PTAB

IPR2017-00364

Veritas Technologies LLC v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Accelerated Data Storage System
  • Brief Description: The ’908 patent discloses systems and methods for data compression and decompression to accelerate data storage. The core concept involves a "data accelerator" that compresses and stores data blocks faster than they could be stored on a memory device in uncompressed form, particularly by using different compression techniques for different data blocks.

3. Grounds for Unpatentability

Ground 1: Obviousness over Franaszek and Osterlund - Claims 1, 9, 11, 21, 22, 24, and 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 data using a plurality of compression mechanisms. Franaszek’s system analyzes incoming data blocks, selects the "best" compression technique for each block (e.g., Lempel-Ziv, run-length), and stores the compressed blocks. However, Petitioner contended that Franaszek did not explicitly teach the key limitation that "compression and storage occurs faster" than storing the data in uncompressed form. To address this, Petitioner asserted that Osterlund expressly disclosed a data compression device interposed in a data stream to permit data storage and retrieval "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 time required for the storage operation.
    • Motivation to Combine: Petitioner argued that a person of ordinary skill in the art (POSITA) would combine the teachings of Franaszek and Osterlund because both patents address the same field of improving data storage systems using compression. A POSITA would have been motivated to apply Osterlund’s well-understood technique for accelerating data storage to Franaszek’s adaptive compression system to achieve the predictable benefit of faster overall system performance. This combination was presented as a straightforward application of a known solution (Osterlund's acceleration) to improve a similar system (Franaszek's).
    • Expectation of Success: The combination was argued to have a high expectation of success because data compression algorithms and data transfer rates were well-understood and predictable fields. Implementing Osterlund’s speed-enhancing techniques, such as using wide data buses and direct memory access, within Franaszek's system would predictably result in faster data storage without undue experimentation.

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 built upon Ground 1 to address dependent claims requiring the storage and retrieval of a "data descriptor" with the compressed data. Petitioner argued that Franaszek’s disclosure of a "coding identifier" or "compression method description (CMD)" stored with each compressed block already met the "data descriptor" limitation of claim 2. The CMD indicates which compression method was used and is utilized by the decompressor. However, to the extent Franaszek was deemed insufficient, Petitioner introduced Fall. Fall explicitly taught a compressor that stores the "type of compression used to process the object data" (a descriptor) in memory along with the compressed data. Claims 4, 5, and 6, which add retrieving the descriptor and data blocks for decompression, were argued to be disclosed by Franaszek’s decompressor or rendered obvious by the combination.
    • Motivation to Combine: The motivation to combine Franaszek and Osterlund remained the same as in Ground 1. The additional motivation to incorporate Fall’s teachings was to ensure the compressor itself handles the storage of the descriptor, a known and predictable design choice. If Franaszek’s compressor was not seen as performing this function, a POSITA would have looked to analogous systems like Fall's to implement this feature. This modification would be a simple substitution of one known component for another to achieve a predictable function, potentially simplifying system architecture by allowing the compressor to manage its own storage operations.
    • Expectation of Success: Petitioner asserted a reasonable expectation of success for similar reasons as Ground 1. Combining these known features from analogous data compression systems to achieve the claimed functions would have been a predictable and straightforward engineering task for a POSITA.

4. Key Claim Construction Positions

  • Petitioner proposed that the phrase “retrieves the first compressed and the second data blocks from the memory device” (claim 5) should be interpreted to mean "retrieves the first and second compressed data blocks from the memory device." This construction was based on the language of claim 1, which describes storing both blocks, and was asserted as the broadest reasonable interpretation.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §325(d) would be inappropriate. In a footnote, Petitioner asserted that although other inter partes review (IPR) proceedings existed against the ’908 patent, this petition presented different prior art and evidence. Therefore, the arguments raised were substantially different from those presented in other proceedings, making denial on the basis of redundancy improper. The petition also included a motion to join a co-pending IPR (IPR2016-01002).

6. Relief Requested

  • Petitioner requested the institution of an IPR and the cancellation of claims 1, 2, 4-6, 9, 11, 21, 22, 24, and 25 of the ’908 patent as unpatentable.