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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`VMWARE, INC.,
`Petitioner,
`v.
`CIRBA IP, INC.,
`Patent Owner.
`_______________
`Case: PGR2021-00098
`Patent: 10,951,459
`____________________________________________________________
`DECLARATION OF DR. EREZ ZADOK, PH.D.
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`
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`TABLE OF CONTENTS
`Qualifications ................................................................................................... 2
`I.
`II. Materials Considered ..................................................................................... 12
`III. Understanding of Relevant Legal Principles ................................................. 12
`Claim Construction Standard .............................................................. 12
` Written Description ............................................................................. 13
`IV. Background .................................................................................................... 14
`Technical Background ......................................................................... 14
`Overview of the ’459 Patent ................................................................ 18
`1.
`System Parameters .................................................................... 20
`2.
`Compatibility Analyses ............................................................. 21
`3.
`Consolidation Analyses ............................................................ 23
`4.
`Visualization ............................................................................. 26
`5.
`Summary of the ’459 Patent Prosecution History .................... 26
`Level of Skill in the Art ................................................................................. 28
`V.
`VI. Claim Construction ........................................................................................ 29
`VII. The ’459 Patent Specification Does Not Describe Claims 1-63 Such That a
`POSITA Would Understand the ’459 patent Inventors Were in Possession of
`the Claimed Systems, Methods, or Computer Readable Medium ................ 30
`“Already Placed” ................................................................................. 30
`1.
`Analysis Types .......................................................................... 32
`1-to-1 Compatibility Analysis................................................... 32
`N-to-1 Compatibility Analysis .................................................. 33
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`i
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`N-by-N Compatibility Analysis ................................................ 33
`Consolidation Analysis ............................................................. 34
`“Source System” ....................................................................... 35
`2.
`“Issue Instructions” ............................................................................. 37
`Incorporated Applications ................................................................... 41
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`
`
`ii
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`1. My name is Erez Zadok. I have been retained by Petitioner VMware
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`Inc. (“Petitioner” or “VMware”) to assist regarding U.S. Patent No. 10,951,459
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`(Ex. 1001, “the ’459 patent”). Specifically, I have been asked to consider the
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`patentability of claims 1-63 of the ’459 patent (“the Challenged Claims”) in view of
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`prior art and the understanding of a person of ordinary skill in the art (“POSITA”)
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`as it relates to the ’459 patent. I understand that my opinions in this declaration are
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`being submitted as part of the petition in PGR2021-00098. Additionally, I
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`understand two other of my declarations that address the same claims of the ’459
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`patent will be submitted in connection with two IPR petitions (IPR2021-01210 and
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`IPR2021-01211).
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`2.
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`I have personal knowledge of the facts and opinions set forth in this
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`declaration and believe them to be true. If called upon to do so, I would testify
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`competently thereto. I have been warned that willful false statements and the like
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`are punishable by fine or imprisonment, or both.
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`3. My consulting company, Zadoks Consulting, LLC,
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`is being
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`compensated for my time at my standard consulting rate. I am also being reimbursed
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`for expenses that I incur during the course of this work. My compensation is not
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`contingent upon the results of my study and analysis, the substance of my opinions,
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`or the outcome of any proceeding involving the Challenged Claims. I have no
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`financial interest in the outcome of this matter or in any litigation involving the ’459
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`patent.
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`I.
`
`Qualifications
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`4.
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`I am a Professor in the Computer Science Department at Stony Brook
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`University (part of the State University of New York (“SUNY”) system). I direct
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`the File-systems and Storage Lab (FSL) at Stony Brook’s Computer Science
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`Department. My research interests include file systems and storage systems,
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`operating systems, information technology and system administration, security and
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`information assurance, networking, energy efficiency, performance and
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`benchmarking, virtualization, compilers, applied machine learning, and software
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`engineering.
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`5.
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`I studied at a professional high school in Israel, focusing on electrical
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`engineering (“EE”), and graduated in 1982. I spent one more year at the high
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`school’s college division, receiving a special Certified Technician’s degree in EE. I
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`then went on to serve in the Israeli Defense Forces for three years (1983-1986). I
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`received my Bachelor of Science degree in computer science (“CS”) in 1991, my
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`Master’s degree in CS in 1994, and my Ph.D. in CS in 2001—all from Columbia
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`University in New York.
