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Case No. IPR2019-00491
`U.S. Patent No. 8,301,906
`
`
`Preliminary Chart showing Obviousness of U.S. Patent No. 8,301,906 (“the ’906
`patent”) over U.S. Patent No. 7,020,835 (“Loaiza”) in view of U.S. Patent No.
`7,937,404 (“Tripathi”) and in further view of U.S. Patent No. 6,963,976 (“Jutla”).
`
`
`Patent Claim
`2. The apparatus of claim 1,
`further comprising an
`encryptor for encrypting the
`checksum information to
`obtain an integrity
`information, the encryption
`being based on an encryption
`key and wherein the writer is
`adapted for writing the
`integrity information and
`control information on a
`physical or logical location
`of the integrity information
`to the storage medium.
`
`Invalidity Support
`This element is disclosed by the combination of
`Loaiza in view of Tripathi, in further view of
`Jutla. EX1002 at ¶95. For example, Jutla
`discloses a method of encrypting plain-text
`messages by dividing the message into plain-text
`block of data and encrypting the blocks to form
`cipher-text blocks; a message integrity check is
`embedded into the cipher-text block itself. See
`EX1008, 2:11-16. Jutla specifically discloses
`encryption of the checksum information. See
`EX1008, 8:36-38, 42-43 (“In some embodiments
`of the method for encrypting a plain-text message
`the step of encrypting the plain-text blocks
`includes … and/or the step of encrypting includes
`encrypting the check sum…”); see also EX1008,
`20:63-64 (“15. A method as recited in claim 1,
`wherein the step of encrypting includes
`encrypting said check sum.”). Thus, a
`combination of Loaiza with Jutla would add the
`additional function of encrypting the checksums
`with an encryption key. EX1008, 13:23-25
`(showing a private key using the notation x {0,
`1}n); EX1002 at ¶95-96. Therefore, the claim
`element “an encryptor for encrypting the
`checksum information to obtain an integrity
`information, the encryption being based on an
`encryption key” is disclosed, or at least rendered
`obvious, by the combination of Loaiza with Jutla.
`
`With respect to the claim phrase “wherein the
`writer is adapted for writing the integrity
`information and control information on a physical
`or logical location of the integrity information to
`
`
`
`1
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`Unified Patents
`EX1010
`Page 1 of 3
`
`

`

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`
`
`Case No. IPR2019-00491
`U.S. Patent No. 8,301,906
`
`the storage medium,” Loaiza generates a
`checksum from a block of data. See EX1006,
`3:27-29 (“According to one technique, a physical
`checksum calculation is performed on a block of
`data.”). Loaiza discloses that the checksum is
`stored on a storage medium. See EX1006, 6:9-12
`(“In one embodiment, prior to causing a block of
`data to be written to data storage unit 112,
`application 204 initiates a physical checksum
`calculation process 220 to generate a checksum
`value for inserting into the data block.” ); Fig. 2;
`8:62-65; see also EX1006, 16:21-24 (“The
`method as recited in claim 5, further comprising
`storing, in association with the data block,
`checksum data used in the physical checksum
`verification to the nonvolatile memory.” (claim
`6)). Thus, Loaiza discloses a writer for writing
`the checksum information. See EX1002 at ¶¶75,
`77. In the combination of Loaiza with Jutla,
`where the checksum has been encrypted, the
`encrypted checksum would be written to the
`storage medium in the same way disclosed in
`Loaiza. EX1002 at ¶95. With respect to the claim
`sub-phrase “writing” “control information on a
`physical or logical location” “to the storage
`medium” this term is disclosed by the
`combination of Loaiza and Tripathi. As discussed
`in more detail in claim 1, a PHOSITA would
`know to replace the data file of Tripathi with a
`checksum as generated by Loaiza, such that the
`metadata comprises at least one logical address
`pointing to the checksum and one logical address
`pointing to the data block. See EX1002 at ¶¶74,
`81.
`
`Thus, the use of encrypting a checksum to obtain
`an integrity information (that is, to ensure
`integrity of the data) was well known in the art
`prior to the time of the purported invention of the
`
`2
`
`Unified Patents
`EX1010
`Page 2 of 3
`
`

`

`
`
`
`
`
`
`Case No. IPR2019-00491
`U.S. Patent No. 8,301,906
`
`’906 patent, as was writing that encrypted
`information to the storage medium. EX1002 at
`¶¶95-96. Therefore, this claim is disclosed, or at
`least rendered obvious, by the combination of
`Loaiza and Tripathi in further view of Jutla.
`
`3
`
`Unified Patents
`EX1010
`Page 3 of 3
`
`

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