Filed on behalf of Symantec Corporation
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`VEEAM SOFTWARE CORPORATION
`Petitioner
`
`v.
`
`SYMANTEC CORPORATION
`Patent Owner
`
`Case IPR2013-00150
`U.S. Patent No. 7,093,086
`
`PATENT OWNER MOTION TO EXCLUDE
`PURSUANT TO 37 C.F.R. § 42.64(c)
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`VEEAM SOFTWARE CORPORATION
`Petitioner
`
`v.
`
`SYMANTEC CORPORATION
`Patent Owner
`
`Case IPR2013-00150
`U.S. Patent No. 7,093,086
`
`PATENT OWNER MOTION TO EXCLUDE
`PURSUANT TO 37 C.F.R. § 42.64(c)
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`
`TABLE OF CONTENTS
`
`I.
`
`PETITIONER IMPROPERLY RELIES ON HYPOTHETICALS ...............1
`
`A.
`
`B.
`
`Original Declaration of Dr. Shenoy (Veeam 1002) .............................3
`
`Declaration of Dr. Shenoy in Support of Petitioner’s Reply (Veeam
`1030) .....................................................................................................5
`
`II.
`
`PETITIONER’S MISCHARACTERIZATION OF PATENT
`OWNER’S EXPERT TESTIMONY ..............................................................7
`
`III. CONCLUSION .............................................................................................10
`
`i
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`
`TABLE OF AUTHORITIES
`
`CASES
`
`Capsugel Belgium NV v. Innercap Technologies, Inc.,
`IPR 2013-00331 (PTAB Dec. 2013)..................................................................2
`
`Eli Lilly & Co. v. Sicor Pharms., Inc.,
`705 F.Supp.2d 971 (S.D. Ind. 2010) ..................................................................2
`
`Net MoneyIN, Inc. v. VeriSign, Inc.,
`545 F.3d 1359 (Fed Cir. 2008)...........................................................................1
`
`Structural Rubber Products Co. v. Park Rubber Co.,
`749 F.2d 707 (Fed. Cir. 1984)............................................................................2
`
`STATUTES AND RULES
`
`35 U.S.C. § 102............................................................................................. 1, 3, 5, 6
`
`35 U.S.C. § 311(b) .....................................................................................................2
`
`37 C.F.R. § 42.64(c)...................................................................................................1
`
`ii
`
`
`
`Symantec
`Exhibit No.
`Symantec 2001
`Symantec 2002
`Symantec 2003
`Symantec 2004
`Symantec 2005
`
`Symantec 2006
`
`Symantec 2007
`Symantec 2008
`
`Symantec 2009
`
`Symantec 2010
`
`Symantec 2011
`
`Symantec 2012
`
`Symantec 2013
`
`Symantec 2014
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`
`LIST OF EXHIBITS
`
`Document Description
`Office Action, dated April 11, 2005
`Appeal Brief, dated July 19, 2005
`Response to Office Action, dated November 14, 2005
`Supplemental Notice of Allowability, dated July 6, 2016
`Symantec Corp. v. Veeam Software Corp., Civil Action No.
`3:12cv700 (Dkt. 105), Claim Construction Order, dated
`March 8, 2013
`Patent Owner’s Objections to Petitioner’s Evidence Pursuant
`to 37 C.F.R. § 42.64(b)(1)
`Declaration of Daniel Block, dated September 5, 2013
`Patent Owner’s Objections to Petitioner’s Supplemental
`Evidence Pursuant to 37 C.F.R. § 42.64(b)(1)
`Email requesting permission to file motion to amend, dated
`October 21, 2013
`Internet Archive webpage titled “Download VMware
`Products” captured from VMware website, dated June 23,
`2001
`Internet Archive webpage titled “Download VMware
`Products” captured from VMware website, dated June 23,
`2001
`Internet Archive webpage titled “VMware Server Products
`Ordering Information” captured from VMware website, dated
`October 7, 2001
`Internet Archive webpage titled “Evaluate VMware ESX
`Servicer” captured from VMware website, dated June 8, 2001
`Garmin Int’l, Inc. et al. v. Cuozzo Speed Tech. LLC, IPR2012-
`00001, No. 26 (Mar. 5, 2013), Decision
`
`iii
`
`
`
`Symantec
`Exhibit No.
