Ex Parte Needham et al

Patent Trial and Appeal Board

Feb 26, 2018

10880301 (P.T.A.B. Feb. 26, 2018)

United States Patent and Trademark Office
UNITED STATES DEPARTMENT OF COMMERCE
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APPLICATION NO. FILING DATE FIRST NAMED INVENTOR ATTORNEY DOCKET NO. CONFIRMATION NO.
10/880,301 06/28/2004 Paul D. Needham 50277-2432 7760
42425 7590 02/28/2018
HTPKMAN PAT F.RMO RFFTCFR RTNOTTAM/OR AFT F
EXAMINER
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PTOL-90A (Rev. 04/07)
UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE PATENT TRIAL AND APPEAL BOARD
Ex parte PAUL D. NEEDHAM and VIKRAM R. PESATI
Appeal 2017-008312
Application 10/880,3011
Technology Center 2100
Before MAHSHID D. SAADAT, JEFFREY S. SMITH, and ERIC B.
CHEN, Administrative Patent Judges.
CHEN, Administrative Patent Judge.
DECISION ON APPEAL
This is an appeal under 35 U.S.C. § 134(a) from the final rejection of
claims 1, 5—17, and 21—32. Claims 2-4, 18—20, and 33—37 have been
cancelled. (App. Br. 2.) We have jurisdiction under 35 U.S.C. § 6(b).
We AFFIRM.
1 Appellants identify Oracle International Corporation as the real party in
interest. (App. Br. 1.)
Appeal 2017-008312
Application 10/880,301
STATEMENT OF THE CASE
Appellants’ invention relates to regulating access to data in a
database, in particular, binding data sensitivity labels to database table
columns so that security policies can be applied at the column level rather
than at the row level. (Abstract.)
Claim 1 below is exemplary, with disputed limitations in italics.
1. A method for regulating access to data, the method
comprising the computer-implemented steps of:
storing metadata that specifies one or more columns and one or
more security labels bound to the one or more columns;
receiving, from a user, a request for access to data stored in a
column of a data table, said column belonging to said one or more
columns;
based on said metadata, looking up a security label bound to
said column, wherein said security label belongs to said one or more
security labels;
accessing a user security clearance of the user;
determining whether said user is permitted to access said data
in said column by comparing said user security clearance to said
security label bound to said column; and
restricting or permitting access to said data in said column to
said user based on said comparing.
Claims 1, 5—17, and 21—32 stand rejected under 35 U.S.C. § 102(e) as
anticipated by Bird (US 2005/0246338 Al; pub. Nov. 3, 2005).
Claims 1, 5, 6, 12—17, 21, 22, and 28—32 stand rejected under 35
U.S.C. § 103(a) as unpatentable over Cotner et al. (US 7,240,046 B2; iss.
July 3, 2007) and Iyengar (US 7,024,409 B2; iss. Apr. 4, 2006).
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Application 10/880,301
Claims 7—11 and 23—27 stand rejected under 35 U.S.C. § 103(a) as
unpatentable over Cotner, Iyengar, and Flyntz (US 7,134,022 B2; iss.
Nov. 7, 2006).2
ANALYSIS
§103 Rejection—Cotner and Iyengar
First, we are unpersuaded by Appellants’ arguments (App. Br. 12; see
also Reply Br. 3) that the combination of Cotner and Iyengar would not have
rendered obvious independent claim 1, which includes the limitation
“security labels.”
The Examiner found that the user table of Cotner, which includes a
security label (SECLABEL) column, as illustrated in Figure 2A, corresponds
to the limitation “security labels.” (Final Act. 13.) We agree with the
Examiner’s findings.
Cotner relates to “providing security in database management
systems.” (Col. 1,11. 8—9.) Figure 2A of Cotner illustrates a conventional
user table in a database management system. (Col. 4,11. 15—16.) Cotner
explains that “[t]he table contains various columns of data, labeled Coll,
Col2, and Col3” and “also includes a security label (SECLABEL) column.”
