PTAB

IPR2018-00613

EchoStar Corp v. Realtime Data LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: DATA COMPRESSION SYSTEMS AND METHODS
  • Brief Description: The ’707 patent discloses a system for data compression that uses a combination of content-independent and content-dependent techniques. The system employs a plurality of encoders and a compression ratio module to select an optimal compression method for an input data stream, with the goal of achieving maximum compression while avoiding data expansion.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hsu and Kawashima - Claims 16-17, 23, 26-27, 30, 32, and 36 are obvious over Hsu in view of Kawashima.

  • Prior Art Relied Upon: Hsu (a 1995 journal article titled "Automatic Synthesis of Compression Techniques for Heterogeneous Files") and Kawashima (Patent 5,805,932).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hsu taught a characteristic-dependent compression system that analyzes data blocks to determine their type and compressibility, then applies the "best compression method" from a database of algorithms. Hsu also disclosed outputting data uncompressed if "negative compression" (i.e., data expansion) occurred, along with a code for 'no compression'. Petitioner contended that Kawashima augmented Hsu by teaching a system that explicitly prevents "wasteful data expansion" by comparing the compressed data size to the input data size and outputting the pre-compression data if expansion occurred. The combination was alleged to teach all limitations of independent claims 16 and 17, including receiving a data block, selecting a compression technique from a plurality, determining if data expansion occurred, and outputting either the compressed data block or the original block in its received form with an appropriate descriptor.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Hsu and Kawashima to improve both space savings and execution time, which were fundamental benchmarks for compression systems. Petitioner asserted a POSITA would use Hsu's sophisticated framework for selecting the best algorithm for heterogeneous files and supplement it with Kawashima’s explicit and efficient check for data expansion to create a more robust and practical system. Both references addressed the common goal of optimizing data compression and shared similar underlying technologies, such as Lempel-Ziv (LZ) compression.
    • Expectation of Success: Petitioner argued a POSITA would have a high expectation of success, as the combination required implementing a known technique (Kawashima's expansion check) into a system (Hsu's) that was explicitly designed to be modular and allow for the addition or modification of compression methods and heuristics.

Ground 2: Obviousness over Hsu, Kawashima, and Craft - Claim 36 is obvious over Hsu in view of Kawashima and Craft.

  • Prior Art Relied Upon: Hsu, Kawashima, and Craft (Patent 5,627,534).
  • Core Argument for this Ground: This ground focused on the limitation in claim 36 requiring "a plurality of encoders that operate sequentially."
    • Prior Art Mapping: Petitioner asserted that Craft explicitly taught a "dual stage" compression method using successive operations: a first-stage run-length compressor followed by a second-stage LZ compressor. This directly disclosed the sequential operation of a plurality of encoders.
    • Motivation to Combine: A POSITA would be motivated to add Craft's sequential compression structure to the Hsu/Kawashima system to achieve greater compression ratios. Craft taught that its two-stage approach created a synergistic effect that improved efficiency, a goal shared by the base combination. Furthermore, Hsu itself contemplated "running several algorithms in succession," making the integration of Craft's specific implementation a logical and predictable improvement.

Ground 3: Obviousness over Hsu, Kawashima, and Dillon - Claim 30 is obvious over Hsu in view of Kawashima and Dillon.

  • Prior Art Relied Upon: Hsu, Kawashima, and Dillon (Patent 6,658,463).
  • Core Argument for this Ground: This ground targeted claim 30’s limitations of "transmitting said compressed data block" and subsequently "decompressing said compressed data block based on said descriptor."
    • Prior Art Mapping: Dillon disclosed a point-to-point network system that performed compression to optimize transmission speed between a server and clients. Petitioner argued Dillon taught transmitting compressed data along with "Compression Information" in data headers that "defines how to decompress the block," which constituted the claimed descriptor.
    • Motivation to Combine: A POSITA would combine Dillon's network transmission system with the Hsu/Kawashima compression engine to apply its advanced, content-aware compression method to a practical network environment. This would realize the optimized transmission speed offered by both Dillon and the base combination.

Ground 4: Obviousness over Hsu, Kawashima, and Franaszek - Claims 21 and 22 are obvious over Hsu in view of Kawashima and Franaszek.

  • Prior Art Relied Upon: Hsu, Kawashima, and Franaszek (Patent 5,870,036).
  • Core Argument for this Ground: This ground addressed limitations related to processing a second data block and "determining that no data type is associated with" it.
    • Prior Art Mapping: Petitioner argued that while Hsu taught processing blocks by type, Franaszek explicitly disclosed a system for handling blocks where the data type is unknown. Franaszek’s system applied a "default list of compression methods" when no data type was available, ensuring all blocks in a stream could be processed.
    • Motivation to Combine: A POSITA would integrate Franaszek's teachings to make the Hsu/Kawashima system more robust and universally applicable. This would allow the system to handle any data block within an input stream, including those with no predefined data type, which was a foreseeable issue in real-world applications.

4. Key Claim Construction Positions

  • "data block": Petitioner proposed this term be construed broadly to mean "a single unit of data, which may range in size from individual bits through complete files or collection of multiple files." This construction was important for applying prior art references that discussed compressing files, packets, or blocks interchangeably to the claims.
  • "data block in received form": Petitioner proposed this term be construed to mean a "data block that was not further compressed." This construction was critical for arguing that prior art disclosing the output of original, unprocessed data (e.g., when compression resulted in data expansion) met this specific claim limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 16, 17, 21-23, 26, 27, 30, 32, and 36 of Patent 8,502,707 as unpatentable.