PTAB

IPR2017-01196

NetApp Inc v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression and Decompression Systems
  • Brief Description: The ’908 patent discloses data acceleration techniques using compression and decompression. The system purports to achieve improved data transfer speeds by using multiple encoders, comparing their compression ratios against a threshold, and selecting an appropriate encoder, with the claimed result that compression and storage occur faster than storing the data in uncompressed form.

3. Grounds for Unpatentability

Ground 1: Claims 1, 21, 22, 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 most limitations of the independent claims, including a system that compresses data using a plurality of compression mechanisms. Franaszek’s system analyzes data blocks to select the "best" compression technique and stores the compressed block with an identifier indicating the chosen method. However, Petitioner contended Franaszek did not explicitly teach the claimed limitation that "compression and storage occurs faster than" storing the data uncompressed. To supply this element, Petitioner asserted that a person of ordinary skill in the art (POSITA) would look to Osterlund, which explicitly taught 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 speed increase through techniques like using wide data buses and direct memory access.
    • Motivation to Combine: A POSITA would combine Osterlund’s teachings with Franaszek's multi-algorithm system to achieve the well-known and desirable benefit of faster data storage. Both references were in the analogous art of data compression for storage systems, and improving system speed was a predictable goal. The combination aimed to gain the benefits of Franaszek’s improved compression efficiency with Osterlund’s accelerated storage speed.
    • Expectation of Success: Petitioner asserted that because the relevant art was predictable and the benefits of faster storage were well-understood, a POSITA would have had a reasonable expectation of success in integrating Osterlund’s speed-enhancing techniques into Franaszek's system.

Ground 2: Claims 2-4 and 6 are obvious over Franaszek in view of Osterlund and 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 the combination in Ground 1 to address limitations in dependent claims 2-4 and 6, which required storing and retrieving a "data descriptor" indicative of the compression technique used. Petitioner first argued that Franaszek’s stored "compression method description (CMD)" already met this limitation. To the extent Franaszek was deemed insufficient, Petitioner introduced Fall. Fall was argued to explicitly teach a compressor that stores compressed data along with a descriptor identifying the "type of compression used" in a memory buffer. Fall also taught retrieving this descriptor from memory.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Fall’s explicit teaching of storing and retrieving a compression descriptor into the Franaszek/Osterlund system. In a multi-algorithm system like Franaszek's, it is a functional necessity to track which algorithm was used for each data block to ensure proper decompression. Fall provided a known, straightforward method for achieving this, making its integration a matter of applying a known solution to a known problem for predictable results.

  • Additional Grounds: Petitioner asserted additional obviousness challenges over Osterlund in view of Franaszek (Ground 3) and Osterlund in view of Franaszek and Fall (Ground 4), which relied on reciprocal combinations of the same prior art references and similar design modification theories.

4. Key Claim Construction Positions

  • Petitioner argued that the key limitation "compression and storage occurs faster than [storing] in uncompressed form," recited in independent claims 1, 21, and 25, should not be given patentable weight. The petition contended this phrase merely recited an intended result without providing any supporting structure or techniques in the specification for achieving it. Petitioner argued that the patent was attempting to claim the result itself, rather than a specific invention that achieves the result.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-4, 6, 21, 22, and 25 of the ’908 patent as unpatentable under 35 U.S.C. §103.