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`6. When I began my undergraduate studies at Columbia University, I also
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`started working as a student assistant in the various campus-wide computer labs,
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`eventually becoming an assistant to the head labs manager, who was managing all
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`public computer labs on campus. During that time, I also became more involved
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`with research within the CS Department at Columbia University, conducting
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`research on operating systems, file and storage systems, distributed and networked
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`systems, security, and other topics. I also assisted the CS department’s computer
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`administrators in managing the department’s computers, which included storage, IT,
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`networking, and cyber-security related duties.
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`7.
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`In 1991, I joined Columbia University’s CS department as a full-time
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`systems administrator, studying towards my MS degree part-time. My MS thesis
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`topic related to file system reliability, fault tolerance, replication, and failover in
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`mobile networked storage systems using file virtualization. My main duties as a
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`systems administrator involved installing, configuring, and managing many
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`networked servers, proxies, and desktops running several operating systems, as well
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`as network devices setup; this included many hardware upgrades, device upgrades,
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`and BIOS firmware/chipset updates/upgrades. My duties also included ensuring
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`reliable, secure, authenticated access to networked systems/storage and licensed
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`software, as well as software updates, security and bug fixes. Examples of servers
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`and their protocols included email (SMTP), file transfer (FTP), domain names
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`(DNS), network file systems (NFS), network news systems (NNTP), and Web
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`(HTTP).
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`8.
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`In 1994, I left my systems administrator position to pursue my doctoral
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`studies at Columbia University. My Ph.D. thesis topic was on versatile file system
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`development using stackable (virtualized) file systems, with examples in the fields
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`of security and encryption, efficiency, reliability, and failover. I continued to work
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`part-time as a systems administrator at the CS department, and eventually I was
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`asked to serve as manager to the entire information technology (“IT”) staff. From
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`1991 to 2001, I was a member of the faculty-level Facilities Committee that oversaw
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`all IT operations at the CS department.
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`9.
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`As part of my Ph.D. studies at Columbia, I collaborated on projects to
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`develop advanced AI-like techniques to detect previously unknown viruses (a.k.a.
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`“zero-day malware”), using data mining and rule-based detection. This work led to
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`several highly cited papers (over 1,300 citations for one of the papers alone), and
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`two patents. I also became a Teaching Assistant (TA) for a first-ever Computer
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`Security course given at Columbia University’s CS department with Dr. Matt Blaze
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`as instructor.
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`10. From 1990 to 1998, I consulted for SOS Corporation and HydraWEB
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`Technologies, as a systems administrator and programmer, managing data storage
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`use and backup/restore duties, as well as information assurance and cyber-security
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`(e.g., malware protection, software licensing). From 1994 to 2000, I led projects at
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`HydraWEB Technologies, and then became the Director of Software Development-
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`overseeing the development of several products and appliances such as stateful
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`firewalls and HTTP load-balancers, utilizing network-virtualization and high-
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`availability techniques. Since 2009, I have consulted for Packet General Networks,
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`a startup specializing in secure, virtualized, network storage and applications’ data
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`security in the cloud.
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`11.
`
`In 2001, I joined the faculty of Stony Brook University, a position I
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`have held since that time. In 2002, I joined the Operations Committee, which
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`oversees the IT operations of the CS department at Stony Brook University. From
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`2006 to 2010, I was the Director of IT Operations of the CS department; my day-to-
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`day duties included setting policies regarding computing, hiring and training new
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`staff, assisting any staff with topics of my specialty, defining requirements for new
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`software/hardware, and purchasing. From 2010 to 2015, I have served as the Co-
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`Chair to the Operations Committee. From 2016 to 2019, I oversaw the IT Operations
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`as the Chair of the Operations Committee. A significant component of these duties
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`included defining and helping implement policies for data management, so as to
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`ensure the security of users and their data, and data reliability and availability, while
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`minimizing the inconvenience and performance impact to users. I personally helped
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`setup and maintain an initial virtual host infrastructure in the department. Since late
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`2019, I’ve been a member of the department’s Executive Committee that also
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`oversees all IT operations.
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`12.
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`In 2017, I became the department’s Graduate Academic Adviser,
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`advising all Masters students (over 400 annually on average) and many other
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`graduate students on an assortment of academic matters.
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`13. Since 2001, I personally configured and managed my own research
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`lab’s network. This includes setting up and configuring multiple storage systems
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`(e.g., NFS, CIFS/SMB, NAS), virtual and physical environments, applications such
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`as database and mail servers, user access control (e.g., NIS, LDAP), backups and
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`restores, snapshot policies, and more. I’ve personally installed, configured, changed,
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`replaced parts, and upgraded components in numerous devices from laptops to
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`servers, both physical and virtual.
