PTAB

IPR2018-01342

Sling TV LLC v. Realtime Adaptive Streaming LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: SYSTEMS AND METHODS FOR VIDEO AND AUDIO DATA STORAGE AND DISTRIBUTION
  • Brief Description: The ’535 patent discloses a data compression system that seeks to balance execution speed and compression efficiency. The system selects a suitable compression algorithm from a plurality of available algorithms based on a determined parameter or attribute of the data, such as its data type or access frequency.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 2, 9, 10, and 14 under 35 U.S.C. §102

  • Prior Art Relied Upon: Dvir (Patent 6,557,001).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dvir discloses every limitation of the challenged independent claims 1 and 14. Dvir teaches a system for compressing and transmitting multimedia data over a low-bandwidth network. The system determines a "parameter" or "characteristic" of the data (e.g., number of unique colors, level of motion) and uses this to select a "compression profile" from a plurality of profiles. Petitioner asserted this "compression profile" is the same as the claimed "access profile," as it links a data characteristic to a specific compression method. Dvir then compresses the data using the selected method, explicitly teaching the use of MPEG encoders. Petitioner contended that MPEG was well-known as a form of "asymmetric data compression" (i.e., slow encoding, fast decoding) at the time of the invention, thus meeting the claim limitation for asymmetric compression and satisfying all elements of the independent claims.
    • Key Aspects: The core of this ground rested on equating Dvir's "compression profile" with the ’535 patent's "access profile" and establishing that Dvir’s taught use of MPEG compression inherently discloses the claimed "asymmetric data compression."

Ground 2: Obviousness of Claims 3-6, 8, 11, and 12 over Dvir in view of Ishii

  • Prior Art Relied Upon: Dvir (Patent 6,557,001) and Ishii (Patent 5,675,789).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed dependent claims reciting features like storing data blocks as files and selecting a compressor based on access frequency (number of reads). Petitioner argued that while Dvir provides the primary system for selecting a compression algorithm based on data characteristics, it does not explicitly teach selecting compression based on access frequency or detailed file storage methods. Ishii, however, remedies these deficiencies by teaching a file compression processor for an online database that selects a compression method based on both the "data type" and the "access frequency" of a file. Ishii explicitly teaches selecting compression methods with shorter decompression times for files with higher access frequency to reduce latency. This directly maps to the limitations of claim 8. Furthermore, Ishii's system inherently involves storing compressed data as files on a disk, satisfying the limitations of claims 3-6, 11, and 12.
    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Dvir and Ishii to improve the performance of Dvir's system. A POSITA would have recognized that applying Ishii's access-frequency-based compression selection and file storage management to Dvir's multimedia transmission system would reduce end-user latency, improve storage efficiency, and optimize performance over bandwidth-constrained networks. Both references addressed the common problem of efficient, adaptive data compression.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references, as it involved applying Ishii's known storage and access-frequency-based optimization techniques to Dvir's compression system. This integration would require only conventional programming and hardware design skills to achieve the predictable result of a more efficient system.

  • Additional Grounds: Petitioner asserted that claims 1, 2, 9, 10, and 14 are also obvious over Dvir alone under 35 U.S.C. §103. This alternative ground argued that even if Dvir does not explicitly disclose asymmetric compression, a POSITA would have found it obvious to use a well-known asymmetric algorithm like MPEG in Dvir’s system to reduce end-user latency by providing for fast decoding.

4. Key Claim Construction Positions

  • "asymmetric data compression": Petitioner argued this term should be construed as "an algorithm where compression of data and decompression of that compressed data take different amounts of time." This construction was central to the argument that Dvir's teaching of MPEG compression, a technique known to have a more complex encoding process than its decoding process, met this limitation.
  • "access profile": Petitioner proposed construing this term as "information that enables a controller to determine a compression routine that is associated with a data type of the data to be compressed." This broad construction allowed Petitioner to argue that Dvir's "compression profile," which links data characteristics to a compression method, was equivalent to the claimed "access profile."
  • "data block": Based on the specification and related litigation, Petitioner argued this term means "at least a single unit of data, which may range in size from individual bits through complete files or collection of multiple files."
  • "parameter": Petitioner argued this term should be construed as "any recognizable data token or descriptor," consistent with its use in the specification and related litigation.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 1-6, 8-12, and 14 of the ’535 patent as unpatentable.