PTAB

IPR2016-00377

Oracle America Inc v. Realtime Data LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Accelerated Data Storage and Retrieval
  • Brief Description: The ’908 patent relates to a "data storage accelerator" system designed to improve data storage bandwidth. The system uses one or more high-speed, lossless data compression encoders to compress an incoming data stream, enabling the compressed data to be stored on a memory device faster than the data could be stored in its original, uncompressed form.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kawashima and Sebastian - Claims 1-2, 4-6, 9, 11, 21-22, and 24-25 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 core framework of the invention: a data compression and storage system designed to accelerate storage by ensuring that the total time to compress and store data is less than the time required to store the same data uncompressed. Petitioner specifically pointed to diagrams in Kawashima that illustrate this time savings, arguing it directly discloses the key "faster than" limitation found in independent claims 1, 21, and 25. Kawashima also disclosed the requisite system components, including a data compression apparatus ("accelerator") and a memory device.

    • However, Petitioner contended that Kawashima, while acknowledging different data types exist, primarily focuses on using a single compression technique. This is where Sebastian’s teachings become relevant. Sebastian was presented as a reference that explicitly addresses optimizing compression for data streams containing multiple data types. Sebastian teaches a system that uses different compression techniques (e.g., Lempel-Ziv, Huffman) for different data blocks based on their specific format or type (e.g., text, spreadsheets, images). This disclosure was argued to directly supply the limitation in the independent claims requiring the use of a second, different compression technique for a second data block.

    • For the dependent claims, Petitioner argued Sebastian’s teachings were also directly applicable. Sebastian was asserted to disclose the use of descriptors (identification codes) to indicate which compression technique was used, which could be stored with the compressed data to facilitate decompression (claims 2, 4, 22). Furthermore, Sebastian explicitly teaches using dictionary and Lempel-Ziv compression, as required by claims 9, 11, and 24.

    • Motivation to Combine: The petition asserted that a person of ordinary skill in the art (POSITA) would have been motivated to combine the references to solve a known problem. Both Kawashima and Sebastian operate in the same technical field of data compression and storage optimization. Kawashima provided a system for accelerated storage but was suboptimal for data streams with varied data types—a problem it implicitly recognized. Sebastian provided a known solution for improving compression efficiency on varied data types by using multiple, type-specific algorithms. A POSITA would combine Sebastian’s multi-algorithm compression strategy with Kawashima’s accelerated storage framework to create a more robust and efficient system, which was a predictable improvement.

    • Expectation of Success: A POSITA would have had a reasonable expectation of success in making this combination. The integration involved applying Sebastian’s well-understood, data-type-specific compression methods into the system architecture disclosed by Kawashima. This was argued to be a combination of known elements according to known methods to yield predictable results, namely improved compression efficiency within an accelerated storage system.

4. Key Claim Construction Positions

  • Petitioner proposed a construction for the key limitation present in independent claims 1, 21, and 25: “the compression and storage occurs faster than the first and second data blocks are able to be stored on the memory device in uncompressed form.”
    • Proposed Construction: "wherein the time to compress and store the first and second data blocks is less than the time to store the first and second data blocks without compressing them."
    • Significance: This construction was central to Petitioner's argument. It framed the core inventive concept as a simple time-based comparison, which Petitioner argued was explicitly taught and illustrated in the Kawashima reference. By establishing this construction, Petitioner aimed to show that the primary distinguishing feature of the ’908 patent was already present in the prior art, leaving only the combination with Sebastian’s multi-algorithm approach as the difference to be bridged by obviousness.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-2, 4-6, 9, 11, 21-22, and 24-25 of Patent 9,116,908 as unpatentable.