PTAB

IPR2018-00582

Hulu LLC v. Sound View Innovations LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Real-Time Event Processing System With Analysis Engine Using Recovery Information
  • Brief Description: The ’133 patent discloses methods and systems for processing computer events in real-time, particularly for applications with demanding performance requirements like telecommunications. The core technology involves a "real-time analysis engine" that uses a "main-memory database system" to achieve high speeds and a mechanism for storing recovery information to restore the system to a previous state after a failure.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hvasshovd in view of Kao and DeWitt - Claims 1, 9-13, and 21 are obvious over Hvasshovd, Kao, and DeWitt.

  • Prior Art Relied Upon: Hvasshovd (a 1995 conference proceeding on telecom databases), Kao (a 1995 book chapter on real-time database systems), and DeWitt (a 1984 conference paper on main-memory database implementation).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hvasshovd disclosed a real-time event processing system for telecommunications that used a main-memory database (the "ClustRa" system) to meet high throughput and response time requirements, thus teaching the core limitations of claim 1. Hvasshovd’s system processed events like call routing and number mapping, similar to the ’133 patent. Petitioner contended that Hvasshovd also taught storing recovery information via a "main-memory logging technique" that writes transaction logs to the main memory of a neighbor node, including "checkpoints" that function as recovery points. To the extent Hvasshovd's recovery teachings were considered insufficient, Petitioner asserted that Kao and DeWitt remedied any deficiency. Kao and DeWitt taught that main-memory databases are inherently volatile and require recovery mechanisms. They explicitly disclosed storing recovery information (e.g., transaction logs, checkpoints) in stable storage or a battery-backed portion of main memory to allow the database to be restored to a consistent state after a failure.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to improve the reliability of Hvasshovd’s system. Since Hvasshovd employed a main-memory database, a POSITA would have recognized the known problem of data loss upon power failure, as taught by Kao. To create a commercially viable and robust system, a POSITA would be motivated to incorporate the well-known recovery techniques for main-memory databases described in detail by Kao and DeWitt. The goal was to ensure data integrity and enable fast system restarts, which are critical for real-time applications.
    • Expectation of Success: A POSITA would have had a high expectation of success, as this involved applying a standard solution (database recovery) to a known problem (volatility in main-memory databases) to yield a predictable result.

Ground 2: Obviousness over O'Neil in view of Kao and DeWitt - Claims 1, 9-13, and 21 are obvious over O'Neil, Kao, and DeWitt.

  • Prior Art Relied Upon: O'Neil (Patent 6,226,364), Kao (a 1995 book chapter), and DeWitt (a 1984 conference paper).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that O'Neil disclosed a "real-time telephone call monitoring, rating, and response system" that constituted the claimed "real-time analysis engine." O'Neil’s system processed events from a Mobile Switching Center in real-time to perform functions like debit-based billing and fraud detection. However, O'Neil did not explicitly disclose that its databases were main-memory based. Petitioner asserted that Kao and DeWitt supplied this missing element. Kao taught that using main-memory databases was desirable or even necessary for real-time systems like the telephone switching application in O'Neil to achieve "fast and predictable access time." Kao and DeWitt further provided the necessary teachings for storing recovery information for such a main-memory database.
    • Motivation to Combine: A POSITA would combine O'Neil with Kao and DeWitt to improve the performance and reliability of O'Neil's real-time system. To meet the stringent timing requirements of a real-time billing system like O'Neil's, a POSITA would have been motivated to replace its conventional databases with the high-performance main-memory databases taught by Kao. The modular nature of O'Neil's architecture, where databases function as interchangeable components, would make this substitution straightforward. Once a volatile main-memory database was incorporated, a POSITA would have been further motivated to add the recovery features taught by Kao and DeWitt to ensure data persistence and system stability.
    • Expectation of Success: The combination was presented as a predictable substitution of known components to enhance system performance, which would have yielded the expected benefits of increased speed and reliability without undue experimentation.

4. Key Claim Construction Positions

  • "event": Petitioner proposed construing this term as "any type of transaction involving contents of a database system, such as, for example, a group of read update, delete and/or modify operations," based on an explicit definition in the ’133 patent specification.
  • "real-time analysis engine": Petitioner proposed this term be construed as "a portion of a high-throughput computer system that aggregates or processes computer events in real-time." This construction was based on descriptions of the engine's function in the specification.
  • "in a main-memory database system": Petitioner agreed with a construction previously proposed by the Patent Owner in related litigation, construing the term to mean "in a database that resides entirely or almost entirely in main memory."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 9-13, and 21 of the ’133 patent as unpatentable under 35 U.S.C. §103.