PTAB

IPR2016-00783

SAP America Inc v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and method for lossless data compression and decompression
  • Brief Description: The ’812 patent discloses a method that combines two data compression techniques. The system first analyzes an input data stream to detect a run-length sequence of similar data blocks, which is then encoded using run-length encoding; data blocks not part of a run are compressed using a dictionary-based encoding algorithm.

3. Grounds for Unpatentability

Ground 1: Obviousness over O'Brien in view of Nelson - Claims 1-4, 8, and 28 are obvious over O'Brien in view of Nelson.

  • Prior Art Relied Upon: O'Brien (Patent 4,929,946) and Nelson (The Data Compression Book, 1992).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that O'Brien disclosed all elements of the challenged claims, but used different terminology. O'Brien taught a compression apparatus that combined run-length encoding with an "adaptive data compression algorithm" for string compression. Petitioner contended that O'Brien's "reference value encoder" and associated "compression string table" collectively perform the functions of the claimed "dictionary encoder," including maintaining a dictionary, building data block strings, searching for matches, and outputting code words. Nelson, a seminal textbook on data compression, was cited to demonstrate that the LZW-type algorithm used by O'Brien's string encoder was well-understood by a person of ordinary skill in the art (POSITA) to be a form of dictionary-based encoding. Nelson clarified that O'Brien's "reference values" are equivalent to dictionary indices/code words and its "string table" is a dictionary.
    • Motivation to Combine: A POSITA would combine the teachings because O'Brien explicitly stated that "adaptive data compression algorithms are well known" and declined to disclose its specific algorithm in detail. This, Petitioner argued, would have prompted a POSITA to consult a standard reference like Nelson to understand the details of such well-known algorithms. Nelson described various LZW encoders, which closely resemble O'Brien's system, as "dictionary encoders." Therefore, a POSITA would have been motivated to use Nelson's teachings to understand O'Brien's system as a dictionary-based one or to substitute features from Nelson's encoders into O'Brien's framework.
    • Expectation of Success: A POSITA would have had a high expectation of success because both run-length encoding and LZW-type dictionary encoding were well-known, mature technologies. Combining them or substituting one known LZW implementation for another would involve applying known techniques to achieve a predictable result.

Ground 2: Obviousness over O'Brien, Nelson, and Welch - Claims 14-17 and 21 are obvious over O'Brien in view of Nelson and the Welch Patent.

  • Prior Art Relied Upon: O'Brien (Patent 4,929,946), Nelson (The Data Compression Book, 1992), and Welch (Patent 4,558,302).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims directed to a "program storage device readable by a machine" (i.e., software claims). The underlying compression method steps in these claims were identical to those addressed in Ground 1. Petitioner argued that O'Brien and Nelson together taught the method steps. The Welch patent was added to show that implementing such compression algorithms in software was a well-known and obvious design choice. Welch, the foundational patent for the LZW algorithm, explicitly described and provided figures for both hardware and software implementations of its LZW encoder.
    • Motivation to Combine: The motivation to combine O'Brien and Nelson was the same as in Ground 1. The motivation to further consider Welch was that it was a common and obvious design choice for a POSITA to implement a known data processing method, such as the compression algorithm of O'Brien, in either hardware or software. Welch provided direct evidence that this design choice was known specifically in the context of LZW compression, the very technology used in O'Brien and the ’812 patent.
    • Expectation of Success: A POSITA would have had a high expectation of success in creating a software implementation of O'Brien's system. Welch demonstrated that the conversion was routine, and the result of implementing a known algorithm in software was entirely predictable.

4. Key Claim Construction Positions

  • "Dictionary": Petitioner argued this term was central to its obviousness argument. It proposed the construction "a set of indices (dictionary indices), each of which is mapped to a corresponding data block string (code word) or a decoder signal (control code word)." This construction was critical to mapping the claims onto O'Brien, which did not explicitly use the word "dictionary" but described a "compression string table" and "reference values" (both for strings and control signals) that Petitioner argued collectively met this proposed definition.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-4, 8, 14-17, 21, and 28 of the ’812 patent as unpatentable under 35 U.S.C. §103.