`Symantec 2015
`
`Symantec 2016
`
`Symantec 2017
`Symantec 2018
`
`Symantec 2019
`
`Symantec 2020
`
`Symantec 2021
`Symantec 2022
`Symantec 2023
`
`Symantec 2024
`
`Symantec 2025
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`
`Document Description
`Declaration of Matthew D. Green in Support of Patent
`Owner’s Motion to Amend
`Declaration of Matthew D. Green in Support of Patent
`Owner’s Response
`Cross-Examination Testimony of Prashant Shenoy
`Non-Provisional Patent Application Serial No. 10/109,186
`accorded a filing date of March 28, 2002 (original ‘086
`specification)
`Declaration of Matthew D. Green in Support of Patent
`Owner’s Reply to Petitioner’s Opposition (Green Rep.)
`Deposition Transcript of Prashant Shenoy, March 7, 2014
`(Shenoy 2nd Dep.)
`Suzaki, U.S. Patent 7,240,239
`CP Command Reference for general Users (“VM Dump”)
`Linux on IBM eserver zSeries and S/390: ISP/ASP Solutions
`(“Linux on IBM”)
`Preemptable Remote Execution Facilities for the V-System
`(“Theimer”)
`CM BrightStor VM:Backup Operator’s Guide (“CM
`BrightStor”)
`
`Currently Filed
`
`Symantec 2026
`Symantec 2027
`
`Patent Owner’s Objections to Evidence, March 2, 3013
`Deposition Transcript of Dr. Green, March 28, 2014
`
`iv
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`
`TABLE OF ABBREVIATIONS
`
`Abbreviation
`Pet.
`Reply
`
`Shenoy 2nd Dep.
`
`Description
`Petition for Inter Partes Review
`Petitioner’s Reply to Patent Owner’s Response (Paper No.
`33)
`Deposition Transcript of Dr. P. Shenoy, March 7, 2014
`(Symantec 2020)
`
`Orig. Shenoy Dec.
`
`Original Declaration of Dr. Shenoy (Veeam 1002)
`
`Shenoy Reply Dec.
`
`Declaration of Dr. Shenoy in Support of Petitioner’s Reply
`(Veeam 1030)
`
`v
`
`
`
`Case IPR2013-00150
`U.S. Patent No. 7,093,086
`
`Pursuant to 37 C.F.R. § 42.64(c), Patent Owner respectfully moves to
`
`exclude portions of Petitioner’s Petition (Paper 2), Reply to Patent Owner’s
`
`Response (Paper 33), and the corresponding Declarations of Dr. Shenoy in support
`
`of these papers (Exhibits VEEAM 1002 and 1030). Patent Owner seeks to exclude
`
`the portions in these papers which are identified below on the grounds that they: 1)
`
`improperly rely on hypotheticals regarding the operation of products or systems
`
`that are outside the scope of, and/or irrelevant to, the grounds instituted in this IPR,
`
`and 2) cite to incomplete and misleading testimony by Dr. Green in his deposition
`
`transcript (VEEAM 1026).
`
`I.
`
`PETITIONER IMPROPERLY RELIES ON HYPOTHETICALS
`
`Petitioner repeatedly tries to supplement or expand the disclosure set forth in
`
`the Lim and ESX references. This is improper. The grounds instituted by the
`
`Board with respect to these references were under 35 U.S.C. § 102. Decision, p. 2.
