi).
3. Kimura, U.S. Patent No. 5,237,609, issued Aug. 17, 1993
(Ex. 1006, Kimura).

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Patent 6,968,459 B1
Petitioner further relies on the Declaration of Dr. Paul Franzon
(Ex. 1002).
D.

Proposed Grounds of Unpatentability

Petitioner advances the following grounds of unpatentability:

References

Statutory Ground Challenged Claims

Bensimon

35 U.S.C. 102(b)

1, 13, 14, 33, 39, 46,

and 48

Bensimon & Takahashi

35 U.S.C. 103(a)

2, 15, and 34

Kimura & Takahashi

35 U.S.C. 103(a)

18

E.

Related Proceedings

Petitioner identifies the following related matters: Intellectual

Ventures I, LLC and Intellectual Ventures II, LLC v. Lenovo Group Ltd.,
Lenovo (United States) Inc., LenovoEMC Products USA, LLC, and EMC
Corp., No. 1:16-cv-10860 (D. Mass); and Intellectual Ventures I, LLC and
Intellectual Ventures II, LLC v. NetApp, Inc., No. 1:16-cv-10868 (D. Mass).
Pet. 2.

III.

CLAIM CONSTRUCTION

Petitioner seeks construction of the following terms: device-specific

security information, device-specific information, user-specific security
information, status change . . . for the storage device, and storage
manager. Pet. 1117. Patent Owner urges that we need not construe the
terms of the Challenged Claims. Prelim. Resp. 6. Because construction of
the terms proposed by Petitioner is not necessary to our analysis on whether
to institute a trial, we do not construe these terms. Vivid Techs., Inc. v. Am.
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Sci. & Engg, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (explaining that only
claim terms in controversy need to be construed, and only to the extent
necessary to resolve the controversy).

IV.
A.

ANALYSIS

Overview of Cited References

1.

Bensimon

Bensimon relates to a system for securing removable information

storage devices, including means for preventing the computer system from
reading from, or writing to, the storage device absent the entry of a selected
password by a user of the host computer system. Ex. 1004, 2:4549.
Figure 1 of Bensimon is reproduced below.

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Patent 6,968,459 B1
Figure 1 of Bensimon depicts computer 10 and storage device 100,
which Bensimon describes as an intelligent storage device. Id. at 4:50,
5:3234. The intelligent storage device of Bensimon includes a password
security feature at the device level. Password security at the device level
provides an advantage over system-level password security in that a stolen
storage device cannot be used in any computer unless the thief also knows
the password. Id. at 4:5056.
Figure 3 of Bensimon is reproduced below.

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Patent 6,968,459 B1
Figure 3 of Bensimon depicts a simplified block diagram of an
intelligent removable information storage device 100 in accordance with the
invention. Id. at 4:3545. In a preferred embodiment of Bensimon, the
password and a password enabling flag are stored in the media 102 itself,
along with the protected data, rather than with the control electronics. Id. at
6:3537.
2.

Takahashi

Takahashi teaches a secure memory management unit fabricated on a

single integrated circuit chip 10. Ex. 1005, 2:2830. Figure 1 of Takahashi
is reproduced below.

Figure 1 of Takahashi depicts a block diagram of a preferred

embodiment of a secure memory management unit on integrated circuit
chip 10. Id. at 2:2634. Takahashis secure memory management unit
comprises a memory controller 16 and a secure digital memory access
controller 14. Id. at 2:4849. The primary function of this secure memory
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management unit is to read encrypted external program code instructions
and data stored in the external memory, decrypt these instructions, and
store the information in a secure random access memory (RAM). Id. at
2:3240.
3.