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`14. Since 1995, I have taught courses on operating systems, storage and file
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`systems, advanced systems programming in Unix/C, systems administration, data
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`structures, data/software security, and more. My courses often use storage, file
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`systems, distributed systems, and system/network security as key teaching principles
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`and practical examples for assignments and projects. I have taught these concepts
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`and techniques to my students, both to my direct advisees as well as in my courses.
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`For example, in my graduate Operating Systems course, I often cover Linux’s kernel
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`mechanisms to protect users, applications, and data files, as well as distributed
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`storage systems (e.g., NFS). And in the System Administration undergraduate
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`course, I covered many topics such as networking, storage, backups, and configuring
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`complex applications such as mail, web, and database servers.
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`15. My research often investigates computer systems from many angles:
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`security, efficiency, energy use, scalability, reliability, portability, survivability,
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`usability, ease-of-use, versatility, flexibility, and more. My research gives special
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`attention to balancing five often-conflicting aspects of computer systems:
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`performance, reliability, energy use, security, and ease-of-use. Since joining Stony
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`Brook University in 2001, my group in the File-systems and Storage Lab (FSL) has
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`developed many file systems and operating system extensions; examples include a
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`highly-secure cryptographic file system, a portable copy-on-write (COW)
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`versioning file system, a tracing file system useful to detect intrusions, a replaying
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`file system useful for forensics, a snapshotting and sandboxing file system, a
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`namespace unification file system (that uses stackable, file-based COW), an anti-
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`virus file system, an integrity-checking file system, a load balancing and
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`replication/mirroring file system, network file system extensions for security and
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`performance, distributed secure cloud-based storage systems, transactional key-
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`value stores and file systems, OS level embedded databases, a compiler to convert
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`user-level C code to in-kernel efficient yet safe code, GCC plugins, stackable file
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`system templates, and a Web-based backup system. Many of these projects used
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`one form of virtualization or another (storage, network, host, etc.). I continue to
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`maintain and release newer versions of some of these file systems and software.
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`16.
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`I have published over 120 refereed publications (in ACM, IEEE,
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`USENIX, and more). To date, my publications have been cited more than 8,700
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`times (as per Google Scholar as of June 21, 2021). My papers cover a wide range
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`of related technologies such as file systems, storage systems, transactional systems,
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`security, performance benchmarking and optimization, energy efficiency, system
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`administration, and more. I also published a book titled “Linux NFS and
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`Automounter Administration” (Sybex, 2001), covering systems administration
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`topics related to network storage and data security.
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`17. Some of my research has led to public software releases that have been
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`used worldwide. I have publicly maintained the Amd Berkeley Automounter in a
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`package called “am-utils” since 1992; this software helps administrators manage the
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`multitude of file system mounts on dozens of different Unix systems, especially
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`helping to automate access to multiple NFS/NAS storage volumes. Since 1997, I
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`have maintained and released several stackable (virtualized) file system software
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`projects for Linux, FreeBSD, and/or Solaris, in a package called FiST. One of my
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`stackable file system encryption projects, called Cryptfs, became the basis for IBM’s
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`public release of eCryptfs, now part of Linux. Packet General Networks, for whom
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`I have provided consulting services since 2009, licensed another encryption file
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`system called Ncryptfs. Another popular file system released in 2003, called
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`Unionfs, offers virtual namespace unification, transparent shadow copying (a.k.a.
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`copy-on-write or COW), file system snapshotting (e.g., useful for forensics and
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`disaster recovery), and the ability to save disk space by sharing a read-only copy of
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`data among several computers, among other features.
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`18. My research and teaching make extensive use of data security features.
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`For example, each time I taught the graduate operating system course, the first
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`homework assignment includes the creation of a new system call that performs new
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`or added functionality, often for encrypting a file or verifying its integrity; many of
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`my other assignments cover topics of user/process access control, anti-virus filtering,
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`and more. Since 2001, over 1,000 graduate students were exposed to these simple
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`principles directly through my teaching and research at Stony Brook University.
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`19. Moreover, in an undergraduate course titled “Advanced Systems
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`Programming in Unix/C,” I cover many topics of system security and vulnerabilities,
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`such as the structure of UNIX processes, and memory segments such as the heap and
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`stack. Often, the first assignment for this course is to develop a tool to
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`encrypt/decrypt files using advanced ciphers, use digital signatures to certify the
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`cipher keys used, and reliably recover files in case of failures. Since 2001, several
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`hundred undergraduate students were exposed to these principles directly through
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`my teaching and research at Stony Brook University.
