PTAB

IPR2017-01664

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 ’513 patent discloses systems and methods for data compression that analyze data blocks to select between content-dependent and content-independent compression algorithms. The analysis determines whether a specific characteristic, attribute, or parameter is recognized to apply a corresponding content-dependent algorithm.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hsu in view of Franaszek - Claims 1, 4, 14, and 15 are obvious over Hsu in view of Franaszek.

  • Prior Art Relied Upon: Hsu (“Automatic Synthesis of Compression Techniques for Heterogeneous Files,” a 1995 journal article) and Franaszek (Patent 5,870,036).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hsu discloses all limitations of the independent claims except for applying a content-independent algorithm when a data type is not identified. Hsu teaches a two-phase compression system: an analysis phase that uses statistical methods on data blocks to identify a "useful data type" and select a content-dependent encoder, and a compression phase. If the analysis phase does not identify a useful data type (i.e., one with an associated encoder in its database), Hsu teaches forgoing compression for that block to conserve computing resources. Franaszek was cited to remedy this deficiency, as it expressly teaches applying a default list of compression methods (i.e., a content-independent approach) when a data type for a block cannot be identified from its "type field."
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine Hsu and Franaszek to improve overall compression efficiency. While Hsu’s approach of not compressing unrecognized data saves computational overhead, a POSITA would recognize that data might be misclassified or be of a new, unknown type that is still compressible. A POSITA seeking to maximize data storage, a primary goal of compression, would have been motivated to replace Hsu’s "no compression" step with Franaszek’s "use a default compressor" step for unrecognized data blocks. This modification addresses the known problem of handling diverse and evolving data types.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the combination involves substituting one known technique (no compression) for another known, alternative technique (default compression) to achieve a predictable improvement in compression ratio. Implementing this change would involve basic programming logic (e.g., an "if-else" statement), which is well within the skill of a POSITA.

Ground 2: Obviousness over Hsu in view of Sebastian - Claims 1, 4, 14, and 15 are obvious over Hsu in view of Sebastian.

  • Prior Art Relied Upon: Hsu (a 1995 journal article) and Sebastian (Patent 6,253,264).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented a similar argument to Ground 1, with Sebastian serving the same role as Franaszek. Petitioner asserted Hsu teaches all elements of claim 1 except the use of a content-independent algorithm for unrecognized data. Sebastian was introduced because it teaches a compression system that applies data-type-specific "filters" (encoders) but uses a "generic" compression encoder, such as a Lempel-Ziv variant, if no installed filter matches the data format. This "generic" encoder is functionally equivalent to the claimed content-independent algorithm.
    • Motivation to Combine: The motivation was identical to that asserted in Ground 1. A POSITA would modify Hsu's system with Sebastian's teaching to ensure that data blocks with unrecognized formats are still attempted to be compressed, thereby improving the overall system performance for its primary purpose of saving space. Sebastian explicitly teaches that using a generic encoder is beneficial for handling a "wide range of data formats," including those unknown to the system.
    • Expectation of Success: The expectation of success was based on the same reasoning as Ground 1: combining two known technologies for their intended purposes to produce predictable results.

Ground 3: Obviousness over Franaszek in view of Hsu - Claims 1, 4, 14, and 15 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: This ground used Franaszek as the primary reference. Franaszek discloses analyzing a "data type" entry in a "type field" (a descriptor) to select a compression method. Petitioner argued that Franaszek is silent on how to determine the data type when the type field is empty or not present. Hsu was introduced to supply this missing element, as it teaches methods for analyzing the data content itself—using statistical analysis of data segments and calculating redundancy metrics—to identify a data type without relying on a descriptor.
    • Motivation to Combine: A POSITA implementing Franaszek's system would be motivated to incorporate Hsu's data analysis techniques to make the system more robust. By using Hsu's methods, the Franaszek system could generate the necessary "data type" information for blocks that lack a pre-existing descriptor, allowing it to process a wider variety of data streams. This combination would predictably extend the utility of Franaszek's system.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 1, 4, 14, and 15 based on the combination of Franaszek and Chu (Patent 5,467,087), which also relied on a similar design modification theory where Chu teaches methods of analyzing data itself to identify data types.

4. Key Claim Construction Positions

  • “analyzing”/“analyze”: Petitioner adopted the construction from a related district court case, meaning "directly examining / directly examine." This was used to argue that references like Hsu, which perform statistical analysis on the data itself, meet this limitation.
  • “content independent [data] compression algorithm”: Petitioner proposed the construction "compression algorithm for data for which a specific data type or content is not identified or recognized," which was previously used by the Board in a related IPR. This construction was central to arguing that the "default" or "generic" encoders in Franaszek and Sebastian meet the claim limitation for content-independent compression.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 4, 14, and 15 of the ’513 patent as unpatentable.