PTAB

IPR2017-00176

Dell Inc v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression System
  • Brief Description: The ’506 patent discloses a method for compressing data blocks using a combination of content-dependent and content-independent data compression. The system analyzes a data block to identify its data type and, if identified, uses a specific content-dependent encoder; otherwise, it applies a content-independent or default encoder.

3. Grounds for Unpatentability

Petitioner asserted a single ground of unpatentability under 35 U.S.C. §103 with two alternative prior art combinations.

Ground 1: Claims 104 and 105 are obvious over Franaszek in view of Hsu, or in the alternative, over Franaszek in view of Hsu and Sebastian.

  • Prior Art Relied Upon: Franaszek (Patent 5,870,036), Hsu (a 1995 journal article titled Automatic Synthesis of Compression Techniques for Heterogeneous Files), and Sebastian (Patent 6,253,264).
  • Core Argument for this Ground: Petitioner argued that the challenged claims were obvious because the primary reference, Franaszek, taught nearly all elements of a dual-mode data compression system. The key missing element—analyzing data within a block rather than relying solely on a descriptor to identify its type—was supplied by Hsu. The tertiary reference, Sebastian, provided an alternative and well-known teaching for using a single "generic" encoder for unknown data types, further supporting the obviousness of the claimed invention.
    • Prior Art Mapping: Independent claims 104 and 105 recite a method of analyzing a data block to identify its data type, performing content-dependent compression if a type is identified, and performing data compression with a "single data compression encoder" or a "default data compression encoder" if a type is not identified. A central limitation requires that the analysis "excludes analyzing based only on a descriptor that is indicative of the data type."
      • Petitioner asserted that Franaszek disclosed a compression system that analyzes a data block's "type field" (a descriptor) to determine if a data type is known. If a type is identified, the system selects from a pre-selected "Compression Method List" of encoders tailored to that data type. If the type is unknown, the system uses a "default list of compression methods" to test samples of the block and select the single best-performing encoder to compress the entire block. Petitioner argued this taught most claim elements but relied on a descriptor for type identification.
      • Hsu was argued to teach the missing "excludes analyzing based only on a descriptor" limitation. Hsu's method for compressing heterogeneous files determines a block's data type by examining and analyzing samples from the beginning, middle, and end of the data block itself. This analysis of the block’s internal content, rather than reliance on a header or descriptor field, was asserted to directly teach the claimed analysis method.
      • Sebastian was presented as an alternative teaching for the "single data compression encoder" limitation. Sebastian disclosed a system with various format-specific encoders ("filters") and a single "generic" filter for use when a data block's format is not supported by a specific filter. Petitioner contended that using Sebastian’s single generic filter when a data type is not matched was a direct mapping for the claimed use of a single encoder for unidentified data types.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would have been motivated to combine Franaszek and Hsu to improve Franaszek’s system for the practical purpose of handling increasingly common heterogeneous files, where data types can vary within a single data block. Replacing Franaszek’s simple descriptor-based identification with Hsu’s more robust content analysis was a logical and predictable modification to improve encoder selection accuracy. The motivation to incorporate Sebastian was to improve the efficiency and speed of Franaszek’s default compression process. A POSITA would have recognized the benefit of substituting Sebastian's single, efficient "generic" encoder for Franaszek's more time-consuming process of testing multiple default encoders, achieving a predictable trade-off between compression speed and compression ratio.
    • Expectation of Success: The combination of these known techniques would have yielded predictable results. Applying Hsu's known content analysis method to Franaszek's established compression framework was a straightforward application of known technologies for their intended purposes, leading to a high expectation of success in creating a more robust data compression system.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 104 and 105 of the ’506 patent as unpatentable.