Kimura

Kimura describes a portable information memory card and a system

for utilizing such card which provides security without the necessity for an
onboard microprocessor. Ex. 1006, 18:4043. The system of Kimura
stores on the portable memory card two separate pieces of information to be
used in a security check comparison: (i) an identification code and (ii)
external identification information. Id. at 18:4060. The identification code
is internal information specific to the particular memory card and cannot be
easily read out from the card because it is not available to the interface bus
under any circumstances. Id. The external identification information is
encrypted and thus must be read out from the card and decrypted in order to
perform the security check comparison. Id.
B.
Anticipation of Claims 1, 13, 14, 33, 39, 46, and 48 based on
Bensimon
1.

Claim 1

Petitioner asserts Bensimon anticipates independent claim 1. Pet. 20

27. We have reviewed the information provided by Petitioner, including the
relevant portions of the supporting Franzon Declaration. Petitioners
analysis demonstrates where Bensimon discloses each element of claim 1.
Id. For example, relying on the Franzon Declaration, Petitioner contends
Bensimons password and password-enabling flag stored on the storage
media meet the claimed device-specific security information. Id. at 22
(citing Ex. 1002 5260). According to Petitioner, Bensimon discloses the
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claimed full-access mode permitting read and write access when
Bensimons storage device 100 has the password-enabling flag and the
read/write password as the device-specific security information. Pet. 26
(citing Ex. 1002 61); see also Ex. 1004, 6:1329. Further, Petitioner
contends Bensimon discloses the claimed restricted-access mode
permitting read access and preventing write access when Bensimons storage
device 100 has the password-enabling flag and the write protection (readonly) password as the device-specific security information. See Pet. 27
(citing Ex. 1002 6263); see also Ex. 1004, 6:1329.
Patent Owner argues Bensimon does not disclose the restrictedaccess mode because when Bensimons password security is not enabled,
the device operates in an unprotected mode. Prelim. Resp. 10 (citing Ex.
1004, 6:34). Similarly, Patent Owner argues Bensimon does not disclose
the restricted-access mode because, if the write protection (read only)
password is not entered correctly, write access and read access are
restricted. Prelim. Resp. 12. We are not persuaded by Patent Owners
arguments. Claim 1 recites, A method comprising. . . . The transition
comprising in a method claim indicates that the claim is open-ended and
allows for additional steps. Invitrogen Corp. v. Biocrest Manufacturing,
L.P., 327 F.3d 1364, 1368 (Fed. Cir. 2003). The presence of an additional
unprotected mode in Bensimon, therefore, is not excluded by the scope of
claim 1. Similarly, the presence of an additional mode preventing access
due to incorrect password entry is not excluded by the scope of claim 1.
Rather, we agree with Petitioner that Bensimon discloses the claimed
restricted-access mode permitting read access and preventing write access
in the situation where Bensimons storage device 100 has the password-

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enabling flag and the correctly-entered write protection (read-only)
password. See Pet. 27 (citing Ex. 1002 6263); see also Ex. 1004, 6:13
29.
Patent Owner additionally argues Bensimon lacks the claimed
device-specific security information because Bensimons passwords are
user-specific informationa user selects and sets the password. Prelim.
Resp. 15 (emphasis omitted). Thus, according to Patent Owner, the user
can assign the exact same password to each and every device in Bensimon.
Id. We are not persuaded by Patent Owners argument. To the extent Patent
Owner contends passwords may not be device-specific security
information, we disagree. The 459 patent does not disclose that devicespecific security information must not include passwords, or that all
passwords are user-specific rather than device-specific. See Ex. 1001, 3:65
4:5. Moreover, Petitioner relies on both Bensimons password and its
password-enabling flag, and cites Bensimons description of the passwordenabling flag stored on the storage media as a unique string of characters.
Pet. 2627 (citing Ex. 1004, 6:1329). We agree with Petitioner, based on
the record before us and at this stage of the proceeding, that at least
Bensimons password and password-enabling flag stored on the device are
device-specific as required by claim 1.
For the reasons discussed above and based on the current record
at this stage of the proceeding, we determine Petitioner has shown a
reasonable likelihood of prevailing on this anticipation challenge to
claim 1.

