PTAB

IPR2016-01672

Oracle America Inc v. Realtime Data LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Data Compression and Decompression
  • Brief Description: The ’908 patent relates to data compression and decompression techniques for data storage systems. It discloses a "data accelerator" system that uses multiple compression techniques to compress and store data blocks faster than they could be stored on the memory device in their uncompressed form.

3. Grounds for Unpatentability

Ground 1: Obviousness over Franaszek and Osterlund - Claims 1, 9, 11, 21-22, and 24-25 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 and decompressing data that uses a plurality of compression mechanisms. Franaszek describes analyzing data blocks to select the "best" compression technique (e.g., dictionary, run-length) for each block before storing the compressed data in a second memory. However, Petitioner contended Franaszek did not explicitly teach the key limitation that "compression and storage occurs faster" than storing the data in uncompressed form. To supply this teaching, Petitioner cited Osterlund, which discloses a data compression device interposed in the data stream between a host computer and a storage controller. Osterlund explicitly teaches that its system achieves "overall faster rates of data storage and retrieval" because the compression reduces the amount of data that must be physically stored, thus completing the write task faster.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would have been motivated to combine the teachings of Osterlund with the system in Franaszek. Both references address the same field of improving data storage efficiency through compression. A POSITA would combine Osterlund’s known technique for accelerating data storage with Franaszek’s more advanced, adaptive compression system to achieve the predictable and highly desirable result of faster overall system performance. The motivation was to apply a known solution (accelerated storage) to improve a similar system (adaptive compression) to gain well-understood benefits.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in making this combination. The field of data compression was mature and predictable, and the effects of reducing data volume on storage time were well-understood and could be easily 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 builds upon the combination in Ground 1 to address dependent claims requiring the storage and retrieval of a "data descriptor" indicative of the compression technique used. Petitioner argued that Franaszek’s teaching of a "compression method description" (CMD) field stored with each compressed block already met this limitation. However, to the extent Franaszek was deemed insufficient, Petitioner introduced Fall. Fall explicitly teaches a compressor that stores compressed data in a memory buffer and also stores the "type of compression used to process the object data." Fall further teaches a decompressor that retrieves these object descriptors from memory to properly decompress the data. Therefore, Fall provides an express teaching of a data accelerator (compressor/decompressor) that stores and retrieves the required descriptor from the memory device.
    • Motivation to Combine: Petitioner argued that a POSITA would find it obvious to incorporate Fall's method of handling descriptors into the Franaszek/Osterlund system. Franaszek and Fall address analogous problems of optimizing data storage using multiple compression schemes. If Franaszek's system were seen as lacking an explicit mechanism for the accelerator itself to store the descriptor, a POSITA would have looked to other known systems like Fall for a solution. Implementing Fall’s descriptor-handling was a predictable design choice that would ensure the necessary decompression information was available with the data, resulting in a more robust system.
    • Expectation of Success: The combination represented a simple substitution of one known method for storing descriptors (Fall) into an existing compression system (Franaszek/Osterlund) to achieve a predictable result.

4. Key Claim Construction Positions

  • Petitioner argued that the phrase "retrieves the first compressed and the second data blocks from the memory device" (claim 5) should be interpreted to mean retrieving the compressed data blocks from the memory device where they are stored. This construction was based on the plain language of the claims and supported by the patent’s specification, which describes storing compressed data on a memory device and subsequently decompressing it. No other specific constructions were argued to be necessary to resolve the challenges.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-2, 4-6, 9, 11, 21-22, and 24-25 of the ’908 patent as unpatentable under 35 U.S.C. §103.