PTAB

IPR2017-01354

NetApp Inc 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 ’728 patent discloses systems for data compression that analyze a data block to identify its parameters or attributes. If specific parameters are identified, a content-dependent data compression encoder is used; if not, a content-independent single data compression encoder is used.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hsu and Sebastian - Claims 1-2, 9-10, 15, 17, 20, and 24 are obvious over Hsu in view of Sebastian.

  • Prior Art Relied Upon: Hsu ("Automatic Synthesis of Compression Techniques for Heterogeneous Files," a 1995 journal article) and Sebastian (Patent 6,253,264).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hsu, the primary reference, disclosed most limitations of the challenged claims. Hsu taught a two-phase compression system that first analyzed data blocks to determine parameters (e.g., data type, redundancy metrics) and then selected an appropriate content-dependent compression encoder from a database. However, Hsu taught that if its analysis did not identify a useful combination of parameters for a data block, that block was left uncompressed. Petitioner asserted that Sebastian supplied the missing element. Sebastian disclosed a system that used format-specific compression when a data format was known, but critically, used a single "generic" content-independent encoder (e.g., Lempel-Ziv) when the format was unknown or unsupported. This directly taught the claimed step of using a single encoder when parameters are not identified.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine Hsu and Sebastian to improve Hsu's system. Hsu's approach of not compressing unrecognized data blocks could be inefficient if a block was, in fact, compressible but simply misclassified. Sebastian provided a known solution to this problem by teaching the use of a default, generic compressor for unrecognized data. A POSITA would have been motivated to incorporate Sebastian's default compression strategy into Hsu's system to ensure that all data blocks were subjected to at least a baseline level of compression, thereby improving overall space savings, a stated goal of Hsu.
    • Expectation of Success: The combination was presented as a predictable application of known techniques. Implementing a default "else" condition (compressing with Sebastian's generic encoder) to handle cases where Hsu's primary "if" analysis (identifying specific parameters) failed was a straightforward modification with a high expectation of success.

Ground 2: Obviousness over Franaszek and Hsu - Claims 1-2, 9-10, 15, 17, 20, and 24 are obvious over Franaszek in view of Hsu.

  • Prior Art Relied Upon: Franaszek (Patent 5,870,036) and Hsu (a 1995 journal article).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner used Franaszek as the primary reference, arguing it taught a system that dynamically selected compression methods for data blocks. If a "data type" was identified from a data field, a preselected list of content-dependent methods was used. If the data type was not identified, Franaszek assigned a default "Compression Method List" (CML). Petitioner argued this default CML could obviously be limited to a single encoder. The main limitation missing from Franaszek was the analysis of the data content itself to determine its type, as Franaszek relied on a pre-existing "data type" field. Hsu was introduced to supply this teaching, as it explicitly disclosed analyzing segments of the data block to determine parameters like data type and redundancy.
    • Motivation to Combine: A POSITA implementing Franaszek's system would be motivated to incorporate Hsu's data analysis techniques to make the system more versatile, allowing it to handle data sources that lacked a pre-populated "data type" field. This combination would allow Franaszek’s system to generate the necessary data type information on the fly. Furthermore, Petitioner argued a POSITA would be motivated to modify Franaszek's default CML to contain only a single encoder to reduce computational overhead and increase compression speed, which are common and desirable engineering trade-offs.
    • Expectation of Success: Combining Hsu's data analysis front-end with Franaszek's compression selection back-end would have been a predictable integration of complementary technologies to create a more robust system.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Hsu in view of Wang (WO 00/46688) and Franaszek in view of Chu (Patent 5,467,087), relying on similar theories where Wang and Chu were used to teach the use of a default single data compression encoder or the analysis of data content, respectively.

4. Key Claim Construction Positions

  • "analyzing"/"analyze": Petitioner adopted the Patent Owner's proposed construction from district court litigation, which defined the term as "means directly examining / directly examine."
  • "a single data compression encoder": Petitioner argued this term should be interpreted to mean the one content-independent encoder used when data parameters are not identified. This construction was based on arguments the Patent Owner had made during a prior reexamination of a related patent (’506 patent), where it distinguished prior art by asserting that art disclosed multiple encoders, not a single one, for the default case.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1, 2, 9, 10, 15, 17, 20, and 24 of the ’728 patent as unpatentable.