PTAB

IPR2017-01663

NetApp Inc v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Data Compression
  • Brief Description: The ’992 patent discloses systems for providing efficient data compression by using a combination of content-dependent and content-independent techniques. The claimed method involves analyzing a data block to identify its data type by means other than just a descriptor, using a specific encoder if one is associated with that type, and reverting to a default encoder if no specific encoder is associated.

3. Grounds for Unpatentability

Ground 1: Claim 48 is obvious over Hsu in view of Franaszek.

  • Prior Art Relied Upon: Hsu (a 1995 journal article titled "Automatic Synthesis of Compression Techniques for Heterogeneous Files") and Franaszek (Patent 5,870,036).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hsu teaches all limitations of independent claim 48 except for the use of a "default encoder." Hsu discloses a system that analyzes the content of data blocks using statistical methods to determine a data type and then selects an optimal, data-type-specific compression algorithm. This analysis is not based solely on a descriptor. However, when Hsu's system fails to identify a useful data type with an associated encoder, it forgoes compression for that block.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would have been motivated to modify Hsu’s system by incorporating the teachings of Franaszek. Franaszek expressly teaches using a default list of compression methods when a specific data type for a block is not available. The motivation would be to improve Hsu’s system to achieve a higher overall compression ratio—a primary goal in the field—by attempting to compress all data blocks, rather than leaving some uncompressed. Hsu’s choice to not compress was presented as a way to conserve computing resources, but a POSITA seeking maximum compression would have found Franaszek’s approach beneficial.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. Implementing a default encoder in Hsu’s system would be a simple and predictable modification, such as adding an "else" condition to the existing logic. This would involve substituting one known solution (no compression) with another known solution (default compression) to achieve a predictable improvement in performance.

Ground 2: Claim 48 is 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 asserted that Franaszek discloses a system that selects compression methods based on a "data type" field associated with a data block and uses a default compression method list if that field is unavailable. This teaches the "default encoder" limitation. However, Franaszek is silent on how to determine the data type if the field is empty and relies on a descriptor (the "type field" itself), failing to teach the limitation of analyzing data content where analysis is not based only on a descriptor.
    • Motivation to Combine: A POSITA implementing Franaszek's system would be motivated to incorporate Hsu's teachings to handle data blocks lacking a pre-populated "type field." Hsu provides a well-known method for analyzing the actual data content—using statistical analysis of the data itself—to determine its type without relying on a descriptor. This directly addresses the gap in Franaszek's disclosure and would allow the system to handle a wider variety of data.
    • Expectation of Success: The combination was presented as a straightforward application of a known data analysis technique (from Hsu) to an existing compression framework (from Franaszek). A POSITA would expect this combination to work predictably, enabling Franaszek's system to classify previously unidentifiable data blocks.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that Claim 48 is obvious over Hsu in view of Sebastian (Patent 6,253,264) and over Franaszek in view of Chu (Patent 5,467,087). These arguments relied on similar rationales, with Sebastian providing an alternative teaching of a "generic" or "default" encoder to supplement Hsu, and Chu providing an alternative method for analyzing data content itself to supplement Franaszek.

4. Key Claim Construction Positions

  • “analyzing”/“analyze”: Petitioner noted that for the purposes of the petition, it applied the construction from a related district court case: “directly examining / directly examine.” This construction supports the argument that references like Hsu, which perform statistical analysis directly on the data bits, meet this limitation.
  • “default encoder”: Petitioner adopted the agreed-upon construction from the related litigation: “an encoder used automatically in the absence of a designated alternative.” This construction is central to the obviousness grounds, as secondary references like Franaszek and Sebastian were cited specifically for teaching this exact functionality.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claim 48 of the ’992 patent as unpatentable.