(Col. 4,11. 17—18.) In particular, Cotner explains that “the security labels are
the names of various colors such as red, blue, yellow, green” and “[e]ach
color name represents a particular set of security privileges associated with
2 Appellants do not present any arguments with respect to the rejection of
claims 7—11 and 23—27 under 35 U.S.C. § 103(a). Thus, any such arguments
are deemed to be waived and we summarily sustain the Examiner’s
rejection.
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Application 10/880,301
the user table row.” (Col. 4,11. 20-24.) Because Cotner explains that
security labels are associated with the user table row, as illustrated in
Figure 2A, Cotner teaches the limitation “security labels.”
Appellants argue that “[t]he privacy metadata of Iyengar is not a
security label” and “[a] security label does not specify a transform.” (App.
Br. 12; see also Reply Br. 3.) However, the Examiner cited to Cotner, rather
than Iyengar, for teaching the limitation “security labels.” (Final Act. 13.)
Thus, we agree with the Examiner that the combination of Cotner and
Iyengar would have rendered obvious independent claim 1, which includes
the limitation “security labels.”
Second, we are unpersuaded by Appellants’ arguments (App. Br. 13—
14) that the combination of Cotner and Iyengar would not have rendered
obvious independent claim 1, which includes the limitation “determining
whether said user is permitted.”
The Examiner found that the read mandatory security unit of Cotner,
which compares the user’s security label to the row’s security label,
corresponds to the limitation “determining whether said user is permitted.”
(Final Act. 14.) We agree with the Examiner’s findings.
Figure 3 of Cotner illustrates database management systems (DBMS)
18, which includes data manager 22 and read mandatory security unit 36.
(Col. 6,11. 43 47.) Cotner explains that when “data manager 22 attempts to
read a row of data from the data storage unit 24, the request is directed
through the read mandatory security unit 36” such “[t]hat security unit
compares a user’s security label passed by the data manager with a security
label associated with the requested row of data in the data storage unit 24.”
(Col. 6,11. 56—62.) Because read mandatory security unit 36 of Cotner
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Application 10/880,301
compares the user’s security label with the requested row of data from data
storage unit 24, Cotner teaches the limitation “determining whether said user
is permitted.”
Appellants argue that “Iyengar may disclose privacy metadata” but
“the mechanism that Iyengar proposes is not used to decide, at the time a
request arrives, whether to allow access.” (App. Br. 13.) However, the
Examiner cited to Cotner, rather than Iyengar, for teaching the limitation
“determining whether said user is permitted.” (Final Act. 14.) Thus, we
agree with the Examiner that the combination of Cotner and Iyengar would
have rendered obvious independent claim 1, which includes the limitation
“determining whether said user is permitted.”
Third, we are unpersuaded by Appellants’ arguments (App. Br. 14—
15) that the combination of Cotner and Iyengar would not have rendered
obvious independent claim 1, which includes the limitation “a request for
access to data.”
The Examiner found that the query processor of Cotner, which
controls the interaction of the data manager with the data repository,
corresponds to the limitation “a request for access to data.” (Final Act. 13.)
We agree with the Examiner’s findings.
Cotner explains that “query processor 20 processes requests
containing queries received at a web site from a client” and that “[bjased on
the query, the query processor 20 controls the data manager 22 to interact
with the data repository 24 to handle the appropriate data satisfying the
query.” (Col. 4,11. 7—14.) Because query processor 20 of Cotner processes
requests containing queries received from the client, Cotner teaches the
limitation “a request for access to data.”
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Appellants argue that “the mechanism that Iyengar proposes regards
imagined future querying and is not used to decide, when a query arrives,
whether to allow access” (App. Br. 14) and “[s]uch imaginary usage is
insufficient, because it does not enable determining whether to permit access
to particular data identified by a particular request” {id. at 14—15). However,
the Examiner cited to Cotner, rather than Iyengar, for teaching the limitation
“a request for access to data.” (Final Act. 13.) Thus, we agree with the
Examiner that the combination of Cotner and Iyengar would have rendered
obvious independent claim 1, which includes the limitation “a request for
access to data.”
