PTAB

IPR2016-00972

Dell Inc v. Realtime Data LLC

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1. Case Identification

  • Case #: IPR2016-00972
  • Patent #: 7,415,530
  • Filed: April 29, 2016
  • Petitioner(s): Dell Inc; Riverbed Technology, Inc.; SAP America, Inc.; Sybase, Inc.; Hewlett-Packard Enterprise Co.; HP Enterprise Services, LLC; Teradata Operations, Inc.; Echostar Corporation; and Hughes Network Systems, LLC
  • Patent Owner(s): Realtime Data LLC d/b/a IXO
  • Challenged Claims: 1-5, 9-12, 14, 18, 19, and 24

2. Patent Overview

  • Title: Data Compression and Decompression Systems
  • Brief Description: The ’530 patent relates to data compression and decompression techniques for data storage systems. The invention is described as a "data storage accelerator" designed to enable the process of data compression and storage to occur faster than storing the data in its original, uncompressed form.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1, 9-11, 14, and 18 over Franaszek in view of Osterlund

  • Prior Art Relied Upon: Franaszek (Patent 5,870,036) and Osterlund (Patent 5,247,646).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Franaszek teaches a data compression system disclosing nearly all limitations of independent claim 1. This includes a system with a memory device and a "data accelerator" (compressor/decompressor) that receives a data stream, processes it as distinct data blocks, uses a plurality of different compression techniques, and stores a descriptor with the compressed data to identify which technique was used. The petition asserted that Osterlund supplies the one key limitation not expressly taught by Franaszek: that "compression and storage occurs faster than said data stream is able to be stored on said memory device in said received form." Osterlund was cited as explicitly teaching a compression module that achieves "overall faster rates of data storage and retrieval."
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Franaszek's adaptive compression system with Osterlund's speed-enhancing architecture to address the well-known problem of slow data storage. Because both references are in the analogous art of data compression for storage, a POSITA would be motivated to apply Osterlund's known solution to improve the performance of Franaszek's system and achieve the predictable result of faster operation.
    • Expectation of Success: Petitioner asserted that the relevant art is predictable. A POSITA would have had a reasonable expectation of successfully combining the references because compression algorithms and data transfer rates are easily modeled, simulated, and tested.

Ground 2: Obviousness of Claims 2-5 over Franaszek in view of Osterlund and further in view of Fall

  • Prior Art Relied Upon: Franaszek (Patent 5,870,036), Osterlund (Patent 5,247,646), and Fall (Patent 5,991,515).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targets dependent claims 2-5, which add limitations related to the data accelerator storing and retrieving the compression descriptor and compressed data. Petitioner asserted that Franaszek’s decompressor already retrieves the descriptor and data. However, to the extent Franaszek is found not to teach this, Fall was introduced as disclosing a compressor that explicitly stores descriptors in memory and a decompressor that retrieves both the descriptor and the compressed data from memory.
    • Motivation to Combine: A POSITA would be motivated to look to Fall, which addresses similar problems of data compression for storage, to incorporate a known method for descriptor management into the Franaszek/Osterlund system. Integrating Fall’s teachings would be a simple substitution of one known storage and retrieval method for another to simplify system architecture and ensure predictable data retrieval.

Ground 5: Obviousness of Claim 24 over Franaszek in view of Osterlund, Clark, and Rynderman

  • Prior Art Relied Upon: Franaszek (Patent 5,870,036), Osterlund (Patent 5,247,646), Clark (Patent 5,319,682), and Rynderman (Patent 5,563,961).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground challenges independent claim 24, which recites a system similar to claim 1 but adds limitations requiring (1) determining the bandwidth of the received data stream and (2) adjusting the data rate of the compressed stream to be compatible with the memory device's bandwidth. Petitioner argued that Clark teaches determining the input data rate (bandwidth) to optimize encoder performance and avoid overwhelming the processor. Rynderman was cited for teaching "adaptive control of the bandwidth of processed data output" to ensure compatibility with any desired storage device. Petitioner contended that claim 24 is merely an unpatentable aggregation of known, independent optimization techniques.
    • Motivation to Combine: A POSITA would combine these known optimization techniques from Clark and Rynderman with the base system of Franaszek/Osterlund as a matter of routine design. The motivation would be to create a more efficient, flexible, and robust system that could use lower-cost processors (per Clark) and work with a variety of memory devices having different bandwidths (per Rynderman), thereby increasing its usability.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that Claim 12 (requiring a solid-state mass storage device) is obvious over the primary combination further in view of Assar (Patent 5,479,638), and Claim 19 (requiring the data stream to be a collection of multiple files) is obvious over the primary combination further in view of Crawford (Patent 5,771,354).

4. Key Claim Construction Positions

  • Petitioner argued for a specific construction of the term "bandwidth" as used in claim 24. It proposed that when applied to the received data stream, "bandwidth" should be construed as the actual speed at which data is transmitted. When applied to the memory device, it should be construed as the capability of the device to accept data at a certain rate. This distinction was argued to be critical for mapping the "data rate" measurements of Clark and the "output bandwidth" control of Rynderman onto the claim's limitations.

5. Arguments Regarding Discretionary Denial

  • The petition acknowledged other pending IPRs filed by a different party (Oracle America, Inc.) against the ’530 patent. Petitioner argued that discretionary denial under 35 U.S.C. §325(d) would be inappropriate because this petition "presents different prior art and different evidence" and raises arguments that are "substantially different" from those in the other proceedings.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-5, 9-12, 14, 18, 19, and 24 of the ’530 patent as unpatentable.