PTAB

IPR2018-00614

EchoStar Corp v. Realtime Data LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression Systems and Methods
  • Brief Description: The ’728 patent discloses systems and methods for data compression that analyze data within a data block to identify its parameters or attributes. Based on this internal analysis, the system performs "content dependent data compression" using a selected encoder; if parameters are not identified, it may perform compression with a single encoder.

3. Grounds for Unpatentability

Ground 1: Obviousness over Franaszek, Hsu, and Sebastian - Claim 25 is obvious over Franaszek in view of Hsu and Sebastian under 35 U.S.C. § 103.

  • Prior Art Relied Upon: Franaszek (Patent 5,870,036), Hsu (Automatic Synthesis of Compression Techniques for Heterogeneous Files, Oct. 1995), and Sebastian (Patent 6,253,264).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Franaszek taught a foundational compression system that selects from a list of compression methods based on a data type descriptor provided with a data block. However, Franaszek relied on this external descriptor. Hsu was alleged to supply the missing element of analyzing the data within the block itself—using statistical sampling and calculating "redundancy metrics"—to determine the optimal compression algorithm. This combination met the claim limitation requiring analysis that "excludes analyzing based solely on a descriptor." Sebastian was asserted to teach the use of a single "generic" compression filter as a fallback when a data block's specific type is not recognized or supported, thereby disclosing the claimed "single data compression encoder."
    • Motivation to Combine: A POSITA would combine Franaszek with Hsu to improve compression efficiency and handle heterogeneous files where a simple descriptor is insufficient or unavailable. By analyzing the content itself, the system could make more intelligent compression choices. A POSITA would then add Sebastian's teaching to improve processing speed; using a single generic encoder as a default is faster and more efficient than Franaszek's method of testing an entire list of default encoders when a data type is unknown.
    • Expectation of Success: Petitioner contended that since all three references operate in the same technical field of data compression and address similar problems of efficiency and space savings, a POSITA would have a reasonable expectation of success. The underlying compression techniques (e.g., Lempel-Ziv) are compatible, making their integration straightforward.

Ground 2: Obviousness over Franaszek, Hsu, Sebastian, and Kawashima - Claim 25 is obvious over Franaszek in view of Hsu, Sebastian, and Kawashima under §103.

  • Prior Art Relied Upon: Franaszek (Patent 5,870,036), Hsu (Automatic Synthesis of Compression Techniques for Heterogeneous Files, Oct. 1995), Sebastian (Patent 6,253,264), and Kawashima (Patent 5,805,932).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground incorporated the arguments from Ground 1 and added Kawashima to further strengthen the obviousness case. Kawashima was presented as explicitly teaching a system that decides whether to output compressed data or the original, uncompressed data. It does so by comparing the actual compression ratio to a threshold to avoid "wasteful data expansion"—a situation where the compressed file is larger than the original. This directly supported the claim limitation of "determining...whether to output the data block in a received form or in a compressed form."
    • Motivation to Combine: A POSITA, having already combined Franaszek, Hsu, and Sebastian to create an efficient, adaptive compression system, would be further motivated to incorporate Kawashima's teachings. The motivation was to prevent negative compression, a known problem that wastes processing time and storage space. Adding an explicit check for data expansion, as taught by Kawashima, was argued to be a logical and predictable improvement to further optimize the system's overall performance.
    • Expectation of Success: The combination was asserted to be predictable because preventing data expansion is a fundamental goal in data compression. Integrating Kawashima's threshold comparison into the combined Franaszek/Hsu/Sebastian system was a minor modification that used known techniques for a predictable result.

4. Key Claim Construction Positions

  • "data block": Petitioner proposed this term means "a single unit of data, which may range in size from individual bits through complete files or collection of multiple files." This construction was based on the patent's specification.
  • "data block in [a/the] received form": Petitioner argued this term means a "data block that was not further compressed." This interpretation was central to mapping prior art that outputs original, uncompressed data when compression is ineffective.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claim 25 of Patent 9,054,728 as unpatentable.