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2.

Claims 33 and 39

Petitioner asserts Bensimon anticipates independent claims 33 and 39,

which Petitioner asserts are of commensurate scope with claim 1. Pet. 29
30 (analysis of claim 33) and 3132 (analysis of claim 39). Petitioner does
not present separate arguments on either claim 33 or claim 39, instead
relying on the arguments presented on claim 1. Id. Claim 1 recites a
method, claim 33 recites a computer-readable medium containing
instructions for performing a method, and claim 39 recites a computer
comprising components for performing particular functions. For purposes of
our analysis, we determine that claims 33 and 39, although differing in
format, do not require a separate analysis from claim 1. Accordingly, for the
reasons discussed above in the context of claim 1 and based on the current
record at this stage of the proceeding, we determine Petitioner has shown a
reasonable likelihood of prevailing on this anticipation challenge to claims
33 and 39. See supra Section IV.B.1.
3.

Claims 13 and 14

Petitioner asserts Bensimon anticipates dependent claims 13 and 14.

Pet. 2728. We have reviewed the information provided by Petitioner,
including the relevant portions of the supporting Franzon Declaration.
Petitioners analysis demonstrates where Bensimon discloses each element
of claims 13 and 14. Id. For example, Petitioner contends Bensimon meets
the claim 13 limitation of performing the claimed sensing step when a
status change is detected and the claim 14 limitation that the status change
indicates the insertion of the storage device into the computer because
Bensimon discloses:
Upon insertion of the pc card 100 into the computer 10,
[h]ost systems that are password aware may look at this
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data field prior to attempting access, and determine
whether the password is required to be issued to the
drive. Preferably, this issuance will be accomplished via
system prompt of the user.
Id. at 28 (citing Ex. 1004, 6:3034).
Patent Owner argues Bensimon fails to meet the limitations of claim
13 and 14 because Bensimon does not disclose detecting the insertion of
the PC card, let alone performing the sensing step once the detection
occurs. Prelim. Resp. 18 (emphasis omitted). We are not persuaded by
Patent Owners arguments. The passages of Bensimon cited by Petitioner
disclose that password aware systems determine whether a password is
required to be issued to the card prior to attempting access to the card (i.e.,
sensing whether a storage device has device-specific security information
stored thereon). Ex. 1004, 6:3032. If a password is required to be issued,
Bensimon discloses prompting the user to issue the password. Id. at 6:32
34. According to Bensimon, this process allows the user to enable
protection for a pc card not previously in a password protected mode upon
insertion of the pc card into the computer (i.e., when a status change is
detected . . . the status change indicates the insertion of the storage device
into the computer). Id. at 5:3240. Therefore, we agree with Petitioner,
based on the record before us and at this stage of the proceeding, that
Bensimon meets the limitations of claims 13 and 14.
For the reasons discussed above and based on the current record
at this stage of the proceeding, we determine Petitioner has shown a
reasonable likelihood of prevailing on this anticipation challenge to
claims 13 and 14.

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4.

Claims 46 and 48

Petitioner asserts Bensimon anticipates dependent claims 46

and 48. Pet. 3233. We have reviewed the information provided by
Petitioner, including the relevant portions of the supporting Franzon
Declaration. Petitioners analysis demonstrates where Bensimon
discloses each element of claims 46 and 48. Id. Specifically,
Petitioner cites Bensimons pc card 100 as meeting the removable
storage medium recited in claim 46 and the magnetic disk within pc
card 100 as meeting the disk-shaped storage medium recited in
claim 48. Id. at 33. Patent Owner does not present separate
arguments on these issues. See Prelim. Resp. 1720. Accordingly,
based on the current record at this stage of the proceeding, we
determine Petitioner has shown a reasonable likelihood of prevailing
on this anticipation challenge to claims 46 and 48.
C.
Obviousness of Claims 2, 15, and 34 based on Bensimon in
combination with Takahashi
1.