`
`It is well settled that for a claimed invention to be anticipated under 35 U.S.C. §
`
`102, the reference “must … disclose all elements of the claim within the four
`
`corners of the document.” Net MoneyIN, Inc. v. VeriSign, Inc., 545 F.3d 1359,
`
`1369 (Fed Cir. 2008). Consequently, under § 102, a party may not rely on the
`
`knowledge of a person of ordinary skill in the art to supplement or modify a
`
`reference. Structural Rubber Products Co. v. Park Rubber Co., 749 F.2d 707, 715-
`
`16 (Fed. Cir. 1984); Eli Lilly & Co. v. Sicor Pharms., Inc., 705 F. Supp. 2d 971,
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`992 (S.D. Ind. 2010) (stating that “[i]n showing that all elements of an invention
`
`were anticipated, the challenging party may not rely upon the knowledge of one
`
`skilled in the art”).
`
`Moreover, 35 U.S.C. § 311(b) makes clear that an inter partes review
`
`(“IPR”) is limited to patents and printed publications. In an IPR, petitioners are
`
`not permitted to rely upon the actual products or systems that may have been sold
`
`or in public use prior to the subject patent to assert that the claims are unpatentable.
`
`See Capsugel Belgium NV v. Innercap Technologies, Inc., IPR 2013-00331, Paper
`
`No. 9 at 14-15 (PTAB Dec. 2013) (In declining to institute trial for a claim, the
`
`Board held that “the Midol product is not a patent or printed publication and
`
`cannot be the basis of a ground for review.”). Thus, Petitioner’s arguments and
`
`evidence directed to how the products that are associated with its asserted
`
`references may be used clearly fall outside the scope of this IPR. Indeed, Veeam’s
`
`own expert, Dr. Shenoy, acknowledged that the products may not work the same
`
`way as the user manuals/guides say they do, which further demonstrates why
`
`Petitioner’s arguments and evidence must be focused on the references themselves
`
`and not how the software products allegedly may have worked or been used.
`
`Shenoy 2nd Dep. 104:5-9.
`
`2
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`Patent Owner, therefore, requests that the Board strike Petitioner’s
`
`arguments and evidence that are directed to subject matter outside the scope of,
`
`and/or irrelevant to, the grounds instituted in this IPR.
`
`A.
`
`Original Declaration of Dr. Shenoy (Veeam 1002)
`
`In his original declaration, Dr. Shenoy engages in hypothetical discussions
`
`regarding the operation of products or systems when discussing Lim and ESX.
`
`Importantly, however, this declaration was submitted in support of the Petition for
`
`inter partes review which only advanced grounds for anticipation under 35 U.S.C.
`
`§ 102 in connection with each of these references. Petition, p. 8.
`
`For example, when discussing the Lim reference, Dr. Shenoy states that
`
`“[s]ince the stored state vector persists, and can thus be stored indefinitely, it can
`
`be copied to another virtual machine at any time, for example while the virtual
`
`machine is executing.” Orig. Shenoy Dec., para. 22. As Patent Owner previously
`
`noted, this does nothing to show that the virtual machine in Lim can continue
`
`executing during the copy step. Patent Owner Response, p. 41. Notably, Dr.
`
`Shenoy does not provide any support in the Lim reference itself for this conclusion
`
`given that there is no disclosure whatsoever in Lim that the state vector is copied
`
`while the virtual machine is executing. Dr. Shenoy confirmed this lack of
`
`disclosure during his deposition, stating that “it doesn’t say what happens after you
`
`store the state vector” and “Lim is silent on what is happening when the virtual
`
`3
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`machine state is being transferred.” Shenoy 2nd Dep. 59:5-19; 60:5-16. Thus, Dr.
`
`Shenoy’s analysis improperly tries to expand and supplement the disclosure of
`
`Lim.1
`
`Similarly, when discussing the ESX reference, Dr. Shenoy states that “after
`
`the redo log has been copied to the console operating systems it can be copied to
`
`another destination (such as a remote destination) at any time, particularly when
`
`the virtual machine is executing.” Orig. Shenoy Dec., para. 27. Dr. Shenoy,
`
`however, does not provide any support in the ESX reference for this conclusion.
