PTAB

IPR2016-01738

Apple Inc v. Realtime Data LLC

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1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Accelerated Loading of Operating Systems and Application Programs
  • Brief Description: The ’862 patent discloses methods for reducing computer boot time by preloading "boot data," such as operating system (OS) or application files, from a slower primary storage device (e.g., hard disk drive) into a faster secondary memory (e.g., flash memory). The system accesses and decompresses this data from the faster memory upon startup.

3. Grounds for Unpatentability

Ground 1: Claims 8-12, 14-22, 59-82, 101-104, 114-115, and 117 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 taught the core method of accelerating boot times by preloading necessary "control information" (equivalent to the ’862 patent's "boot data") for an OS and applications from a hard disk drive (HDD) into a faster flash memory. Sukegawa’s system uses this loaded information to start the OS and applications at a "higher speed." However, Sukegawa did not explicitly teach storing this data in a compressed format. Petitioner asserted that Dye supplied this missing element by disclosing a memory controller with a "fast parallel compression and decompression" engine to increase the effective density and read access time of non-volatile storage devices, including HDDs and flash memory. The combination of Sukegawa's preloading architecture with Dye's compression technology renders the challenged claims obvious. For example, claim 8’s limitations were allegedly met as Sukegawa taught storing an OS portion (limitation 8.1), loading it to a second memory (8.2), accessing it (8.3), and using it to boot (8.5), while Dye taught performing these steps with compressed data and decompressing it upon access (8.4).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Dye's compression/decompression technology with Sukegawa's system to further Sukegawa's stated goal of reducing boot time. Applying Dye's compression would increase the effective data transfer rate from Sukegawa's HDD to flash memory, thereby decreasing the time required to load the boot data and accelerating the overall boot process. This modification was presented as a predictable solution to a known problem.
    • Expectation of Success: A POSITA would have had a high expectation of success because Dye's compression controller was designed to work with the exact types of storage (HDDs, flash memory) disclosed in Sukegawa. Integrating a compression engine into a memory controller was a known technique for improving performance.

Grounds 2-5: Claims 8-12, 14-22, 59-82, 101-104, 114-115, and 117 are obvious over Sukegawa and Dye in view of Settsu, Burrows, and/or Zwiegincew.

  • Prior Art Relied Upon: Sukegawa (Patent 5,860,083), Dye (Patent 6,145,069), Settsu (Patent 6,374,353), Burrows ("On-line Data Compression in a Log-structured File System" (1992)), and Zwiegincew (Patent 6,317,818).
  • Core Argument for this Ground:
    • Prior Art Mapping: These grounds relied on the same fundamental combination of Sukegawa and Dye as in Ground 1. The additional references—Settsu, Burrows, and Zwiegincew—were introduced to provide further motivation and reinforce the obviousness of applying compression to a boot-loading process.
    • Motivation to Combine (Incremental Contribution): Petitioner argued that these secondary references confirmed that using compression to accelerate data access from slow storage during system boot was a well-understood and common practice.
      • Settsu was cited for its teaching of storing OS modules as separate compressed files on a boot device specifically to "reduce the time required for booting up." This provided a direct parallel to the claimed invention's purpose.
      • Burrows was cited to show that using a fast hardware data compressor to "increase the effective disk transfer rate" was a known technique for speeding up a system.
      • Zwiegincew was cited for recognizing slow boot times caused by hard page faults and proposing to pre-fetch required data. Critically, Zwiegincew expressly taught using a "disk compressor/decompressor" on this pre-fetched data to achieve performance improvements.
    • Key Aspects: These references collectively demonstrated that a POSITA, when faced with the task of improving the boot speed of a system like Sukegawa's, would have naturally looked to compression as an obvious tool, as taught by Dye and exemplified in real-world applications by Settsu, Burrows, and Zwiegincew.

4. Key Claim Construction Positions

  • "boot data": Petitioner argued this term should be construed broadly as "data associated with data requests expected to result from a system power-on/reset."
    • Importance: This construction was critical for mapping the prior art. Petitioner contended that Sukegawa's disclosure of preloading "control information necessary for starting" an OS and frequently used applications fell squarely within this broad definition. This interpretation allowed Petitioner to argue that Sukegawa taught the loading of "boot data" as required by the claims, even though Sukegawa used different terminology.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 8-12, 14-22, 59-82, 101-104, 114-115, and 117 of the ’862 patent as unpatentable under 35 U.S.C. §103.