Claims 2 and 34

Petitioner asserts dependent claims 2 and 34 would have been obvious

in light of Bensimon and Takahashi. Pet. 3640 (analysis of claim 2) and
4243 (analysis of claim 34). We have reviewed the information provided
by Petitioner, including the relevant portions of the supporting Franzon
Declaration. Petitioners analysis demonstrates where the elements of
claims 2 and 34 are taught or suggested by Bensimon and Takahashi. Id.
For example, Petitioner relies on Takahashis secure memory management
unit whose primary function is to read encrypted external program code
instructions and data stored in the external memory (Ex. 1005, 2:2640),
decrypt these instructions, and store the information in a secure RAM as
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teaching or suggesting the claim 2 limitations: encrypting digital data to be
written to the storage device from the computer and decrypting digital data
read from the storage device by the computer. Pet. 3638 (citing Ex. 1005,
2:2639). Petitioner further relies on Takahashi as teaching or suggesting
encrypting digital data to be written to the storage drive; and decrypting
digital data read from the storage device, as recited by claim 34. Id. at 42
43.
Finally, relying on the Franzon Declaration, Petitioner asserts one of
ordinary skill in the art would have been motivated to combine the cited
references because one of ordinary skill would have recognized that, by
adding Takahashis technique to Bensimons system, the unauthorized user
would not only have to know the password for the device as described by
Bensimon, but would also need to have the particular encryption firmware as
described by Takahashi. Id. at 3840 (citing Ex. 1002 81; see also id.
82).
Patent Owner advances no argument on claim 34 and argues regarding
claim 2 that Petitioner fails to show the cited references teach or suggest
automatically performing the encrypting and decrypting. Prelim. Resp. 21.
We are not persuaded by this argument because Takahashi teaches
performing the cited encryption and decryption without user intervention via
direct memory access controller 14 and memory controller 16. Ex. 1005,
2:603:20.
For the reasons discussed above and based on the current record
at this stage of the proceeding, we determine Petitioner has shown a
reasonable likelihood of prevailing on this obviousness challenge to
claims 2 and 34.

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2.

Claim 15

Claim 15 recites, in relevant part, providing full-access when the

storage device senses device-specific security information by encrypting and
decrypting digital data using the security information. Thus, claim 15
requires using the device-specific security information to encrypt and
decrypt digital data.
Petitioner asserts independent claim 15 would have been obvious in
light of Bensimon and Takahashi. Pet. 4042. More particularly, Petitioner
contends, It would have been obvious to encrypt the outbound data (i.e., the
data written to the storage device) in Takahashi using the security
information of Bensimon. Pet. 42. This is because, according to
Petitioner, Bensimons security information is made up of a password
already shared by the storage device 100 and the host computer 10. Id.
Petitioner does not proffer any citations from Bensimon in support for this
statement. After concluding the paragraph containing this assertion,
Petitioner directs our attention to paragraphs 82 through 85 of the Franzon
Declaration. Id. Paragraph 85 of the Franzon Declaration summarily asserts
Bensimons password is already shared by the storage device 100 and the
host computer 10, without citation to Bensimon. Ex. 1002 85.
Contrary to Petitioners assertions, Patent Owner contends
Bensimons password is stored only on the storage device and not on the
host computer and the computer has no need for the password because the
storage device controls access to its memory. Prelim. Resp. 2425 (citing
Ex. 1004, 5:6567). We agree with Patent Owner. Bensimon describes a
user entering a password string and the computer transfer[ring] the
password string to the device 100. Ex. 1004, 5:6365. Petitioner does not

