Rackspace US Inc v. Realtime Data LLC

1. Case Identification

• Patent #: 7,415,530
• Filed: June 16, 2017
• Petitioner(s): Rackspace US, Inc.
• Patent Owner(s): Realtime Data LLC
• Challenged Claims: 1-4, 12, 18-20

2. Patent Overview

• Title: Data Compression and Decompression Systems
• Brief Description: The ’530 patent discloses systems and methods for data compression and storage. The technology involves using multiple, different compression techniques on different blocks of a data stream and storing a descriptor indicating which technique was used, with a key purported benefit being that the overall process of compression and storage is faster than storing the data in its original, uncompressed form.

3. Grounds for Unpatentability

Ground 1: 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 asserted that Franaszek teaches a compression system that uses a plurality of different compression mechanisms, analyzes data blocks to select the best mechanism for each, compresses them, and stores them with a "coding identifier" (a descriptor). This combination meets most limitations of independent claim 1. However, Franaszek does not explicitly teach the key limitation that "compression and storage occurs faster than said data stream is able to be stored on said memory device in said received form." Petitioner argued Osterlund remedies this deficiency by disclosing a data compression device interposed in the data path specifically to permit data storage and retrieval "to occur at a faster rate than would otherwise be possible." Osterlund achieves this using techniques like wide data buses and direct memory access (DMA). For dependent claim 18, which requires a "first encoder," Petitioner contended Franaszek's disclosure of using a "run length" encoder meets this limitation.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the teachings of Franaszek and Osterlund because both relate to the analogous art of data compression for storage applications. A POSITA would have been motivated to incorporate Osterlund’s known techniques for accelerating data storage into Franaszek’s system for using multiple compression algorithms to achieve the predictable result of a faster, more efficient system.
  • Expectation of Success: Because data compression and data transfer are predictable fields where performance can be modeled and tested, a POSITA would have had a reasonable expectation of success in combining the references to achieve faster storage speeds.

Ground 2: Claims 2-4 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 builds on the combination of Franaszek and Osterlund to address dependent claims 2-4. Claim 2 requires that the "data accelerator stores said first descriptor to said memory device." Petitioner argued that Franaszek inherently discloses this, as its compressor adds an identifier to the compressed data block before storage. To the extent this is not explicit, Petitioner introduced Fall, which teaches a compressor that stores the "type of compression used to process the object data" (the descriptor) in memory. Claims 3 and 4, which require the data accelerator to retrieve the descriptor and/or the compressed data stream, are allegedly met by Franaszek's decompressor, which retrieves the compressed block and its associated descriptor (CMD field) from memory to perform decompression. If not, Fall also teaches a decoder that retrieves both descriptors and compressed data from memory.
  • Motivation to Combine: A POSITA would look to Fall for teachings on how a compressor operates in a data storage system. Modifying the Franaszek/Osterlund system with Fall’s explicit teaching of having the compressor store the descriptor is a simple substitution of one known storage method for another to simplify the system and improve data management, yielding predictable results.

Ground 3: Claim 12 is obvious over Franaszek in view of Osterlund and Assar

• Prior Art Relied Upon: Franaszek (Patent 5,870,036), Osterlund (Patent 5,247,646), and Assar (Patent 5,479,638).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground addresses dependent claim 12, which specifies the memory device is a "solid-state mass storage device." Franaszek discloses its system can be used with "semiconductor memories" but also with magnetic disks. To make the limitation explicit, Petitioner cited Assar. Assar teaches replacing a rotating magnetic hard disk with a "semiconductor non-volatile memory" (i.e., solid-state storage) to resolve known problems such as latency, power consumption, and susceptibility to physical shock.
  • Motivation to Combine: A POSITA would have been motivated to substitute the memory device in the combined Franaszek/Osterlund system with the solid-state storage taught by Assar. This would be a simple and predictable substitution of one known component for another to gain the well-understood benefits of solid-state storage.

• Additional Grounds: Petitioner asserted several additional obviousness challenges, including grounds where Osterlund was the primary reference modified by Franaszek. Other grounds relied on Crawford (Patent 5,771,354) to teach that a data stream can comprise a collection of multiple files (for claim 19) and Kitagawa (Patent 6,078,541) as an alternative reference for using solid-state storage (for claim 12).

4. Key Claim Construction Positions

• Petitioner dedicated significant argument to the construction of the phrase "compression and storage occurs faster than said data stream is able to be stored on said memory device in said received form."
• Petitioner argued this limitation should not be given patentable weight because it merely claims an intended result without reciting any structure or steps for achieving it. The petition contended that the ’530 patent fails to describe how this result is accomplished, making the term functional at the point of novelty.
• In the alternative, should the Board give the term patentable weight, Petitioner argued it should be given its broadest reasonable interpretation. This construction is central to the petition's arguments, as this limitation was reportedly a key reason the claims were previously allowed during reexamination.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-4, 12, and 18-20 of the ’530 patent as unpatentable.