PTAB

IPR2016-00375

Oracle America Inc v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Accelerated Data Storage and Retrieval
  • Brief Description: The ’530 patent relates to a "data storage accelerator" system designed to improve data storage and retrieval speeds. The invention uses high-speed data compression encoders to losslessly compress an incoming data stream at a rate that allows the combined compression and storage process to complete faster than storing the data in its original, uncompressed form.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 4, 10-12, and 18-20 are obvious over Kawashima in view of Sebastian.

  • Prior Art Relied Upon: Kawashima (Patent 5,805,932) and Sebastian (Patent 6,253,264).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of Kawashima and Sebastian rendered the challenged claims obvious under 35 U.S.C. §103. Kawashima was asserted to teach the foundational system of the ’530 patent, including a "data accelerator" (data transmitting apparatus) that receives a data stream and stores it to a memory device. Crucially, Petitioner contended that Kawashima discloses the core inventive concept: that if a data stream is compressed at a sufficiently high ratio, the total time to compress and store the data will be less than the time required to store the same data uncompressed. This teaching was identified as the key limitation that was not found in the prior art during a previous reexamination of the ’530 patent.

      Petitioner argued that Sebastian supplied the remaining limitations of independent claim 1. Specifically, Sebastian was cited for its teaching of optimally compressing data streams containing multiple data types by applying different compression techniques to different data blocks. Sebastian discloses using specific "filters" (encoders) based on data type (e.g., for Excel or Word files) in combination with generic encoders. Furthermore, Sebastian teaches appending a descriptor (an "identification (ID) code") to the compressed data to indicate which compression technique was used, and utilizing this descriptor during decompression to reverse the process. This combination was argued to teach every element of the independent claims, with dependent claims being obvious variations disclosed by the same combination (e.g., using an optical disk or RAM as the memory device, which are disclosed memory types in Kawashima).

    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the references to solve the common and known problem of efficiently compressing a data stream containing different types of data. Kawashima expressly recognizes that different data types yield different compression ratios but primarily teaches using a single compression technique. Sebastian directly addresses this by teaching the use of multiple, data-type-specific compression techniques to improve overall efficiency. Therefore, a POSITA would be motivated to modify Kawashima’s high-speed storage system by incorporating Sebastian’s method of using different compression algorithms. This combination would be a predictable implementation to improve the performance of the Kawashima system.

    • Expectation of Success: A POSITA would have a high expectation of success in combining the references. Both Kawashima and Sebastian operate in the same technical field of data compression and storage, address the shared goal of optimizing system performance, and teach the use of the same classes of compression algorithms (e.g., Lempel-Ziv, Huffman). Integrating Sebastian's specific multi-algorithm approach into Kawashima's more general high-speed framework was presented as a straightforward application of known principles to achieve a predictable result.

4. Key Claim Construction Positions

  • The petition asserted that the claim term "said compression and storage occurs faster than said data stream is able to be stored on said memory device in said received form" (claim 1) was central to the invalidity analysis.
  • Petitioner proposed the construction: "wherein the time to compress and store the received data stream is less than the time to store the received data stream without compressing it." This construction was argued to be consistent with the patent's specification and was critical for mapping the teachings of Kawashima, which explicitly illustrates this time-saving benefit as a primary objective of its system.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-2, 4, 10-12, and 18-20 of the ’530 patent as unpatentable.