1. Katayama does not disclose “moving the new data segment

from the cache memory to the next available space within

primary memory.”…………………………………………….31

2. Katayama does not disclose “storing the data segments to

primary memory in a manner consistent with an industry

standard data storage format while retaining linking between

data segments created in previous steps.”…………………….34

3. Mills discloses almost none of the elements of claim 1 of the

’108 patent……………………………………………………35

a. Mills does not disclose “creating the primary memory

from a non-volatile, long-term storage medium” as

contemplated by the inventors…………………………36

b. Mills does not disclose “storing the data segments to

primary memory in a manner consistent with an industry

standard data storage format while retaining linking

between data segments created in the previous

steps.”………………………………………………….38

C. Petitioners fail to offer any meaningful analysis as to why the

combination of Katayama and Mills would have been obvious to one

of ordinary skill in the art at the time of the invention……………...41

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