PTAB

IPR2016-01365

Apple Inc v. Realtime Data LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Accelerated Loading of Operating Systems and Application Programs
  • Brief Description: The ’608 patent relates to a data storage controller designed to accelerate computer boot times. The invention proposes preloading "boot data" (e.g., operating system and application files) from a primary storage device like a hard disk into an on-board cache memory before the host system requests it. This preloading, combined with optional data compression and decompression, allows the controller to service initial data requests from the cache, reducing system startup latency.

3. Grounds for Unpatentability

Ground 1: Obviousness over Sukegawa and Dye - Claims 1-31 are obvious over Sukegawa in view of Dye.

  • Prior Art Relied Upon: Sukegawa (Patent 5,860,083) and Dye (Patent 6,145,069).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sukegawa disclosed the core preloading functionality of the ’608 patent. Sukegawa taught a cache system with a controller that preloads operating system (OS) and frequently used application program (AP) data from a slow hard disk drive (HDD) into a faster, non-volatile flash memory cache to address the problem of slow boot speeds. This preloading could be initiated by user selection or automatically based on access frequency. Dye disclosed a "Compression Enhanced Flash Memory Controller" that used data compression/decompression to improve storage density and read access time for non-volatile memory. Petitioner asserted that adding Dye's compression engine to Sukegawa's controller would result in the claimed invention: a system that preloads boot data and uses compression to enhance performance.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Dye's compression technology with Sukegawa's preloading system for predictable benefits. Sukegawa's use of flash memory, which has limited storage capacity, would have motivated a POSITA to apply Dye's well-known compression techniques to increase the effective storage capacity of the cache. Furthermore, Dye explicitly taught that its compression technology increased the effective read access rate, which would have further motivated its use to achieve Sukegawa's stated goal of reducing boot time.
    • Expectation of Success: Combining a known compression engine with a caching controller was a straightforward and predictable design choice. A POSITA would have had a high expectation of success in integrating Dye's compression module into Sukegawa's controller to store more preloaded data and access it faster, thereby further accelerating the boot process.

Ground 2: Obviousness over Sukegawa and Dye in view of Settsu and/or Burrows - Claims 1-31 are obvious over Sukegawa and Dye in view of Settsu and/or Burrows.

  • Prior Art Relied Upon: Sukegawa (Patent 5,860,083), Dye (Patent 6,145,069), Settsu (Patent 6,374,353), and Burrows ("On-line Data Compression in a Log-structured File System," 1992).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground relied on the same fundamental combination of Sukegawa and Dye as in Ground 1. Settsu and Burrows were cited as providing additional, explicit motivation for the combination. Settsu taught booting a computer at high speed by storing OS files in a compressed format on a hard disk boot device, loading them into memory as compressed data, and then decompressing them. Burrows taught that incorporating a fast hardware compressor into the data path to a disk increases the effective disk transfer rate, thus speeding up the system.
    • Motivation to Combine: Petitioner argued that Settsu and Burrows provided even stronger motivation for a POSITA to add compression to Sukegawa's system. Settsu provided an explicit reason to use compression on boot data specifically to reduce boot-up time, directly aligning with Sukegawa’s objective. Burrows confirmed that it was well-known that compression could increase the effective data transfer rate from a hard disk itself, motivating the compression of data stored on Sukegawa’s HDD before it was even preloaded into the cache. These references reinforced the logic of combining Sukegawa and Dye and confirmed it was a known technique for achieving the desired result.
    • Expectation of Success: The teachings of Settsu and Burrows would have confirmed to a POSITA that applying compression to boot data on both hard disks and in cache was a well-understood, predictable, and successful strategy for improving system performance.
  • Additional Grounds: Petitioner asserted separate Grounds 2, 3, and 4, which challenged claims 1-31 over combinations of Sukegawa and Dye with Settsu, with Burrows, and with both Settsu and Burrows, respectively. These grounds all relied on the same core mapping, with Settsu and Burrows providing reinforcing motivation for applying compression.

4. Key Claim Construction Positions

  • "boot data": Petitioner argued that under the broadest reasonable interpretation, "boot data" should be construed to include any data associated with data requests expected to result from a system power-on or reset. This construction was asserted to be critical, as it encompassed not only OS data but also application data and document files. This broad scope allowed the "control information" for the OS and APs disclosed in Sukegawa to meet the "boot data" limitation of the challenged claims.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-31 of Patent 7,181,608 as unpatentable.