PTAB

IPR2017-01691

Rackspace US 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 ’867 patent discloses systems and methods for data compression. The invention receives a stream of data blocks and determines whether to compress each block by testing various encoders, selecting the best result based on a compression ratio threshold, and outputting either the compressed block with a corresponding descriptor or the original block with a null descriptor.

3. Grounds for Unpatentability

Ground 1: Claims 16 and 17 are obvious over Dawson in view of Franaszek and Christensen.

  • Prior Art Relied Upon: Dawson (Patent 5,553,160), Franaszek (European Patent Application Publication EP 0729237 A2), and Christensen (Patent 5,555,377).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of references teaches every element of the challenged claims. Dawson was asserted to teach the core method of dynamically determining whether to compress an image (a "data block") on a block-by-block basis using either a lossless or lossy encoder, or not at all. Dawson also taught including header information with the output to indicate which compression process was used. To address the "several encoders" limitation of claim 16, Petitioner contended that Franaszek taught testing multiple different lossless compression encoders (e.g., run-length, arithmetic, static dictionary) on a data sample to determine the most effective one. To address the "null data compression type descriptor" limitation, Petitioner pointed to Christensen, which explicitly disclosed using a "compress bit" in a data frame header (set to 0) to indicate when a data block is not compressed.
    • Motivation to Combine (for §103 grounds): Petitioner presented two primary motivations for combining the references.
      • Dawson and Franaszek: A person of ordinary skill in the art (POSITA) would combine Franaszek with Dawson to improve Dawson’s method. Dawson taught choosing between a single lossless and a single lossy encoder. Franaszek taught the known technique of testing multiple lossless encoders to find the one that produces the best compression. Petitioner argued it would have been obvious to apply Franaszek's technique to Dawson's system to enhance its efficiency by selecting from a wider array of encoders to find the optimal compression method, a predictable improvement.
      • Dawson and Christensen: A POSITA would have been motivated to modify Dawson’s header information with Christensen’s null-compression indicator. Dawson taught including a header indicating the type of compression used but did not explicitly teach an indicator for when no compression is performed. Christensen taught this exact feature for the same purpose: using a specific bit value to signal that a data block is uncompressed. A POSITA would incorporate this feature into Dawson’s system to provide complete status information to the receiving agent, thereby avoiding wasted processing time trying to decompress an uncompressed block.
    • Expectation of Success (for §103 grounds): Petitioner argued a POSITA would have had a high expectation of success because combining the references involved applying known techniques (testing multiple encoders, using a null indicator bit) to a known type of system (selective data compression) to achieve predictable and beneficial results.

4. Key Claim Construction Positions

  • Petitioner asserted that two key terms required construction to properly evaluate the prior art.
    • "data block(s)": Petitioner proposed this term encompasses "a block of data or blocks of data ranging in size from a single bit through a complete file or a collection of multiple files." This construction was argued as necessary to show that the "image file" processed by Dawson qualifies as a "data block" under the ’867 patent.
    • "encoder": Petitioner proposed this term encompasses "a software or hardware element for compressing data." This construction was used to argue that the compression processes and compressors disclosed in Dawson and Franaszek (which include software routines and hardware components) meet the "encoder" limitation of the claims.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §325(d) would be inappropriate. It acknowledged that claims 16 and 17 of the ’867 patent were previously challenged in another inter partes review, IPR2017-00557. However, Petitioner asserted it was not a party to that proceeding and that this petition presents different prior art combinations, new arguments, and different expert declaration testimony. Citing PTAB precedent, Petitioner contended that these differences fall outside the scope of §325(d), which is intended to prevent duplicative challenges, and that the Board should consider the new unpatentability case on its merits.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 16 and 17 of the ’867 patent as unpatentable under 35 U.S.C. §103.