PTAB

IPR2017-01688

Veritas Technologies LLC v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression Using Content-Dependent and Content-Independent Methods
  • Brief Description: The ’506 patent discloses a system for compressing data using a combination of content-dependent and content-independent encoders. The system analyzes a data block to determine if its data type is identifiable; if it is, a specific content-dependent encoder is used, and if not, a default or content-independent encoder is applied.

3. Grounds for Unpatentability

Ground 1: Claims 104 and 105 are obvious over Franaszek in view of Hsu, with an alternative combination including Sebastian.

  • Prior Art Relied Upon: Franaszek (Patent 5,870,036), Hsu (a 1995 journal article titled Automatic Synthesis of Compression Techniques for Heterogeneous Files), and Sebastian (Patent 6,253,264).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of references teaches every limitation of the challenged claims.
      • Franaszek was asserted to teach the core framework of the claims: a data compression method that analyzes a data block and selects an encoder based on whether a data type is identified. If a data type is known (via a "type field" descriptor), Franaszek selects an encoder from a pre-selected list associated with that type ("content dependent"). If the data type is unknown, it selects an encoder from a "default list" ("content independent"). This was argued to teach performing content-dependent compression if a data type is identified and performing data compression with a single or default encoder if it is not.
      • Hsu was introduced to supply the limitation requiring that the analysis of the data block "excludes analyzing based only on a descriptor." Petitioner contended this was the key feature that allowed the claims during reexamination. Hsu allegedly teaches this by determining a data block's type not from a descriptor, but by analyzing the actual content within the block itself. Specifically, Hsu describes analyzing samples from the beginning, middle, and end of the data block and comparing those samples to a collection of known data patterns to identify the "most applicable" data type.
      • Sebastian was presented as an alternative teaching for the "single data compression encoder" used when a data type is not identified. Sebastian discloses a "generic" filter (encoder) that is used when an installed encoder does not match the data's format. This generic filter provides a single, non-specific compression algorithm, which Petitioner argued would be an obvious substitute for Franaszek's method of testing multiple encoders from a default list.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Franaszek and Hsu to improve the data type identification process. Franaszek’s reliance on a simple descriptor is less robust for heterogeneous files where data types can vary within a block. Hsu directly addresses this known problem by teaching a content-based analysis. A POSITA would have been motivated to integrate Hsu’s superior data type analysis into Franaszek's established compression framework to achieve more accurate encoder selection and better overall compression. The motivation to substitute Sebastian's "generic" filter into the Franaszek/Hsu combination was presented as a simple design choice, trading potentially lower compression ratios for increased speed by eliminating Franaszek’s time-consuming process of sampling and testing multiple default encoders.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involves applying a known, improved data-type identification method (Hsu) to a known compression framework (Franaszek). The components were designed to solve related problems in the same field, and their integration would have been straightforward and predictable. Substituting Sebastian’s single generic encoder for Franaszek's default list was portrayed as a simple substitution of one known element for another to achieve a predictable tradeoff between speed and compression efficiency.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that institution was proper and requested joinder with an already-instituted proceeding, IPR2017-00176. The petition asserted that it presented the exact same challenged claims and unpatentability grounds as the instituted IPR, supplemented with additional evidentiary support, making joinder efficient and appropriate.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR), joinder with case IPR2017-00176, and cancellation of claims 104 and 105 of the ’506 patent as unpatentable under 35 U.S.C. §103.