PTAB

IPR2017-02006

Commvault Systems Inc v. Realtime Data LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression System
  • Brief Description: The ’530 patent describes a data storage system that uses data compression to reduce the time required for data transmission and storage. The system employs a data accelerator with high-speed encoders to losslessly compress an input data stream at a rate faster than the data could otherwise be stored on a memory device.

3. Grounds for Unpatentability

Ground 1: Claims 1-5, 13-21, 23, and 25 are obvious over Chu in view of Fox.

  • Prior Art Relied Upon: Chu (Patent 5,467,087) and Fox ("Adapting to Network and Client Variability via On-Demand Dynamic Distillation," an ACM article from Oct. 1996).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chu, which describes a "high speed lossless data compression" system, teaches nearly all limitations of the challenged claims. Chu discloses a system that receives a data stream, uses different techniques (e.g., Lempel-Ziv, Huffman) for different data types (e.g., ASCII, binary), and stores the compressed data with a descriptor in a memory buffer. The key limitation that Chu allegedly does not explicitly teach—that "compression and storage occurs faster than said data stream is able to be stored on said memory device in said received form"—is supplied by Fox. Fox, an article not previously considered by the PTO, empirically demonstrates through performance charts that its "distillation" (compression) system significantly reduces end-to-end latency, allowing data to be transmitted and stored faster than the original uncompressed data.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the teachings of Chu and Fox to improve the performance and versatility of Chu's system. Both references address the same problem of speeding up data handling through datatype-specific compression. A POSITA would have been motivated to incorporate Fox's demonstrably faster techniques into Chu's foundational system to achieve superior speed, a recognized goal in the field.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. The underlying compression principles (e.g., Lempel-Ziv, Huffman) and system goals were compatible and well-understood. Integrating Fox's performance-enhancing methods into Chu's framework would have been a routine optimization to improve its versatility and efficiency.

Ground 2: Claims 6-12 are obvious over Chu in view of Fox and Wood.

  • Prior Art Relied Upon: Chu (Patent 5,467,087), Fox (Oct. 1996 ACM article), and Wood ("DASD Trends: Cost, Performance, and Form Factor," an IEEE article from Apr. 1993).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combination of Chu and Fox from Ground 1. Dependent claims 6-12 add limitations specifying various well-known memory devices and interfaces, such as a small computer systems interface (SCSI), fibre channel, magnetic memory, optical memory, and solid-state storage. Petitioner argued that Wood, which had not been previously considered, explicitly teaches that data compression techniques are compatible with this exact range of storage technologies and interfaces to improve their capacity and performance.
    • Motivation to Combine: A POSITA would combine Wood with the Chu/Fox system to expand its compatibility with a wide array of conventional and readily available hardware. Doing so would allow the resulting compression system to be used in more applications at various price points, a clear design advantage.

Ground 3: Claims 22 and 26 are obvious over Chu in view of Fox and Rynderman.

  • Prior Art Relied Upon: Chu (Patent 5,467,087), Fox (Oct. 1996 ACM article), and Rynderman (Patent 5,563,961).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground also builds on the Chu and Fox combination. Claim 22 adds the limitation of processing "analog video," which Rynderman's video compression system expressly discloses. Claim 26 requires adjusting the data rate of the compressed stream by adjusting the encoder's compression ratio. Rynderman teaches this by describing "adaptive control of the bandwidth of processed data output" to match the capabilities of the storage device.
    • Motivation to Combine: A POSITA would incorporate Rynderman's teachings to add adaptive bandwidth control to the Chu/Fox system. This would prevent overloading storage devices with data faster than they could handle it and enhance compatibility with a wider range of client devices. Given the similar goals, adapting the Chu/Fox system with Rynderman's features would have been a logical step to improve system robustness.

Ground 4: Claim 24 is obvious over Chu in view of Fox, Rynderman, and Clark.

  • Prior Art Relied Upon: Chu (Patent 5,467,087), Fox (Oct. 1996 ACM article), Rynderman (Patent 5,563,961), and Clark (Patent 5,319,682).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses claim 24, a claim added during reexamination. Most limitations of claim 24 are taught by the Chu/Fox combination. For the remaining limitations, Clark supplies the teaching of determining the bandwidth of the received data stream by "observ[ing] the incoming stream of characters." Rynderman, as in Ground 3, supplies the teaching of adjusting the data rate of the compressed data stream to make its bandwidth compatible with the memory device's bandwidth.
    • Motivation to Combine: A POSITA would combine these references to create a fully adaptive compression system. The combination allows the system to monitor the input data rate (per Clark) and adapt the output data rate (per Rynderman) to optimize the performance of the core compression engine (per Chu/Fox). This would be a routine optimization to create a more robust and efficient system.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that this IPR petition is not redundant of prior proceedings and should not be denied on discretionary grounds. The petition relies on new combinations of prior art, with two principal references (Fox and Wood) that have never been considered by the PTO in any prior IPR or the inter partes reexamination of the ’530 patent. Furthermore, the petition challenges all 26 claims, including many claims whose patentability has never been addressed in prior proceedings.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-26 of Patent 7,415,530 as unpatentable.