PTAB

IPR2017-00366

Veritas Technologies LLC 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 ’513 patent discloses systems and methods for data compression that analyze incoming data to determine whether to apply a content-dependent compression algorithm (if the data type is recognized) or a content-independent compression algorithm (if the data type is not recognized).

3. Grounds for Unpatentability

Ground 1: Obviousness over Wang, Matsubara, and Franaszek - Claims 1-4, 6, 10-16, 18-20, and 22 are obvious over the combination of Wang, Matsubara, and Franaszek.

  • Prior Art Relied Upon: Wang (WO 00/46688), Matsubara (Patent 5,838,821), and Franaszek (Patent 5,870,036).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Wang, Matsubara, and Franaszek taught every limitation of the challenged claims. Wang disclosed the foundational method of automatically compressing files by first attempting to recognize the file format and data type to apply a suitable content-dependent algorithm (e.g., JPEG for images) and applying a default content-independent lossless algorithm (e.g., LZW) if the file format is not recognized. For the key limitation requiring analysis that "excludes analyzing based only on a descriptor," Petitioner contended that Matsubara supplied this element. Matsubara taught a specific technique for identifying a file’s data type by analyzing its actual content—specifically, by constructing and analyzing a histogram of the file’s byte patterns—which is inherently not based on a descriptor alone. Franaszek was argued to supplement Wang by explicitly teaching the use of a default compression algorithm when a data type is not recognized, providing a clear solution for a scenario not fully detailed in Wang. For apparatus claims (e.g., claim 15), Petitioner asserted that Matsubara explicitly taught implementing such compression methods using circuits, including application-specific integrated circuits (ASICs). Dependent claims were addressed by further teachings, such as Franaszek’s disclosure of appending a recognizable data token to indicate the compression algorithm used (for claim 6) and Matsubara’s teaching of selecting an algorithm to achieve the highest compression ratio (for claim 14).
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would have been motivated to combine the references to achieve a more robust and effective compression system. The primary motivations were:
      • A POSITA would combine Matsubara with Wang to implement Wang’s general teaching of "automatically recogniz[ing] the type of data" with Matsubara’s specific and known technique of analyzing byte patterns. This represented using a known technique to improve a similar method for predictable results.
      • A POSITA would incorporate the teachings of Franaszek and Wang to handle instances where Matsubara’s data type analysis might fail. Both references taught using a default, lossless compression algorithm when a data type or format is unknown, which would be an obvious way to make the combined system more robust.
      • A POSITA would implement the combined method using ASICs as taught by Matsubara, as this was a well-known design choice for improving the performance of data compression hardware.
      • A POSITA would add Franaszek’s technique of appending a data token identifying the compression method to the compressed data to improve the ease and reliability of decompression, a known method for improving a similar system.
    • Expectation of Success: Petitioner argued that a POSITA would have had a reasonable expectation of success because the combination involved integrating known, compatible elements for their established functions. Combining a specific data analysis technique (Matsubara) with a general compression framework (Wang) and adding a known error-handling step (Franaszek’s default algorithm) were all straightforward applications of prior art principles that would yield predictable improvements.

4. Key Claim Construction Positions

  • "content independent compression algorithm": Petitioner proposed that this term should be construed as "a compression algorithm that is applied when the data type or content of the data block is not identified, recognized, or associated with a specific data compression algorithm." This construction was based on the patent’s disclosure that this type of algorithm is used when content cannot be identified.
  • "content dependent compression algorithm": Petitioner proposed construing this term as "a compression algorithm that is applied when the data type or content of the data block is identified, recognized, or associated with a specific data compression algorithm." This construction aligned with the patent’s description of applying specific algorithms once the system recognizes a particular data type.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. § 325(d) would be inappropriate. The petition asserted that it presented different prior art combinations, different arguments, and different expert declaration testimony than those relied upon in a previously instituted IPR against the same patent (IPR2016-00374). Petitioner emphasized that because the instant petition presented new prior art and arguments not previously considered by the Office, it fell outside the scope of § 325(d).

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-4, 6, 10-16, 18-20, and 22 of the ’513 patent as unpatentable. Petitioner also requested joinder with IPR2016-00978, which was instituted on the same grounds.