PTAB

IPR2018-00612

EchoStar Corporation v. Realtime Data LLC

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1. Case Identification

2. Patent Overview

  • Title: METHODS FOR ENCODING AND DECODING DATA
  • Brief Description: The ’204 patent discloses systems and methods for accelerating data transmission, particularly for broadcast data such as financial data, over a communication channel. The invention purports to achieve this by using content-dependent data compression and decompression, where encoders are selected based on characteristics of data fields within data packets to effectively increase bandwidth and reduce latency.

3. Grounds for Unpatentability

Ground 1: Claims 12-14 and 21 are obvious over Hsu in view of Kawashima and Welch under 35 U.S.C. §103.

  • Prior Art Relied Upon: Hsu (Automatic Synthesis of Compression Techniques for Heterogeneous Files, Oct. 1995), Kawashima (Patent 5,805,932), and Welch (A Technique for High-Performance Data Compression, Jun. 1984).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these references teaches every element of independent claim 12. Hsu taught a method for processing heterogeneous files by analyzing blocks of data to determine their characteristics (e.g., data type, compressibility) and then selecting the "best compression method" from a database of algorithms for each block. This mapped to the limitations of recognizing a data characteristic and selecting an appropriate encoder. Kawashima taught a system that ensures the total time for compression, transmission, and decompression is less than the time for transmitting the data in uncompressed form, directly addressing the "acceleration" aspect of the claims. Welch disclosed the widely-used Lempel-Ziv-Welch (LZW) algorithm, which uses a "simple state machine" for fast and efficient compression, satisfying the claim requirement of utilizing a state machine. Hsu also taught that its methods could achieve compression ratios of 15:1 to 25:1, meeting the claimed "over 4:1" ratio.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to achieve the well-known goal of optimizing data transmission speed and reducing file size. A POSITA would start with Hsu's adaptive compression framework and incorporate Kawashima's timing constraint to ensure that the compression actually resulted in faster overall transmission. To implement this efficiently, a POSITA would turn to Welch's well-known LZW state machine, which provided a fast, simple, and proven method for achieving the compression taught by Hsu.
    • Expectation of Success: Petitioner asserted a high expectation of success because the references are complementary and address the same technical field. Hsu itself suggested using LZW-type algorithms, and Welch provided the details for an efficient implementation. Integrating Kawashima's timing check was described as a routine optimization, requiring only the selection of algorithms from Hsu's database that meet the timing criteria, a predictable and straightforward modification.

Ground 2: Claims 13 and 20 are obvious over Hsu in view of Kawashima, Welch, and Dillon under §103.

  • Prior Art Relied Upon: Hsu (Automatic Synthesis of Compression Techniques for Heterogeneous Files, Oct. 1995), Kawashima (Patent 5,805,932), Welch (A Technique for High-Performance Data Compression, Jun. 1984), and Dillon (Patent 6,658,463).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1, adding Dillon to address the client-server limitations in dependent claims 13 and 20. Dillon disclosed a communication system with an upstream proxy server that compresses data and downstream proxy servers (clients) that decompress it, all connected via a "two-way point-to-point network." Dillon's upstream server performed "homogenized content compression" to optimize transmission to the downstream clients, which could "reside with the browser on a single personal computer." This architecture directly taught the limitations of compressing on a server, transmitting from the server, and decompressing at the client.
    • Motivation to Combine: A POSITA seeking to apply the advanced compression system of Hsu/Kawashima/Welch in a practical network environment would have been motivated to implement it within a standard client-server architecture like the one taught by Dillon. Dillon's system was designed for the very purpose of accelerating data delivery over a network using compression, making it a natural and logical framework for integrating the specific compression techniques of the other references to achieve improved performance.
    • Expectation of Success: Success would be expected, as this combination involved applying a known compression method (from Hsu/Kawashima/Welch) within a known network architecture (from Dillon) to achieve the predictable result of faster data transmission. The modifications required, such as using the combined compression logic on Dillon's upstream proxy server, were presented as routine engineering tasks.

4. Key Claim Construction Positions

  • "data packet": Petitioner argued that for the purposes of the IPR, this term should be given its broadest reasonable interpretation. Based on the patent's specification, Petitioner contended this term should be construed as "a segregation of data that does not require a specific internal structure." This broad construction was important to Petitioner's arguments because it allowed prior art that discussed compressing "files" or "blocks" of data, like Hsu, to be mapped onto the "data packet" limitation of the challenged claims, even without disclosing a formally structured network packet.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review for claims 12-14, 20, and 21 of Patent 8,717,204, and a final determination that these claims are unpatentable and should be canceled.