Last, we are not persuaded by Appellants’ arguments (App. Br. 15—
16) that the Examiner improperly combined Cotner and Iyengar.
The Examiner found that the metadata of Iyengar, which includes
information about data in the columns that should be suppressed due to
privacy concerns, corresponds to the limitation “storing metadata that
specifies one or more columns.” (Final Act. 14—15.) The Examiner
concluded that “[i]t would have been obvious ... to combine Cotner’s
method of providing secure access to data stored in table utilizing security
labels with Iyengar’s ability to utilize metadata comprising information
about columns and the privacy constraints associated with columns to
abstract or suppress access to column data.” {Id. at 15.) We agree with the
Examiner’s findings and conclusions.
Iyengar relates to managing data, in particular, “transforming data in a
manner that satisfies predetermined privacy constraints.” (Col. 1,11. 17—19.)
Figure 2 of Iyengar illustrates two components of data 20, which include
meta-data 21 and tabular data 22. (Col. 4,11. 10-12.) Iyengar explains that
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Application 10/880,301
“meta-data 21 comprises information about the input data” that “includes the
name and type of information in each column” (col. 4,11. 49—51) and “meta­
data also comprises information on which columns are potentially
identifying and need to be abstracted or suppressed according to privacy
constraints” (col. 4,1. 67 to col. 5,1. 3). Iyengar also explains that “in
tabular data where each row represents an individual, and one or more
columns comprise explicitly identifying information (e.g., social security
numbers), the identifying information can be suppressed.” (Col. 1,11. 54—
57.)
A person of ordinary skill in the art would have recognized that
incorporating the metadata of Iyengar for providing the type of information
in each column, with the user table of Cotner, would improve Cotner by
identifying information subject to privacy constraints. See KSR Int’l Co. v.
Teleflex Inc., 550 U.S. 398, 417 (2007). Thus, we agree with the Examiner
(Final Act. 15) that modifying Cotner to incorporate the metadata of Iyengar
would have been obvious.
Appellants argue that “[t]he combination of Cotner and Iyengar would
compare a user security clearance to a transform that replaces characters,
which is an invalid comparison” (App. Br. 15—16) and “[a]s combined,
Cotner would decide access based on an invalid comparison, which would
not achieve the intended purpose of Cotner’'’ {id. at 16). However, the
Examiner’s articulated rationale for combining Cotner and Iyengar is based
upon modifying the user table Cotner by incorporating the metadata of
Iyengar, rather than incorporating the feature of data transformation to mask
privacy. (Final Act. 14—15.) Therefore, the Examiner has properly
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combined Cotner and Iyengar to reject independent claim 1 under 35 U.S.C.
§ 103(a).
Accordingly, we sustain the rejection of independent claim 1 under 35
U.S.C. § 103(a). Claims 5, 6, and 12—16 depend from claim 1, and
Appellants have not presented any additional substantive arguments with
respect to these claims. Therefore, we sustain the rejection of claims 5, 6,
and 12—16 under 35 U.S.C. § 103(a), for the same reasons discussed with
respect to independent claim 1.
Independent claim 17 recite limitations similar to those discussed with
respect to independent claim 1, and Appellants have not presented any
additional substantive arguments with respect to these claims. We sustain
the rejection of claim 17, as well as dependent claims 21, 22, and 28—32, for
the same reasons discussed with respect to claim 1.
§102 Rejection—Bird
We do not reach the rejection of claims 1, 5—17, and 21—32 under
35 U.S.C. § 102(e) as anticipated by Bird. Affirmance of the rejection
discussed previously renders it unnecessary to reach the remaining
rejections, as all of pending claims have been addressed and found
unpatentable. Cf. In re Gleave, 560 F.3d 1331, 1338 (Fed. Cir. 2009) (not
reaching additional obviousness rejections).
DECISION
The Examiner’s decision rejecting claims 1, 5—17, and 21—32 is
affirmed.
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No time period for taking any subsequent action in connection with
this appeal may be extended under 37 C.F.R. § 1.136(a)(l)(iv).
AFFIRMED
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