PTAB

IPR2016-00373

Oracle America Inc v. Realtime Data LLC

Log In
Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Content Independent Data Compression Method and System
  • Brief Description: The ’992 patent is directed to systems for analyzing incoming data blocks to identify their data type and then selecting and applying an appropriate compression method. If a data type is not recognized, a default compression method is used.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hsu and Franaszek - Claim 48 is obvious over Hsu in view of Franaszek.

  • Prior Art Relied Upon: Hsu (“Automatic Synthesis of Compression Techniques for Heterogeneous Files,” a 1995 journal article) and Franaszek (Patent 5,870,036).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hsu, a reference not previously considered by the examiner, taught every limitation of claim 48 except for the use of a "default encoder." Specifically, Hsu disclosed a system that analyzes the actual content within a data block—not just an appended descriptor—to determine its data type and select an optimal compression algorithm. This, Petitioner asserted, met the key limitation added during reexamination ("wherein the analyzing... excludes analyzing based only on a descriptor"). Franaszek, which was previously cited in reexaminations of the ’992 patent, was argued to expressly disclose the missing element: using a "default" list of encoders when a data block's type is not identified.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would have been motivated to combine the references to solve the common problem of optimally compressing files containing various data types. The Hsu system was designed to be modular and easily modified. A POSITA would have recognized that Hsu's system, which left unrecognized data blocks uncompressed, could be improved by incorporating Franaszek’s well-known technique of applying a default compression algorithm to such blocks. This combination would predictably result in a more robust and efficient compression system.
    • Expectation of Success: A POSITA would have had a high expectation of success because combining the known elements—Hsu's data analysis with Franaszek's default encoding—involved applying a known technique to a known system to yield a predictable result.

Ground 2: Obviousness over Hsu and Sebastian - Claim 48 is obvious over Hsu in view of Sebastian.

  • Prior Art Relied Upon: Hsu (a 1995 journal article) and Sebastian (Patent 6,253,264).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented a similar argument to Ground 1, with Sebastian fulfilling the same role as Franaszek. Petitioner argued Hsu taught all limitations except the "default encoder." Sebastian, like Franaszek, was a reference of record from prior reexaminations and was asserted to explicitly teach the use of a "generic" filter (encoder) when an incoming data block's format does not match any of the system's specific, installed filters. This "generic" filter was argued to be the claimed "default encoder."
    • Motivation to Combine: The motivation was analogous to that in Ground 1. Both Hsu and Sebastian were in the data compression field and aimed to efficiently compress heterogeneous data. Petitioner argued a POSITA would have been motivated to modify Hsu's system by incorporating Sebastian's "generic" filter to handle unrecognized data types. This would improve Hsu's system by ensuring all data blocks are compressed, rather than skipping those that are not identified, achieving the predictable goal of universal compression.
    • Expectation of Success: The expectation of success was based on the straightforward application of Sebastian's known default encoding solution to improve the functionality of Hsu's data-type-specific compression system, representing a combination of familiar elements to achieve a predictable outcome.

4. Key Claim Construction Positions

  • "receiving a data block": Petitioner proposed this term be construed as "receiving one or more data blocks." This construction was argued to be consistent with a prior district court ruling and reexamination history, countering the Patent Owner's previous attempts to limit the term to only "passive" reception of data.
  • "wherein the analyzing of the data within the data block... excludes analyzing based only on a descriptor...": Petitioner proposed this phrase be construed to mean "wherein the analyzing... includes analyzing data other than data appended to the data block that is indicative of the data type." This construction was central to Petitioner's argument, as it framed the limitation in a way that would be met by Hsu's method of analyzing the actual content of the data block (e.g., byte patterns and statistical properties) rather than an external label.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claim 48 of the ’992 patent as unpatentable under 35 U.S.C. §103.