PTAB

IPR2017-01690

Veritas Technologies LLC v. Realtime Data LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression Systems and Methods
  • Brief Description: The ’728 patent discloses a data compression system that uses a combination of content-dependent and content-independent data compression. The system analyzes a data block to identify parameters or attributes and, based on that identification, selects either one or more content-dependent encoders or a single, default content-independent encoder to perform compression.

3. Grounds for Unpatentability

Ground 1: Obviousness over Franaszek and Hsu - Claims 1-3, 9, 10, 15, 20, and 24 are obvious over Franaszek in view of Hsu, with an alternative combination including Sebastian.

  • Prior Art Relied Upon: Franaszek (Patent 5,870,036), Hsu (W.H. Hsu, et al., Automatic Synthesis of Compression Techniques for Heterogeneous Files, Oct. 1995), and Sebastian (Patent 6,253,264).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Franaszek taught nearly all elements of the challenged claims. Franaszek described a system that selects a content-dependent encoder from a "Compression Method List" if a data block's type is specified in a type field. If the data type is not specified, Franaszek taught selecting a single default encoder from a default list by testing samples of the data block. The key limitation added during prosecution, which Petitioner alleged led to allowance, required "analyzing of the data within the data block" that "excludes analyzing based solely on a descriptor." Petitioner contended that Hsu explicitly taught this missing element. Hsu described a system for compressing heterogeneous files by analyzing samples from the beginning, middle, and end of a data block to determine its type and calculating "redundancy metrics" to assess compressibility. This analysis of the data payload itself, rather than just a descriptor field, directly addressed the supposedly novel feature of the ’728 patent. The alternative reference, Sebastian, was cited primarily for its disclosure of a single "generic" filter used when a specific, format-matching filter is not available, reinforcing the obviousness of using a single default encoder.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Hsu's method of analyzing the data payload with Franaszek's overall compression framework to create a more robust system. This combination would improve the ability to handle heterogeneous files, where a simple data type descriptor (as in Franaszek) might be insufficient or inaccurate. Hsu’s analysis provides a better basis for selecting the optimal compression algorithm, a well-known goal in the art.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success as both Franaszek and Hsu operate in the same field of data compression and address the common problem of selecting appropriate encoders for different data types. Integrating Hsu's known data analysis techniques into Franaszek's system was presented as a predictable improvement.

Ground 2: Obviousness over Franaszek, Hsu, and Aakre - Claims 4-8 are obvious over Franaszek in view of Hsu and further in view of Aakre.

  • Prior Art Relied Upon: Franaszek (Patent 5,870,036), Hsu (W.H. Hsu, et al., Oct. 1995), and Aakre (Patent 4,956,808).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Franaszek and Hsu from Ground 1 to address the additional limitation in claims 4-8 requiring that compression be "performed in real-time." While Franaszek was silent on this aspect, Petitioner asserted that Aakre explicitly taught a "real time data transformation and transmission apparatus." Aakre's system was designed to compress data in real-time to match the device requirements for storage media like tape drives, allowing the tape to operate in a continuous "streaming mode" and avoiding inefficient starts and stops.
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to incorporate the real-time processing capabilities taught by Aakre into the compression system of Franaszek/Hsu to solve the known problem of efficiently writing compressed data to slower storage media. Since both Franaszek and Aakre contemplated use with tape-based storage systems, applying Aakre's known solution (a controller and buffer for real-time streaming) to improve Franaszek's system would have been an obvious and beneficial modification to enhance performance.
    • Expectation of Success (for §103 grounds): Integrating a known technique for real-time data processing into a data compression system to improve I/O performance was a predictable application of existing technologies to achieve a known benefit.

4. Key Claim Construction Positions

  • "the data block being included in one or more data blocks" (claims 2 and 3): Petitioner argued that this phrase should be interpreted to mean the data block is "included among a group of one or more data blocks." This construction was proposed to align the claim language with the specification's description of processing a data stream comprised of multiple data blocks, resolving a potential ambiguity where the claim could be read to mean a data block is contained within another data block.

5. Relief Requested

  • Petitioner requested institution of an inter partes review, cancellation of claims 1-10, 15, 20, and 24 of the ’728 patent as unpatentable, and joinder with the instituted review in IPR2017-00179.