PTAB

IPR2018-01384

Cisco Systems Inc v. Realtime Adaptive Streaming LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression/Decompression
  • Brief Description: The ’535 patent discloses methods for data compression where a system analyzes a data block to determine a parameter or attribute (e.g., data type). Based on this parameter, the system selects an appropriate "access profile" which in turn determines which known compression algorithm, including asymmetric algorithms, to apply.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-2, 9-10, and 14 over Dvir and Koz

  • Prior Art Relied Upon: Dvir (Patent 6,557,001) and Koz (Patent 5,990,955).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dvir discloses the core limitations of independent claims 1 and 14. Dvir teaches a method for "rapid video data compression" that determines parameters of video data (e.g., motion, color complexity), matches those parameters to a "compression profile," and then compresses the data using the method specified in the profile, preferably MPEG. This maps directly to the claimed steps of determining a parameter, selecting a profile, and compressing.
    • Motivation to Combine (for §103 grounds): Dvir suggests using MPEG compression but does not provide extensive implementation details. A person of ordinary skill in the art (POSITA) seeking to implement Dvir's system would look to references like Koz for details on MPEG encoding. Koz explicitly teaches that MPEG is an "asymmetric-compression" technique where "compression requires more effort than decompression." A POSITA would combine Koz with Dvir to understand and implement the asymmetric nature of the MPEG compression suggested by Dvir.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success, as this combination merely involved applying a well-known characteristic (asymmetry, from Koz) to the specific compression standard (MPEG) expressly preferred by Dvir.

Ground 2: Claims 5-6, 12, 15-17, 19, and 22 are obvious over Dvir in view of Hamadani (with or without Koz)

  • Prior Art Relied Upon: Dvir (Patent 6,557,001), Hamadani (Patent 5,845,083), and Koz (Patent 5,990,955).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the Dvir/Koz combination to address claims requiring the additional step of storing the compressed data blocks for later retrieval. Hamadani discloses a system where compressed multimedia data (using MPEG) can be loaded into "data storage" or supplied to a remote user. It explicitly teaches storing compressed data so it may be later requested by a user in a "video on demand" system.
    • Motivation to Combine (for §103 grounds): A POSITA would recognize two primary uses for compressed data: immediate transmission (as emphasized in Dvir) and storage for later use. Hamadani explicitly teaches the latter. A POSITA would combine Hamadani's storage and on-demand retrieval features with Dvir's adaptive compression method to create a more versatile system that allows users to view content at their convenience. This combination was argued to be a predictable integration of known system components.
    • Expectation of Success (for §103 grounds): The combination of a compression system with a storage system was a common and well-understood design choice, ensuring a high expectation of success.

Ground 3: Claims 1, 8, 15, and 24 are obvious over Ishii and Koz

  • Prior Art Relied Upon: Ishii (Patent 5,675,789) and Koz (Patent 5,990,955).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued Ishii teaches a "file compression processor" that selects a compression method based on file parameters, including data attributes (e.g., text vs. image) and "access frequency" (determined from last access date and number of accesses). This maps to the claims' requirements of determining a parameter/attribute and selecting a compressor. After compression, Ishii stores the compressed file on a disk.
    • Motivation to Combine (for §103 grounds): Ishii's system focuses on managing storage space by compressing less frequently used image and text files. A POSITA would have been motivated to apply Ishii's efficient, attribute-based storage management techniques to video data, which was becoming increasingly common. Koz provides the necessary bridge, teaching that MPEG video compression is analogous to JPEG image compression and is asymmetric. A POSITA would combine Ishii's method of selecting a compressor based on access frequency with Koz's teaching of asymmetric MPEG to efficiently compress and store video files.
    • Expectation of Success (for §103 grounds): Applying known file management techniques to a new but analogous data type (video) using a standard compression algorithm for that data type would have been a straightforward modification with a high expectation of success.

  • Additional Grounds: Petitioner asserted obviousness challenges based on Dvir in view of Ando (adding details of DVD file structures for claims 3-4 and 11) and Dvir in view of Hamadani and Figueredo (adding deferred transmission based on network throughput for claim 21).

4. Key Claim Construction Positions

  • "data block": Petitioner proposed this term means "a single unit of data, which may range in size from more than one bit through complete files or collections of files." This broad construction was argued to be supported by a patent incorporated by reference and was critical for mapping prior art disclosures of frames, groups of frames, and entire video files to the claims.
  • "access profile": Petitioner proposed this term means "a profile (1) having information used in data compression and (2) being associated with one or more characteristics of data to be compressed." This construction was central to arguing that the "compression profiles" in Dvir and the "access frequency" classifications in Ishii meet the claim limitation.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate. This was Cisco's first challenge to the ’535 patent. The petition asserted that its grounds were not cumulative of other pending IPRs against the same patent, which were filed by unrelated parties and relied on different prior art combinations and arguments. Specifically, Petitioner noted that key secondary references it relied upon—Hamadani, Ando, and Figueredo—had not been cited in any previous petition before the Board.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-6, 8-12, 14-17, 19, 21, 22, and 24 of the ’535 patent as unpatentable.