PTAB

IPR2016-00374

Oracle America Inc v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression System and Methods
  • Brief Description: The ’513 patent discloses systems and methods for compressing data by analyzing a plurality of data blocks and applying a combination of “content dependent” and “content independent” compression algorithms. A key feature is that the analysis to select an algorithm includes examining the data within a block itself, rather than relying solely on a descriptor indicative of the data type.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hsu and Franaszek - Claims 1, 2, 4, 6, 11-16, 18-20, and 22 are 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 and Franaszek collectively teach every limitation of the challenged claims. Hsu was asserted to teach a system that analyzes heterogeneous files by breaking them into fixed-size data blocks. Crucially, Hsu’s system statistically analyzes the data within each block (e.g., character frequencies, run length, string repetition) to determine its data type and select an optimal content-dependent compression algorithm from a database. Petitioner contended this directly teaches the ’513 patent’s core limitation of analyzing the data itself, excluding reliance only on a descriptor. The only element Petitioner argued was arguably missing from Hsu is an explicit process for handling data blocks of an unrecognized type with a content-independent algorithm.

    • Franaszek was argued to supply this missing element. Franaszek discloses a compression system that first checks if a data block has an appended "type" descriptor. If the type is known, a content-dependent algorithm is used. If the type information is not available, Franaszek teaches using a "default" list of compression algorithms—the exact function of the ’513 patent’s "content independent" compression. The combination of Hsu's internal data analysis for known data types and Franaszek's default compression for unknown data types was asserted to render independent claims 1 and 15 obvious. Dependent claims were argued to be obvious as they recite additional well-known features taught by the combination, such as receiving uncompressed data (Hsu), applying algorithms serially (Hsu), and using dictionary-based compression to reduce data repetition (Franaszek).

    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Hsu and Franaszek to solve the common problem of optimally compressing files containing diverse data types. Hsu’s system for content-dependent compression was designed to be extensible. A POSITA would have been motivated to improve Hsu’s system by incorporating Franaszek’s well-known technique of using a default, universal compression algorithm (like Lempel-Ziv) for data blocks that Hsu could not recognize. This would prevent such blocks from being left uncompressed and would be a predictable improvement to achieve more comprehensive compression.

    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. The integration involved applying a known solution (default compression for unknown data types from Franaszek) to a known system (Hsu's content-based analysis) to achieve a predictable result—the optimal compression of all data blocks, whether their type was recognized or not.

4. Key Claim Construction Positions

  • "content independent [data] compression algorithm" (claims 1, 15): Petitioner proposed this term should be construed as "a compression algorithm for data for which a specific data type or content is not identified or recognized." This construction was central to mapping Franaszek's teaching of a "default" compression list, which is used when data type information is unavailable, to this claim limitation.
  • "[excludes/excluding] analyzing based only on [a/the] descriptor" (claims 1, 15): Petitioner proposed this term should be construed as "involves/involving analyzing data other than data appended to the data block." This construction was critical to Petitioner's argument that Hsu taught this limitation. Petitioner argued that the prosecution history of a related patent shows this language was added to distinguish over prior art that only analyzed descriptors (like file headers). Hsu’s method of statistically analyzing the actual byte patterns within a data block was therefore argued to meet this "excluding" limitation.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 2, 4, 6, 11-16, 18-20, and 22 of the ’513 patent as unpatentable.