PTAB

IPR2018-00613

EchoStar Corporation v. Realtime Data LLC

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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 plurality of different encoders to process an input data stream. The system purports to achieve maximum compression by selecting an appropriate technique for a given data type, comparing the resulting compression ratio against a pre-specified threshold, and determining whether to output the compressed data or the original uncompressed data, particularly to avoid "negative compression" (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 under 35 U.S.C. §103.

  • Prior Art Relied Upon: Hsu (an Oct. 1995 publication 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 the core of the invention: a system that analyzes heterogeneous files on a block-by-block basis, determines the data type and compressibility, and selects the "best compression method" from a database of algorithms (e.g., Lempel-Ziv, RLE, JPEG). Hsu also explicitly taught outputting uncompressed data with a "no compression" code if negative compression occurred. Petitioner asserted that Kawashima augmented Hsu by teaching a system focused on improving system performance and storage capacity by preventing "wasteful data expansion." Kawashima explicitly taught comparing the size of compressed data to the input data and outputting the pre-compression (original) data if the size was the same or greater.
    • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would combine Hsu and Kawashima to achieve the shared, predictable goals of optimizing file size and reducing transmission speed. A POSITA would have been motivated to implement Kawashima's explicit check for data expansion into Hsu's system to further improve the space savings and execution time that were the fundamental benchmarks of Hsu's own heterogeneous compressor.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success because the references address the same problem with complementary solutions and suggest similar underlying technologies (e.g., both disclose using the Lempel-Ziv-Welch (LZW) algorithm). Integrating Kawashima’s compression ratio check into Hsu’s modular framework would be a routine modification.

Ground 2: Obviousness over Hsu, Kawashima, and Craft - Claim 36 is obvious over Hsu in view of Kawashima and Craft under §103.

  • Prior Art Relied Upon: Hsu, Kawashima (Patent 5,805,932), and Craft (Patent 5,627,534).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Hsu/Kawashima combination to specifically address the limitation in claim 36 requiring "a plurality of encoders that operate sequentially." Petitioner argued that Craft explicitly disclosed a "dual stage" or "multiple stage" lossless compressor where data is first processed by a "first compression means" (a run-length compressor) and its output is then fed to a "second compression means" (an LZ-1 compressor). This sequential operation was taught by Craft to improve overall compression efficiency and speed.
    • Motivation to Combine (for §103 grounds): A POSITA, seeking to further improve the compression ratio of the Hsu/Kawashima system, would be motivated to incorporate Craft's teaching of sequential compression. Hsu itself acknowledged the concept of running algorithms in succession (e.g., Lempel-Ziv and Huffman), and Craft provided a concrete hardware implementation and rationale for doing so, making the combination a predictable improvement.
    • Expectation of Success (for §103 grounds): Success was expected because Hsu's system was designed to be modular, and combining known compression techniques like those in Craft sequentially was a well-understood method for improving performance.

Ground 3: Obviousness over Hsu, Kawashima, and Franaszek - Claims 21 and 22 are obvious over Hsu in view of Kawashima and Franaszek under §103.

  • Prior Art Relied Upon: Hsu, Kawashima (Patent 5,805,932), and Franaszek (Patent 5,870,036).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed limitations in claims 21 and 22, which require determining that "no data type is associated with a second data block" and then compressing it with a second encoder. Petitioner contended that while Hsu taught determining data types, it did not explicitly address what to do if a data type was unidentifiable. Franaszek was argued to fill this gap by teaching a system that, if a data type is unavailable, uses a "default list of compression methods" to test and compress the block. This ensures that all blocks in a data stream, even those with unknown types, can be processed.
    • Motivation to Combine (for §103 grounds): A POSITA implementing the Hsu/Kawashima system would recognize the need for a fail-safe mechanism to handle data blocks of unknown or indiscernible types. Franaszek provided a known, advantageous solution by teaching a default compression pathway, ensuring the system could robustly handle any input stream.
    • Expectation of Success (for §103 grounds): A POSITA would readily understand how to integrate Franaszek’s default logic into Hsu's table-based algorithm selection by, for example, assigning the default methods to entries with a null data type. This was a minor, predictable modification to improve the system's robustness.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 30 over Hsu, Kawashima, and Dillon (Patent 6,658,463), arguing Dillon taught the claimed steps of transmitting and decompressing the data in a satellite network context.

4. Key Claim Construction Positions

  • "data block": Petitioner argued for the broadest reasonable interpretation, consistent with the specification, to mean "a single unit of data, which may range in size from individual bits through complete files or collection of multiple files." This broad construction was important for mapping the prior art, which processes data in various-sized units, to the claims.
  • "data block in received form": Petitioner contended this term should be construed to mean "data block that was not further compressed." This construction was critical to arguing that prior art systems like Hsu and Kawashima met claim limitations when they chose to output the original, uncompressed data after determining that compression would be inefficient or result in data expansion.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 16-17, 21-23, 26-27, 30, 32, and 36 of the ’707 patent as unpatentable.