`
`Petitioner relies on the foregoing statements in Dr. Shenoy’s original
`
`declaration regarding how the systems or products could work to fill the gaps in
`
`Lim and ESX. Petition, pp. 15, 21-22. This is impermissible under § 102 and
`
`outside the scope of the anticipation grounds on which inter partes review was
`
`initiated and instituted over these references. Moreover, it violates the statutory
`
`prohibition against relying on any prior art other than patents and printed
`
`publications in the grounds of rejection. Finally, it is irrelevant in light of the
`
`expert’s own admissions that products operate differently than guides or manuals
`
`that purport to describe them. Shenoy 2nd Dep. 104:5-9.
`
`For the foregoing reasons, Patent Owner moves to exclude the foregoing
`
`portions of Dr. Shenoy’s Original Declaration as irrelevant and outside the scope
`
`1 Importantly, Petitioner does not assert that the references inherently disclose the
`missing features.
`
`4
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`of the grounds on which inter partes review was initiated and instituted, and
`
`requests that the foregoing corresponding statements in the Petition be stricken.
`
`B.
`
`Declaration of Dr. Shenoy in Support of Petitioner’s Reply
`(Veeam 1030)
`
`In his subsequent declaration in support of Petitioner’s Reply, Dr. Shenoy
`
`continues to engage in hypothetical discussions regarding the operation of products
`
`or systems in discussing references on which the only grounds were granted is
`
`anticipation under 35 U.S.C. § 102. Decision, p. 2.
`
`For example, Dr. Shenoy again tries to expand and supplement the
`
`disclosure of Lim in a manner that is identical to that described above, and
`
`impermissible under § 102. Shenoy Reply Dec., para. 24; supra at 3. Similarly,
`
`when discussing the ESX reference, Dr. Shenoy states that changed files placed in
`
`a redo log “may be enough to resume execution of an application” and
`
`subsequently engages in a hypothetical discussion regarding Microsoft Notepad.
`
`Shenoy Reply Dec., para. 26. Importantly, nowhere in this discussion does Dr.
`
`Shenoy refer to the ESX reference to provide support for these statements. Nor
`
`could he given that there is no disclosure whatsoever in ESX regarding Notepad,
`
`what would be saved in a redo log for Notepad, or whether the contents of the redo
`
`log are sufficient to resume execution.
`
`As another example pertaining to the ESX reference, Dr. Shenoy states that
`
`the ESX reference discloses copying the redo log while the virtual machine is
`
`5
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`executing. Shenoy Reply Dec., para. 32. However, instead of pointing to any
`
`disclosure in the reference regarding how this can be done, Dr. Shenoy supports his
`
`conclusion by stating that “this could be accomplished with any well-known
`
`copying tools that … a person of ordinary skill in the art would have known.” Id.
`
`Again, Dr. Shenoy’s reliance on such alleged “well-known” tools to fill the gaps in
`
`ESX is clearly an attempt to improperly expand and supplement the disclosure of
`
`this reference.
`
`Petitioner relies on all of the foregoing statements in Dr. Shenoy’s reply
`
`declaration regarding the operation of the ESX product to fill the gaps in the ESX
`
`reference. Reply, pp. 10 and 13. This is impermissible under § 102 and is outside
`
`the scope of the anticipation grounds on which inter partes review was initiated
`
`and instituted. Moreover, it violates the statutory prohibition against relying on
`
`any prior art other than patents and printed publications in the grounds of
`
`rejection. Finally, it is irrelevant in light of the expert’s own admissions that
`
`products operate differently than guides or manuals that purport to describe them.
`
`Shenoy 2nd Dep. 104:5-9.
`
`For the foregoing reasons, Patent Owner moves to exclude the foregoing
`
`portions of Dr. Shenoy’s Reply Declaration as irrelevant and outside the scope of
`
`the grounds on which inter partes review was initiated and instituted, and requests
`
`that the foregoing corresponding statements in the Reply be stricken.
