PTAB

IPR2016-01671

Oracle America Inc v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression Systems and Methods
  • Brief Description: The ’530 patent relates to a "data storage accelerator" system that uses data compression and decompression techniques to increase the rate at which data can be stored on and retrieved from a memory device.

3. Grounds for Unpatentability

Ground 1: Obviousness over Franaszek and Osterlund - Claims 1, 9-11, 14, and 18 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 independent claim 1. Franaszek disclosed a system for compressing data using a plurality of compression mechanisms, where different data blocks could be compressed with different techniques. It also taught storing a descriptor with each compressed block to identify the compression method used. Petitioner contended the key limitation not explicitly taught by Franaszek was 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 to remedy this deficiency, as it explicitly taught a data compression device interposed between a host and a storage controller to permit data storage "to occur at a faster rate than would otherwise be possible." Osterlund achieved this by reducing the amount of data that must be stored, thereby reducing the required time.
    • Motivation to Combine: Petitioner asserted both references were analogous art concerning data compression to improve data storage. A person of ordinary skill in the art (POSITA) would combine Osterlund's teachings with Franaszek's system to achieve the predictable result of increased data storage speed, a well-known goal in the field. Applying Osterlund's speed-enhancing architecture to Franaszek's adaptive compression system was presented as a routine design choice to improve performance.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the relevant art was predictable, and combining the known elements would predictably result in a faster, more efficient system.

Ground 2: Obviousness over Franaszek, Osterlund, and Fall - Claims 2-5 are obvious 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 built upon the combination in Ground 1 to address dependent claims. For claim 2, which required that the "data accelerator stores said first descriptor to said memory device," Petitioner argued that while Franaszek inherently taught this, Fall explicitly disclosed it. Fall taught a compressor that attempts to compress data and then "stores the compressed data in the compressed band buffer," which included storing the "type of compression used," i.e., the descriptor. For claims 3 and 4, which involved the data accelerator retrieving the descriptor and compressed data, Fall was also cited for teaching a decoder that "begins the retrieval of data from compressed memory," including object descriptors.
    • Motivation to Combine: A POSITA would combine Fall's teachings because Franaszek and Fall both address optimizing data storage using multiple compression schemes. To the extent Franaszek was viewed as ambiguous on whether the compressor itself stores the descriptor, a POSITA would look to a similar system like Fall for a known, predictable method of implementing this function to simplify the system and improve data handling.

Ground 5: Obviousness over Franaszek, Osterlund, Clark, and Rynderman - Claim 24 is obvious 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 challenged independent claim 24, which added limitations regarding bandwidth determination and adjustment. The base combination of Franaszek and Osterlund was argued to teach the core data acceleration system, as in Ground 1. Clark was added to teach the limitation "wherein a bandwidth of the received data stream is determined." Clark disclosed an adaptive compression system that "measure[s] the data rate at the input...of the encoder" to optimize performance. Rynderman was added to teach adjusting the compressed data rate to be "compatible with a bandwidth of the memory device." Rynderman disclosed "adaptive control of the bandwidth of processed data output to a storage device" to maintain optimal transfer rates.
    • Motivation to Combine: A POSITA would combine these known optimization techniques to improve Franaszek's system. Adding Clark's input bandwidth measurement would allow for more efficient use of processing resources. Incorporating Rynderman's adaptive output rate would increase the system's flexibility and usability, allowing it to work efficiently with various memory devices. These were argued to be routine optimizations to achieve a more robust and adaptable compression system.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for dependent claims 12 and 19. Ground 3 argued claim 12 was obvious over the Franaszek/Osterlund combination further in view of Assar (Patent 5,479,638) for its teaching of solid-state mass storage devices. Ground 4 argued claim 19 was obvious over the Franaszek/Osterlund combination further in view of Crawford (Patent 5,771,354) for its teaching of compressing a collection of multiple files.

4. Key Claim Construction Positions

  • Petitioner proposed a construction for the term "bandwidth" as recited in independent claim 24.
  • Based on its synonymous use with "data rate" in the specification, Petitioner argued "bandwidth" should be construed as "the speed at which data is or can be transmitted or stored, and may be quantified as a certain number of bits per second." This construction was central to mapping the teachings of Clark and Rynderman, which measure and control "data rates," to the "bandwidth" limitations of claim 24.

5. 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.