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`20.
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`In another undergraduate course, System Administration, I taught
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`network configuration, security, and storage configuration and reliability. In a
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`special topics course on Storage Systems, I covered many topics such as data
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`deduplication, RAID, transactional storage, storage hardware including modern
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`Flash based ones, virtual storage, backup/restore, snapshots and continuous data
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`protection (CDP), NAS and SAN, and NFS.
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`21. Overall , in addition to the aforementioned experience, my technical
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`experience relevant to this patent at the time of the alleged invention included the
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`following: configuring and running hypervisors on Linux, Windows, and Mac OS
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`X; experimenting with and/or using products from VMware (ESX, GSX, Fusion,
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`Workstation), Sun Microsystems (VirtualBox), Linux (open-source Xen and KVM),
`
`and others (e.g., Parallels); installed and ran numerous virtual machines (VMs) on
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`these hypervisors, setup storage backends, configured and executed VM migration,
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`manually load-balanced and consolidated VMs and hosts, evaluated hardware
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`capabilities of hosts and VMs, and optimized my VM clusters. I’ve also studied,
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`researched, taught and published on topics of operating system and storage system
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`optimizations using complex algorithms.
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`22. My research has been supported by many federal and state grants as
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`well as industry awards, including an NSF CAREER award, two IBM Faculty
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`awards, two NetApp Faculty awards, a Western Digital award, a Facebook award,
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`several Dell-EMC awards, and several equipment gifts. I was the winner of the 2004
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`Computer Science Department bi-annual Graduate Teaching Award, the winner of
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`the 2006 Computer Science Department bi-annual Research Excellence Award, and
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`a recipient of the 2008 SUNY Chancellor’s Excellence in Teaching award (an award
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`that can be given only once a lifetime).
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`23. My service record to the community includes being the co-chair for the
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`USENIX Annual Technical Conference in 2020 (ATC’20); being the co-chair for
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`USENIX File and Storage Technologies (FAST) in 2015 and being on the FAST
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`Steering Committee since 2015; joining the ACM HotStorage Steering Committee
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`in 2021; and being the co-chair in 2012 and on the Steering Committee of the ACM
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`SYSTOR conference. I have also been an Associate Editor to the ACM Transactions
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`on Storage (TOS) journal since 2009.
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`24.
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`I am a named inventor on four patents, two titled “Systems and Methods
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`for Detection of New Malicious Executables” (U.S. Patent No. 7,487,544, issued
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`February 3, 2009; and U.S. Patent No. 7,979,907, issued July 12, 2011); and two
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`more titled “Multi-Tier Caching,” (U.S. Patent No. 9,355,109, issued May 31, 2016;
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`and U.S. Patent 9,959,279, issued May 1, 2018).
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`25.
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`I have been disclosed as a testifying expert in 13 cases (including inter
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`partes review (IPR) proceedings) in the past four years. I have been deposed 11
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`times and testified in trial twice. A complete copy of my curriculum vitae, which
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`includes a list of my publications and contains further details on my education,
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`experience, publications, patents, and other qualifications to render an expert
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`opinion, is attached as Exhibit 1007.
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`II. Materials Considered
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`26.
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`In performing my analysis and forming the opinions below, I
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`considered the ’459 patent, its prosecution history, the applications that it
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`incorporates by reference, and the materials listed as exhibits to the petition in (this)
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`PGR2021-00098.
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`III. Understanding of Relevant Legal Principles
`
`27.
`
`I am not a lawyer, and I will not provide any legal opinions. Rather, I
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`have been asked to provide my technical opinions based on how a person of ordinary
`
`skill in the art would have understood the claims of the ’459 patent, in light of its
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`disclosure and prosecution history, as of the patent’s priority date. Although I am
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`not a lawyer, I have been advised that certain legal standards are to be applied by
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`technical experts in forming opinions regarding the meaning and validity of patent
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`claims.
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` Claim Construction Standard
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`28.
`
`I understand that claim terms are given their ordinary and customary
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`meaning, as would be understood by a person of ordinary skill in the relevant art in
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`the context of the patent’s entire disclosure and prosecution history. A claim term,
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`however, will not receive its ordinary meaning if the patentee acted as his own
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`lexicographer and clearly set forth a definition of the claim term in the specification.
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`In that case, the claim term will receive the definition set forth in the patent.