`
`6
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`PETITIONER’S MISCHARACTERIZATION OF PATENT
`OWNER’S EXPERT TESTIMONY
`
`II.
`
`The Reply to Patent Owner’s Response and corresponding Declaration of
`
`Dr. Shenoy mischaracterize the testimony taken during the deposition of Dr. Green
`
`on February 14, 2014. In particular, as stated in patent owner’s objections served
`
`March 2, 3013 (Symantec 2026), these papers include a number of statements that
`
`misrepresent Dr. Green’s testimony, and that rely upon and/or cite to incomplete
`
`portions
`
`of
`
`his
`
`deposition
`
`transcript.
`
`As
`
`a
`
`result,
`
`each
`
`of
`
`these
`
`mischaracterizations, which are addressed separately below,
`
`is confusing,
`
`misleading and far more prejudicial than probative and, therefore, inadmissible
`
`under FRE 403. Additionally, to eliminate any potential confusion regarding Dr.
`
`Green’s testimony, and to ensure a complete and accurate record for the Board,
`
`Patent Owner provides copies of the full testimony of Dr. Green with respect to
`
`each issue below. (Symantec 2027).
`
`For example, the Reply to Patent Owner’s Response incorrectly states that
`
`“Patent Owner’s expert acknowledges that replicating is a type of backup.” See
`
`page 8. To support this statement, Petitioner cites to page 26, lines 19-21 of Dr.
`
`Green’s testimony, which recites:
`
`7
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`As evidenced by this reproduced portion of Dr. Green’s transcript, Dr.
`
`Green stated that replication is a “part of” backup, not that it is a “type of” backup.
`
`In fact, Dr. Green further testified that replication is a technology underlying
`
`backup, which Petitioner wholly ignores. See Dr. Green’s transcript at pg. 26,
`
`lines 12-18 (stating “…I have worked in a number of areas, including content
`
`distribution, which includes the process of
`
`replicating, and copying, and
`
`distributing files across large-scale networks… and so I think those are the basic
`
`underlying technologies behind the computer backup.”) As a result, Petitioner
`
`mischaracterizes Dr. Green’s
`
`testimony regarding the difference between
`
`“replication” and “backup” in an attempt to support its position that the Lim
`
`reference is akin to the backup technology discussed in the ‘086 Patent.
`
`Petitioner’s Reply also cites to Dr. Green’s transcript at page 249, line 22 –
`
`page 251, line 9, and asserts that “Patent Owner’s expert, Dr. Green, confirmed
`
`that claims 1 and 12 are not explicitly limited to backup. Reply at p. 3. Petitioner
`
`further asserts that “[a]fter being confronted with the explicit language of claims 1
`
`and 12, Dr. Green testified that copying only an unspecified portion of the state is
`
`not always sufficient for backup, (i.e., to backup the virtual machine).” Id. Both
`
`of these statements are inaccurate.
`
`As can be seen from this cited portion, however, Dr. Green in no way
`
`suggested that claims 1 and 12 are not explicitly limited to backup.
`
`In fact, Dr.
`
`8
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`Green expressed the opposite opinion. Although Dr. Green acknowledged that
`
`these claims do not explicitly use the term “backup” (see, Dr. Green’s transcript at
`
`page 251, lines 12-16), Dr. Green clearly and unequivocally confirmed his opinion
`
`that claims 1 and 12 are directed to backup. See, e.g., Dr. Green’s Transcript at
`
`page 214, lines 9-11 and page 215, lines 12-16. Notably, Petitioner does not cite
`
`these portions of Dr. Green’s testimony which directly address this issue. Instead,
`
`Petitioner merely cites to testimony in which Dr. Green explains that more than
`
`one byte of information would be needed to perform an effective backup.2
`
`Petitioner attempts to rely on this testimony, without any explanation, as an
`
`admission that
`
`the claims are not
`
`limited to backup.
`
`Thus, Petitioner
`
`mischaracterizes Dr. Green’s testimony and opinions that the claims are directed to
`
`backup.
