PTAB

IPR2017-01195

NetApp Inc v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Data Compression and Decompression
  • Brief Description: The ’530 patent discloses a system for accelerating data transfer and storage through data compression. The invention relates to a system with a memory device and a data accelerator that receives a data stream, compresses different data blocks using different compression techniques, and stores the resulting compressed stream faster than the original uncompressed stream could have been stored.

3. Grounds for Unpatentability

Ground 1: Obviousness over Franaszek and Osterlund - Claims 1 and 18 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 teaches nearly all limitations of claim 1, including a system that compresses a data stream on a block-by-block basis, selects the best compression technique from a plurality of available techniques for each block, and stores the compressed block along with a descriptor identifying the technique used. However, Petitioner contended that Franaszek does not explicitly teach the key limitation that "compression and storage occurs faster than" storing the uncompressed data. This limitation, which was central to the patent’s allowance during reexamination, is allegedly taught by Osterlund. Osterlund describes a data compression device interposed in a data stream that permits data storage and retrieval to "occur at a faster rate than would otherwise be possible."
    • Motivation to Combine: A POSITA would combine Osterlund’s known method for accelerating data storage with Franaszek’s adaptive multi-algorithm compression system to achieve the predictable and desirable result of a faster, more efficient data storage system. The motivation was to improve the performance of a system like Franaszek’s by incorporating a known speed-enhancing technique, which is a routine, technology-independent improvement.
    • Expectation of Success: Petitioner asserted a high expectation of success, as combining the references involved applying a known technique from Osterlund (accelerated storage) to an analogous data compression system (Franaszek) to achieve a predictable improvement in performance. The art of data compression was considered a predictable field.

Ground 2: Obviousness over Osterlund and Franaszek - Claims 1 and 18-20 are obvious over Osterlund in view of Franaszek.

  • Prior Art Relied Upon: Osterlund (Patent 5,247,646) and Franaszek (Patent 5,870,036).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground reverses the primary and secondary references. Petitioner argued that Osterlund provides the basic framework, teaching a data compression system where compression and storage are faster than storing the data in its received form. Osterlund, however, does not teach using multiple, different compression techniques for different data blocks. Franaszek was argued to supply these missing elements, as it explicitly discloses a system that analyzes data blocks to select the most appropriate compression method from several available options and stores an identifier with the data. For dependent claims, Franaszek also allegedly teaches using different encoders (claim 18) and a data stream with more than two blocks (claim 20), while Osterlund teaches a stream of multiple files (claim 19).
    • Motivation to Combine: A POSITA would be motivated to modify Osterlund’s high-speed compression system by incorporating Franaszek’s multi-algorithm approach to improve overall compression efficiency and ratios. Using different compression techniques tailored to specific data types was a known method for improving storage efficiency, which is a stated goal of Osterlund. This combination would predictably result in a system that is both fast and highly efficient in its use of storage space.
    • Expectation of Success: Success would have been reasonably expected because it involved integrating a known compression optimization technique from Franaszek into the architecture of Osterlund to enhance a known benefit (storage efficiency) without changing the fundamental principles of operation of either system.

  • Additional Grounds: Petitioner asserted further obviousness challenges for dependent claims by adding a third reference to the core combinations. Claims 2-4 were challenged over Franaszek, Osterlund, and Fall (Patent 5,991,515) to explicitly teach a data accelerator that stores descriptors and retrieves compressed data. Claim 12 was challenged over Franaszek, Osterlund, and Assar (Patent 5,479,638) to teach the use of a "solid-state mass storage device." Claims 19-20 were also challenged over Franaszek, Osterlund, and Crawford (Patent 5,771,354) to teach a data stream comprising a collection of multiple files.

4. Key Claim Construction Positions

  • Petitioner argued that the key limitation, "compression and storage occurs faster than said data stream is able to be stored on said memory device in said received form," should be given no patentable weight.
  • The basis for this position was that the phrase merely recites an intended result or function without providing any supporting structure or specific steps in the claim to achieve that result. Petitioner contended that the claim attempts to capture the result itself, rather than a specific invention that produces the result, making the limitation indefinite and not a patentable distinction over the prior art.

5. Relief Requested

  • Petitioner requests institution of an inter partes review of claims 1-4, 12, and 18-20 of Patent 7,415,530 and requests that those claims be found unpatentable and canceled.