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`29. The face of the ’459 patent claims priority to a series of applications,
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`the earliest of which was filed April 21, 2006. As I explain below, none of the
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`applications in this priority chain provide written description support to the
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`challenged claims. I understand that this means the ’459 patent’s priority date is its
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`November 19, 2019 filing date. Even if, however, an earlier priority date—up to
`
`and including the earliest April 21, 2006 date listed on the face of the ’459 patent—
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`were considered for purposes of determining the level of ordinary skill in the art and
`
`interpreting the ’459 patent, my opinions below would not change.
`
` Written Description
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`30.
`
`I have been informed that 35 U.S.C. § 112 requires patents to contain
`
`an adequate written description of the claimed invention. I understand that the
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`purpose of the written description requirement is to demonstrate that the inventor
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`was in possession of the invention at the time the patent application was filed, even
`
`though subsequently the claims may have been changed or new claims may have
`
`been added. I understand that this requirement is met if, at the time of filing the
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`patent application, a person of ordinary skill in the art reading that application would
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`have recognized that it described the invention as claimed. I understand that the
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`application does not need to specifically disclose a claim limitation as long as a
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`person of ordinary skill in the art would understand that the missing requirement is
`
`necessarily implied in the application as originally filed. I understand that the
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`written description inquiry must take into account the entirety of what is disclosed
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`within the specification. I understand that it is insufficient that undisclosed subject
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`matter would have been obvious to a person of ordinary skill in the art.
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`IV. Background
`
` Technical Background
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`31. To carry out their day-to-day operations, businesses and other
`
`organizations typically require an information technology (“IT”) infrastructure to
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`provide computing and data processing services. IT infrastructures frequently
`
`include one or more “data centers,” where computing and networking equipment is
`
`concentrated for the purpose of collecting, storing, processing, or permitting access
`
`to data, software, or other computing resources. (Ex. 1013 (Wood) at p. 229 (“Data
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`centers—server farms that run networked applications—have become popular in a
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`variety of domains such as web hosting, enterprise systems, and e-commerce
`
`sites.”).)
`
`32.
`
`In the early days of computing, such a data center might have contained
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`a single, powerful “mainframe” computer with enough resources to store large
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`amounts of data and provide services to the organization’s users. But as computing
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`equipment got smaller and cheaper, organizations began to replace these large
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`monolithic mainframe computers with compute “clusters” made up of many
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`(hundreds or even thousands of) smaller, cheaper computer servers, networked
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`together. (Ex. 1014 (Baker) at p. 1 (“there has been a dramatic shift from mainframe
`
`or ‘host-centric’ computing to a distributed ‘client-server’ approach” due to “the
`
`realisation that clusters of high−performance workstations can be realistically used
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`for a variety of applications either to replace mainframes, vector supercomputers and
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`parallel computers or
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`to better manage already
`
`installed collections of
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`workstations.”).)
`
`33. Like the monolithic mainframe had, the cluster would provide users
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`with the perception of single computing resource. (Ex. 1020 (PlateSpin) at p. xxiv
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`(“Clustering allows several physical machines to collectively host one or more
`
`virtual servers.”).) Users could connect to that resource over a network to access
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`data and computing services as before. (Ex. 1020 (PlateSpin) at p. xxiv (“With
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`clustering, clients won’t connect to a physical computer but instead connect to a
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`logical virtual server running on top of one or more physical computers.”).)
`
`34. As data centers grew and changed over time, one problem that arose is
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`“server sprawl.” (Ex. 1018 (Khanna) at Abstract, p. 373 (“As businesses have
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`grown, so has the need to deploy I/T applications rapidly to support the expanding
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`business processes. Often, this growth was achieved in an unplanned way,” which
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`“has led to what is often referred to as ‘server and storage sprawl’, i.e., many
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`underutilized servers, with heterogeneous storage elements.”).)
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`35. Over time, as data centers grew, they frequently came to include “an
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`increasingly complex mixture of server platforms, hardware, operating systems, and
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`applications.” (Ex. 1020 (PlateSpin) at p. 505.) But as new servers and software
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`were added, it quickly became difficult to track them all and to ensure that they
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`remained sufficiently utilized. (Ex. 1020 (PlateSpin) at p. 513 (“Today’s data center
`
`is riddled with production servers that are underutilized and that therefore represents
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`a large amount of potential savings”).) For example, legacy technologies persisted
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`long after they were no longer needed, and underutilized servers imposed significant
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`unnecessary cost in terms of power, temperature conditioning, floor space, licensing,
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`and other costs of maintenance and ownership. (Ex. 1020 (PlateSpin) at p. 505
`
`(“Data centers have accumulated and assimilated a large variety of new technologies
`
`that over time have become ‘legacy’ technologies that never go away” and they
`
`“collectively increase data center costs because of power consumption, temperature
`
`conditioning, and floor space.”).)