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cite, and we do not find, support in Bensimon for the notion that the
password is shared by the computer and the device. Sharing the password
in the manner proposed by Petitioner would be contrary to Bensimons
disclosure that password security at the device level provides an advantage
over system-level password security. Id. at 4:5056. Further, Bensimon
describes storing the password and the password enabling flag in the media
102 itself, along with the protected data, rather than with the control
electronics. Id. at 6:3537. Petitioner fails to explain in the record before
us why one of ordinary skill in the art would be motivated to modify
Bensimons passworddescribed in the above-cited passages as secured
within the storage media itselfto be shared between the storage media and
the computer such that the computer could use that password to decrypt data.
For the reasons discussed above, we determine Petitioner has
not shown a reasonable likelihood of prevailing on this obviousness
challenge to claim 15.
D.
Obviousness of Claim 18 based on Kimura in combination with
Takahashi
Claim 18 recites, in relevant part, sensing whether the storage device
has security information generated from a combination of device-specific
information associated with the storage device and user-specific information
associated with a user. Thus, claim 18 requires a determination of whether
the storage device contains security information generated from a
combination of device-specific and user-specific information.
Petitioner relies on Kimuras particular security code assigned to the
card in question as meeting the claimed security information. Pet. 52. Id.
at 5253 (citing Ex. 1006, 14:1221, 17:2737). Petitioner further relies on
Kimuras comparison of this internal security code (i.e., security
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information) with another security code deciphered from external
information as meeting the claimed sensing whether the storage device
has security information. Pet. 52.
We are not persuaded by Petitioners arguments because they are not
commensurate with the claim language. Claim 18 requires sensing the
presence of security information, which Petitioner contends is taught or
suggested by Kimuras security code. Pet 52. Petitioners contentions,
however, fail to identify adequate teaching or suggestion of sensing the
presence of this secure code. Id. Kimura describes the cited security code
as internal information assigned to that particular card and not available
to the interface bus under any circumstances. Ex. 1006, 18:4060. Thus,
Kimura describes the card has the cited security code within its internal
memory once the code has been assigned to that card. See id. Rather than
establishing that Kimura senses the presence of this code in the internal
memory of the card, Petitioner directs our attention to Kimuras comparison
of a second code to the internal security code. Pet. 52, 5759. Whether the
two codes match, however, does not address sensing whether Kimuras card
contains the internal security codewhich Kimura teaches is in fact stored
within the card after it is assigned to the card. Ex. 1006, 18:4060.
For the reasons discussed above and based on the current record
at this stage of the proceeding, we determine Petitioner has not shown
a reasonable likelihood of prevailing on this obviousness challenge to
claim 18.

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V.

SUMMARY

We determine that Petitioner has demonstrated a reasonable likelihood

of prevailing on its challenges to claims 1, 2, 13, 14, 33, 34, 39, 46, and 48.
Petitioner has failed to demonstrate, however, that there is a reasonable
likelihood Petitioner would prevail with respect to claims 15 and 18. At this
stage of the proceeding, we have not made a final determination as to the
patentability of any of the Challenged Claims.

VI.

ORDER

It is, therefore:
ORDERED that, pursuant to 35 U.S.C. 314(a), an inter partes
review of the 459 patent is hereby instituted on the following grounds:
A. Anticipation of claims 1, 13, 14, 33, 39, 46, and 48 by Bensimon;
and
B. Obviousness of claims 2 and 34 over Bensimon and Takahashi.
FURTHER ORDERED that review based on any other proposed
grounds of unpatentability is not authorized; and
FURTHER ORDERED that pursuant to 35 U.S.C. 314(c) and
37 C.F.R. 42.4, notice is hereby given of the institution of a trial
commencing on the entry date of this decision.

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FOR PETITIONER:
P. Andrew Riley
James D. Stein
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, LLP
Andrew.Riley@finnegan.com
James.Stein@finnegan.com
Jonathan Stroud
UNIFIED PATENTS INC.
jonathan@unifiedpatents.com

PATENT OWNER:
Lori A. Gordon
Byron Pickard
Steven Peters
STERNE, KESSLER GOLDSTEIN & FOX PLLC
lgordon-ptab@skgf.com
bpickard@skgf.com
speters@skgf.com

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