PTAB

IPR2017-00808

Teradata Operations Inc v. Realtime Data LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression System and Method
  • Brief Description: The ’728 patent describes a system for data compression that uses a combination of content-dependent and content-independent methods. The system analyzes a data block to identify parameters or attributes; if recognized, a content-dependent encoder is used, and if not, a content-independent or default encoder is applied.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 9, 10, 15, 20, and 24 are obvious over Franaszek in view of Hsu, with an alternative combination including 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:
    • Prior Art Mapping: Petitioner argued that the primary reference, Franaszek, disclosed most elements of the challenged claims, including a data compression system with a processor that selects from a list of content-dependent encoders if a data block’s type is identified from a descriptor field. If the data type is unknown, Franaszek selects a single encoder from a default list by testing multiple candidates on a sample of the data. The key limitation missing from Franaszek—analyzing data within a block in a manner that "excludes analyzing based solely on a descriptor"—was supplied by Hsu. Hsu taught a system for compressing heterogeneous files that identifies a block’s data type and compressibility by analyzing the content of the data block itself, specifically by examining the first, middle, and last 512-byte segments and calculating "redundancy metrics." This internal analysis, not reliant on a descriptor, directly taught the allegedly novel feature of the ’728 patent.
    • For dependent claims, Petitioner asserted Franaszek taught receiving uncompressed data blocks (claims 2-3), associating a data token with the compressed output (claims 9-10), storing the compressed block (claim 15), and outputting the compressed block with a token (claim 20).
    • As an alternative, Petitioner contended that if Franaszek’s method of selecting a single encoder from a default list was deemed insufficient, Sebastian taught the use of a single, "generic" filter (encoder) when a data block’s format does not match any specific, installed filters. This provided an alternative basis for the "single data compression encoder" and "default data compression encoder" limitations.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Franaszek with Hsu to improve Franaszek’s system for handling increasingly common heterogeneous files. Franaszek’s reliance on a simple descriptor field was limited, whereas Hsu’s technique of analyzing the actual data content provided a more robust and accurate method for selecting the optimal encoder, especially when data types change within a file. This combination was a predictable path to improving compression efficiency. A POSITA would have also been motivated to substitute Sebastian’s single generic encoder into Franaszek’s system as a simple design choice to increase speed. Instead of Franaszek’s time-consuming process of testing multiple default encoders, using Sebastian's single generic encoder offered a faster, albeit potentially less optimal, solution for compressing unidentified data types.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these references. Both Franaszek and Hsu operated in the same field of data compression and addressed the common problem of selecting appropriate encoders. Integrating Hsu’s known data analysis techniques into Franaszek’s framework was a straightforward application of known principles to achieve the predictable result of more effective compression.

4. Key Claim Construction Positions

  • "the data block being included in one or more data blocks" (claims 2 and 3): Petitioner argued this phrase should be given its broadest reasonable interpretation as "the data block is included among a group of one or more data blocks." Petitioner contended that interpreting the claim to mean one data block is physically contained within another is inconsistent with the specification, which describes a stream of sequential data blocks being processed. The proposed construction aligns with the patent’s disclosure of processing a data stream.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-3, 9, 10, 15, 20, and 24 of the ’728 patent as unpatentable.