PTAB

IPR2016-01366

Apple Inc v. Realtime Data LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Accelerated Loading of Operating Systems and Application Programs
  • Brief Description: The ’936 patent discloses data storage controllers designed to accelerate the boot time of a computer system. The invention employs a technique of preloading operating system and application data from a boot device (e.g., a hard disk) into an on-board cache memory, and optionally uses a data compression engine to store and transfer this data more efficiently.

3. Grounds for Unpatentability

Ground 1: Obviousness over Sukegawa and Dye - Claims 1-24

  • 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 taught the core elements of the ’936 patent’s method for accelerating boot time. Sukegawa described a controller that preloads "control information," including operating system (OS) and frequently used application data, from a slow hard disk drive (HDD) into a faster, non-volatile flash memory cache. This preloading allows the host system to start up at a higher speed. Petitioner asserted this disclosed the limitations of maintaining a list of boot data and preloading it into a cache memory. However, Sukegawa did not explicitly teach compressing this boot data. Petitioner argued that Dye supplied this missing element. Dye described a "Compression Enhanced Flash Memory Controller" with an embedded compression/decompression engine to improve system cost and performance. Dye taught that compressing data increases the effective density and read access time of non-volatile storage devices, including both flash memory and hard disks.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Dye's compression technology with Sukegawa's preloading system to solve a known problem. Sukegawa's goal was to accelerate boot time, and Dye explicitly taught that compression improves the performance and access speed of the very memory types used by Sukegawa (flash memory and HDDs). Since the cache in Sukegawa was of limited size, a POSITA would have been motivated to use compression to increase its effective capacity, allowing more boot data to be preloaded, and to increase data transfer rates, further speeding up the boot process.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because Dye taught that its compression/decompression engine could be embedded into prior art flash memory control circuits to substantially improve bandwidth and storage density. Applying this known technique for performance enhancement to Sukegawa's analogous controller was presented as a predictable and straightforward implementation.

Ground 2: Obviousness over Sukegawa and Dye in view of Settsu and/or Burrows - Claims 1-24

  • Prior Art Relied Upon: Sukegawa (Patent 5,860,083), Dye (Patent 6,145,069), Settsu (Patent 6,374,353), and Burrows (a 1992 article titled "On-line Data Compression in a Log-structured File System").
  • 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 introduced to provide additional, explicit motivation for applying compression specifically to accelerate a system's boot process. Settsu related directly to "booting an information processing apparatus at a high speed" by storing OS files in a compressed format on a boot device, loading them into memory as compressed data, and then decompressing them. Settsu explicitly stated this reduces "the time required for booting up." Burrows, a well-known earlier reference, confirmed that compressing data on a disk was an "attractive idea" that could "increase the effective disk transfer rate... thus speeding up the system."
    • Motivation to Combine: Petitioner argued that Settsu and Burrows reinforced the motivation to combine Sukegawa and Dye. While Dye provided a general performance motivation, Settsu provided a highly specific motivation by teaching the direct application of compression to solve the exact problem addressed by Sukegawa: slow boot times. Burrows further confirmed that the benefits of compression for speeding up disk-based systems were well-understood long before the ’936 patent's priority date. A POSITA looking to improve Sukegawa's boot-acceleration system would have found these references to be strong confirmation that adding compression was an obvious path to improvement.
    • Expectation of Success: The expectation of success was the same as in Ground 1, further bolstered by the explicit teachings in Settsu and Burrows regarding the successful application of compression for system speed improvements.
  • Additional Grounds: Petitioner asserted two additional, overlapping grounds (Grounds 3 and 4) which separated the contributions of Settsu and Burrows. These grounds relied on the same core arguments and design modification theories presented above.

4. Key Claim Construction Positions

  • "boot data": Petitioner argued that for the purposes of this inter partes review (IPR), the term "boot data" required a broad construction. They contended a POSITA would understand it to include not just the operating system, but any data associated with data requests expected to result from a system power-on or reset. This construction would encompass OS data, frequently used application data, and even user document files, aligning with the "control information" disclosed in Sukegawa and the full scope of data the ’936 patent described for preloading. This broad interpretation was critical to mapping Sukegawa's teachings onto the claims.

5. Relief Requested

  • Petitioner requested the institution of an IPR and the cancellation of claims 1-24 of Patent 8,090,936 as unpatentable.