`
`36.
`
`In light of the above issues, before the ’459 patent’s earliest priority
`
`date, the advantages of server consolidation were well-known. For example, a patent
`
`assigned to IBM and filed in June 2005 recognized the importance of consolidation
`
`analysis and the cost benefits of consolidation:
`
`
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`It was also known that in some cases where the customer
`is currently using two or more of its own servers, these
`can be consolidated into one dedicated server in an “on
`demand” or “utility” model. For example, if the customer
`was only using a small percentage of the capacity of its
`current servers, these may be consolidated into one vendor
`server of similar or equal power in an “on demand” or
`“utility” model. The cost savings result from a reduction
`in (a) number of operating systems, (b) virtual memory,
`(c) real memory, (d) swap disk space, (e) system manage-
`ment software licenses, (f) customer application software
`licenses, (g) systems administration and support, (h) floor
`space, and/or (i) electricity and cooling costs.
`
`
`(Ex. 1015 (Taylor) at 2:1-13 (emphases added); see also 11:43-15:5 referring to Figs.
`
`4(A)-(E) describing a program that “determines whether two customer servers can
`
`be consolidated into one vendor server.”) Similarly, there were known techniques
`
`for “costing and planning the consolidation of multiple source server computers or
`
`other source computer hardware devices to fewer target server computers or other
`
`target hardware devices.” (Ex. 1016 (Power) at 3:22-26.) And others were
`
`describing how to identify “different possible configurations [of communications
`
`systems] that consolidate some or all of two or more of servers in the system.” (Ex.
`
`1017 (Van Hoose) at Abstract).)
`
`37.
`
`It also was well-known that one way to combat server sprawl is by using
`
`virtualization to perform “server consolidation.” (Ex. 1019 (Menascé) at p. 1
`
`(“Virtualization may be used for server consolidation”); Ex. 1020 (PlateSpin) at p.
`
`505 (“server virtualization alleviates the complexity of the data center to some extent
`
`
`
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`through consolidation”).) Server consolidation refers to the process of converting
`
`some physical machines into VMs and consolidating those VMs onto remaining
`
`physical machines, which act as hosts. (See Ex. 1018 (Khanna) at pp. 373-74
`
`(illustrating five steps of “a simple algorithm for server consolidation” using
`
`virtualization).)
`
` Overview of the ’459 Patent
`
`38.
`
`I have reviewed the overview of the ’459 patent from the corresponding
`
`petition and incorporate it below.
`
`39. The ’459 patent presents techniques for calculating “consolidation
`
`solutions” that can allegedly improve the efficiency of a computing environment
`
`with multiple computer systems. (’459 patent at 2:5-13, 2:66-3:10.) Specifically,
`
`these consolidation solutions are recommendations on where to move existing
`
`applications and data from certain systems (called “source systems”) to other
`
`systems (called “target systems”) in order to reduce the number of systems in the
`
`overall environment. (’459 patent at 5:16-24, 5:55-64, 6:35-51, 8:17-25.)
`
`40. The ’459 patent explains that a “system” can be a “physical system,” a
`
`“virtual system,” or a “hypothetical system” (i.e., a system that does not currently
`
`exist in the environment but is useful for analyzing hypothetical situations). (’459
`
`patent at 5:65-6:10.) According to the ’459 patent, managing an environment with
`
`many of these systems presents challenges in “optimizing efficiency” and
`
`
`
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`“avoid[ing] redundancies and/or under-utilized hardware.” (’459 patent at 1:47-52.)
`
`For example, a sub-optimal environment may include “additional hardware” with
`
`“separate maintenance considerations” that require costly “incidental attention[.]”
`
`(’459 patent at 1:63-67.) Too many systems means that “[h]eat production and
`
`power consumption can also be a concern.” (’459 patent at 1:67-2:1.)
`
`41. The ’459 patent discloses analytical techniques that purportedly address
`
`these problems by calculating “roadmaps” for efficiently reducing the number of
`
`systems. (’459 patent at 5:16-24.) The roadmaps identify “source” systems, “from
`
`which applications and/or data are to be moved,” and “target” systems, “to which
`
`applications and/or data are to be moved.” (’459 patent at 5:57-60, 6:46-51.) Thus,
`
`for example, “an underutilized environment having two systems [] can be
`
`consolidated to a target system (one of the syst