PTAB

IPR2018-01187

Hulu LLC v. Realtime Adaptive Streaming LLC

Log In

1. Case Identification

2. Patent Overview

  • Title: Adaptive Data Compression System
  • Brief Description: The ’477 patent relates to a system for compressing data that dynamically selects from a plurality of different asymmetric data compression encoders. The selection is based upon the determined or expected throughput of a communications channel to balance compression speed and compression ratio.

3. Grounds for Unpatentability

Ground 1: Obviousness over Pauls - Claims 1, 3-6, and 9-14 are obvious over Pauls.

  • Prior Art Relied Upon: Pauls (European Application # EP0905939A2).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Pauls, by itself, taught all limitations of the challenged claims. Pauls described an "access server" that performed "adaptive communications formatting" by selecting from a plurality of transcoders for various data types, including video and image. The transcoders utilized well-known asymmetric compression algorithms like H.263, MPEG, and MPEG-2. Critically, Pauls taught that the selection of the transcoding technique is adaptive to factors including the "nature of the communications network," which explicitly includes the "available bandwidth" and "bit rate," directly corresponding to the throughput-based selection claimed in the ’477 patent. Pauls also taught that selection could be based on data type, meeting limitations for content-dependent compression.
    • Motivation to Combine: Not applicable (single reference ground).

Ground 2: Obviousness over Imai and Pauls - Claims 1, 3-6, and 9-14 are obvious over Imai in view of Pauls.

  • Prior Art Relied Upon: Imai (Japanese Application # H11331305) and Pauls (European Application # EP0905939A2).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Imai disclosed a data transmission system that selects an appropriate encoder from a plurality of asymmetric audio encoders based on the detected throughput of a network. Imai provided a detailed methodology for measuring this throughput by timing data packet transmission. While Imai focused on audio, it expressly stated its invention was "applicable to other signals such as video signals." Pauls provided extensive teachings on applying this exact concept to video, disclosing a plurality of standard asymmetric video transcoders (e.g., H.263, MPEG). The combination of Imai’s throughput determination method with Pauls’ video-specific implementation rendered the claims obvious.
    • Motivation to Combine: A POSITA would combine Imai and Pauls because they addressed the same problem of adaptive encoding for network transmission. A POSITA implementing Imai's system for video, as Imai suggested, would logically look to a reference like Pauls for its detailed teachings on video-specific encoders. The combination would have been a predictable implementation of Imai's teachings in the video context using the well-known video compression standards taught by Pauls.
    • Expectation of Success: A POSITA would have a reasonable expectation of success, given the analogous nature of audio and video compression and the clear, overlapping goals of both prior art references.

Ground 3: Obviousness over Imai, Pauls, and Chao - Claims 2, 11, 20-22, and 25-27 are obvious over Imai in view of Pauls and Chao.

  • Prior Art Relied Upon: Imai (Japanese Application # H11331305), Pauls (European Application # EP0905939A2), and Chao (WO 98/40842).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims requiring the use of an arithmetic compression algorithm. Petitioner argued that the combination of Imai and Pauls established the foundational system of adaptive, throughput-based encoder selection. Chao was introduced for its explicit teaching of an asymmetric video compression system for "streaming video" that used an arithmetic algorithm for entropy coding.
    • Motivation to Combine: A POSITA would combine Chao with the Imai/Pauls system to gain the known advantages of arithmetic coding, which the ’477 patent itself admitted was a "popular" and highly effective technique. Pauls already taught H.263, which had an optional arithmetic mode, but Chao provided an explicit example of an asymmetric video encoder designed with arithmetic coding. A POSITA would view substituting or adding Chao's superior compression technology into the Imai/Pauls framework as a simple, advantageous design choice.
    • Expectation of Success: Success would be expected, as this combination involved incorporating a known, more efficient compression component (an arithmetic encoder) into an established system architecture to achieve the predictable result of improved compression.

  • Additional Grounds: Petitioner asserted a separate obviousness challenge based on Imai alone, arguing its teachings and the knowledge of a POSITA were sufficient to render claims 1, 3-5, and 12-14 obvious.

4. Key Claim Construction Positions

  • "asymmetric data compression encoder[s]": Petitioner proposed a construction of "an encoder(s) configured to utilize a compression algorithm in which the execution time for the compression and decompression routines differ significantly." This construction was based on an express definition in the ’477 patent's specification for an "asymmetrical data compression algorithm."
  • "data blocks": Petitioner proposed this term meant "a unit of data comprising more than one bit." The rationale was that data compression, the patent's subject, requires a unit of data larger than a single bit to achieve any reduction in size. This was supported by the patent's description of compressing files and other data structures.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-6, 9-14, 20-22, and 25-27 of the ’477 patent as unpatentable.