PTAB

IPR2016-01002

Dell Inc v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression and Decompression Techniques
  • Brief Description: The ’908 patent relates to systems and methods for data compression and decompression used in data storage systems. The invention claims a "data accelerator" that achieves accelerated data storage, wherein the compression and subsequent storage of data blocks occur faster than storing the same data blocks in an uncompressed form.

3. Grounds for Unpatentability

Ground 1: Obviousness over Franaszek and Osterlund - Claims 1, 9, 11, 21, 22, 24, and 25 are obvious 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 taught nearly all limitations of the independent claims, including a system for compressing data blocks using a plurality of compression techniques, selecting the best technique for each block, and then storing the compressed blocks. Franaszek’s system adaptively chooses between methods like dictionary compression and run-length coding on a block-by-block basis. However, Franaszek did not explicitly teach the core limitation that "compression and storage occurs faster" than storing uncompressed data. Petitioner asserted that Osterlund supplied this missing element by disclosing a data compression device interposed between a host and a storage controller specifically to permit data storage and retrieval to "occur at a faster rate than would otherwise be possible."
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would have been motivated to combine the references to improve the performance of Franaszek’s system. Franaszek and Osterlund are analogous, as both address data compression for storage applications. A POSITA would combine Osterlund’s speed-enhancing architecture with Franaszek’s adaptive compression method to achieve the known, desirable, and predictable result of faster and more efficient data storage, a common goal in the field.
    • Expectation of Success: Given that the art of data compression was well-developed and predictable, a POSITA would have had a reasonable expectation of success in integrating Osterlund's teachings to speed up the system in Franaszek. The performance of such a combination could be readily modeled and tested.

Ground 2: Obviousness over Franaszek, Osterlund, and Fall - Claims 2 and 4-6 are obvious over Franaszek in view of Osterlund 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 built upon the combination in Ground 1 to address limitations in dependent claims 2 and 4-6, which require storing and retrieving a "data descriptor" indicative of the compression technique used. Petitioner first argued that Franaszek inherently taught this feature with its "coding identifier" or "compression method description (CMD)" that is stored with each compressed block and used for decompression. To the extent Franaszek was deemed insufficient, Petitioner introduced Fall. Fall explicitly taught a compressor that stores compressed data in a buffer along with a descriptor indicating the "type of compression used to process the object data." Fall also disclosed a decoder that retrieves both the descriptor and the compressed data from memory.
    • Motivation to Combine: Petitioner asserted that if Franaszek's system was considered to not explicitly show the compressor itself storing the descriptor in memory, it would have been obvious for a POSITA to look to analogous art like Fall to implement this function. Both Franaszek and Fall addressed optimizing data storage using multiple compression schemes. Modifying Franaszek’s compressor to store the descriptor, as taught by Fall, would have been a predictable implementation that streamlined operations by having the compressor handle its own storage tasks, a simple substitution of one known component for another.

4. Key Claim Construction Positions

  • "retrieves the first compressed and the second data blocks from the memory device" (Claim 5): Petitioner proposed this phrase should be interpreted to mean retrieving the "first and second compressed data blocks." This construction was argued to be consistent with the claim language and specification, which describe storing compressed blocks on the memory device. This clarification ensures the "retrieval" step logically follows the "storage" step of compressed, not uncompressed, data.

5. Relief Requested

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