`
`Furthermore, Dr. Shenoy’s Declaration in Support of the Reply to Patent
`
`Owner’s Response states that the redo log in ESX 1.0 can be transported to a
`
`remote site and copied to a SCSI disk, and that “[t]his could be accomplished with
`
`2 In fact, Dr. Green’s Declaration In Support of Patent Owner’s Reply to
`
`Petitioner’s Opposition states that the portion of the transcript being relied upon by
`
`the Petitioner merely explains that copying a small portion of information (e.g., a
`
`byte) without having previously copied other sufficient information would not be
`
`meaningful for backup purposes. See Symantec 2019, para. 20 on page 15.
`
`9
`
`
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`any of the well-known copying tools that Dr. Green explained a person of ordinary
`
`skill in the art would have known about at the time of the ‘086 invention.” Id., p.
`
`16 (citing Green Dep. Tr. at page 37, lines 14-20 and page 39, line 7 – page 40,
`
`line 3).
`
`Dr. Shenoy’s
`
`statement
`
`implies
`
`that Dr. Green stated, or at
`
`least
`
`acknowledged, that the redo log in ESX 1.0 can be transported using any of the
`
`basic copying tools discussed during Dr. Green’s deposition. This is incorrect.
`
`When read in the proper context, the cited portions of Dr. Green’s testimony
`
`simply provide a general discussion of well-known copying techniques at the time.
`
`Dr. Green did not state, or otherwise acknowledge, that these copying techniques
`
`could be applied in the context of the ESX 1.0, much less for the purpose of
`
`transporting the redo log in ESX 1.0 to a remote site as suggested by Petitioner.
`
`Thus, Dr. Shenoy mischaracterizes Dr. Green’s testimony.
`
`For the foregoing reasons, Patent Owner moves to strike and exclude the
`
`foregoing portions of Petitioner’s Reply and Dr. Shenoy’s Reply Declaration as
`
`confusing, misleading and therefore more prejudicial than probative under FRE
`
`403.
`
`III. CONCLUSION
`
`Patent Owner respectfully requests that its Motion to Exclude be granted.
`
`10
`
`
`
`Date: March 31, 2014
`
`Case IPR 2013-00150
`U.S. Patent No. 7,093,086
`Respectfully submitted,
`
`By: /Joseph J. Richetti, Reg. No. 47024/
`Joseph J. Richetti, Reg. No. 47,024
`BRYAN CAVE LLP
`1290 Avenue of the Americas
`New York, NY 10104
`General Tel: (212) 541-2000
`Direct Tel: (212) 541-1092
`Fax: (212) 541-4630
`Email: joe.richetti@bryancave.com
`Attorney for Patent Owner
`Symantec Corporation
`
`11
`
`
`
`Case IPR2013-00150
`U.S. Patent No. 7,093,086
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing PATENT OWNER
`
`MOTION TO EXCLUDE PURSUANT TO 37 C.F.R. § 42.64(c) was served
`
`electronically via e-mail on March 31, 2014, in its entirety on the following:
`
`Lori A. Gordon
`STERNE, KESSLER, GOLDSTEIN
`& FOX P.L.L.C
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3932
`lgordon-PTAB@skgf.com
`
`Michael Q. Lee
`STERNE, KESSLER, GOLDSTEIN
`& FOX P.L.L.C
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3932
`mlee-PTAB@skgf.com
`
`Respectfully submitted,
`
`By: /Joseph J. Richetti, Reg. No. 47024/
`Joseph J. Richetti
`Lead Attorney for Patent Owner
`Reg. No. 47,024
`BRYAN CAVE LLP
`1290 Avenue of the Americas
`New York, NY 10104
`General Tel: (212) 541-2000
`Direct Tel: (212) 541-1092
`Fax: (212) 541-4630
`Email: joe.richetti@bryancave.com
`
`Attorneys for Patent Owner – Symantec
`Corporation
`
`Date: March 31, 2014
`
`
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