PTAB

IPR2017-02007

Commvault Systems Inc v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression and Decompression in a Data Storage System
  • Brief Description: The ’908 patent describes a system for accelerating data storage and retrieval by using data compression. The system employs a "data accelerator" with high-speed encoders to losslessly compress an input data stream at a rate faster than the stream could be stored uncompressed, thereby reducing the time required for data transmission and storage.

3. Grounds for Unpatentability

Ground 1: Claims 1-7, 9-25, and 27-30 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," a 1996 article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chu, a patent for a high-speed lossless data compression system, taught nearly all limitations of the independent claims. Chu described applying different compression techniques (e.g., Lempel-Ziv, Huffman) based on the input data type and storing a descriptor with the compressed data. To the extent Chu did not explicitly teach that the overall compression and storage process is faster than storing uncompressed data, Petitioner asserted that Fox supplied this limitation. Fox provided empirical data showing its "distillation" (compression) system resulted in greatly reduced end-to-end latency compared to transmitting uncompressed data. Fox also supplied teachings for various dependent claims, including parallel encoding (claim 13), real-time compression (claim 16), processing audio/video data (claim 18), and receiving data over a communications channel (claim 19).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Chu and Fox to improve system performance. Petitioner asserted that Fox empirically demonstrated the primary benefit claimed by the ’908 patent—that compressing data can speed up overall storage and transmission. A POSITA would have been motivated to incorporate the proven speed-enhancing techniques of Fox into Chu’s versatile compression system. Both systems shared the goal of high-speed data processing and used compatible, well-known compression techniques (e.g., Lempel-Ziv), making their integration straightforward.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because combining the references was a matter of applying a known technique (Fox's data-specific compression) to a similar system (Chu's) to achieve a predictable result (improved end-to-end performance). The underlying data compression principles in both references were compatible.

Ground 2: Claim 8 is obvious over Chu in view of Fox and Wood

  • Prior Art Relied Upon: Chu (Patent 5,467,087), Fox (a 1996 article), and Wood ("DASD Trends: Cost, Performance, and Form Factor," a 1993 IEEE article).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1. Dependent claim 8 adds the limitation that the data accelerator is coupled to the memory device via an "industry standard disk interface." Petitioner argued that while Chu and Fox provided the core compression system, Wood taught the missing element. Wood provided an overview of existing, industry-standard disk interfaces, such as Small Computer Systems Interface (SCSI), and explicitly noted their compatibility with data compression to improve storage capacity.
    • Motivation to Combine: A POSITA would combine Wood's teachings with the Chu/Fox system for reasons of practicality and interoperability. To implement the compression system of Chu/Fox in a real-world environment, a POSITA would naturally use conventional, well-known disk interfaces. Wood provided a guide to available standard interfaces, making it an obvious choice for a designer seeking to connect the compression accelerator to storage.
    • Expectation of Success: Success would be expected, as implementing a system using standard hardware interfaces like SCSI was a routine and predictable aspect of computer system design at the time.

Ground 3: Claim 26 is obvious over Chu, Fox, Rynderman, and Clark

  • Prior Art Relied Upon: Chu (Patent 5,467,087), Fox (a 1996 article), Rynderman (Patent 5,563,961), and Clark (Patent 5,319,682).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination for claim 25 (part of Ground 1). Dependent claim 26 adds limitations for (1) determining the bandwidth of the received data blocks and (2) adjusting a system parameter to make the compressed data's bandwidth compatible with the memory device's bandwidth. Petitioner argued that Clark taught the first element by describing an adaptive system that "observes the incoming stream of characters" to "measure the data rate at the input." Petitioner argued Rynderman taught the second element by describing "adaptive control of the bandwidth of processed data output" to match the capabilities of a storage device.
    • Motivation to Combine: A POSITA would combine Clark and Rynderman with the Chu/Fox system to create a more sophisticated and adaptive system. Clark’s input monitoring and Rynderman’s output control would allow the base system to dynamically adjust its performance based on network conditions and storage device characteristics. This would improve efficiency and expand the range of devices and networks the system could work with, which are powerful motivators for combination.
    • Expectation of Success: A POSITA would have a high expectation of success, as Clark and Rynderman both taught adaptive techniques specifically for data compression systems. Integrating these known adaptive control features into the otherwise compatible Chu/Fox system would have been a straightforward design improvement.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that this IPR was not redundant of prior proceedings involving the ’908 patent. The petition asserted that it addressed the patentability of claims not challenged in prior IPRs (specifically challenging all 30 claims). Furthermore, it argued that the grounds relied on new combinations of prior art (Chu, Fox, Wood, Clark, and Rynderman) that were not considered during original prosecution or in any prior IPR petition, thus presenting new questions of patentability for the Board to consider.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-30 of the ’908 patent as unpatentable.