PTAB

IPR2019-00674

ARRIS Solutions Inc v. Realtime Adaptive Streaming LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Adaptive Data Compression
  • Brief Description: The ’535 patent discloses a system for compressing and decompressing data by selecting different compression algorithms based on system throughput or data characteristics. The invention aims to remediate data transfer bottlenecks in mass storage devices by adaptively choosing between symmetric and asymmetric compression routines.

3. Grounds for Unpatentability

Ground 1: Obviousness over Imai and Ishii - Claims 1-14 are obvious over Imai in view of Ishii.

  • Prior Art Relied Upon: Imai (Japanese Patent Application Publication No. H11331305) and Ishii (Patent 5,675,789).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Imai and Ishii teaches every limitation of the challenged claims. Imai, which was not considered during prosecution, allegedly disclosed a system that selects from a plurality of available compression algorithms (including asymmetric ones like MPEG and ATRAC) to encode audio and video data blocks in real-time. The selection in Imai was based on parameters like data content (e.g., vocal vs. instrument sounds), client processing ability, and network throughput. Ishii allegedly taught a file compression processor that selects a suitable compression method based on the "access frequency" and type of a file to improve storage utilization. Petitioner contended that Ishii’s teaching of monitoring access frequency (reads/writes) corresponds directly to the ’535 patent’s concept of an "access profile." By combining these references, a person of ordinary skill in the art (POSITA) would arrive at the claimed invention: using access frequency (from Ishii) as an additional, key parameter within a system like Imai’s to select the optimal asymmetric compression algorithm for a given data block. For independent claim 14, which is not limited to audio/video data but requires a slow-compress/fast-decompress process, Petitioner asserted that both Imai and Ishii disclose known asymmetric compressors (e.g., Lempel-Ziv) that inherently meet this limitation.
    • Motivation to Combine: A POSITA would combine Imai and Ishii to create an improved and more optimized data compression system. Both references address the same field of selecting compression algorithms. A POSITA implementing Imai’s system, which already uses multiple criteria for algorithm selection, would have been motivated to look to other references like Ishii to incorporate additional, known selection criteria. Ishii’s use of "access frequency" was a known factor for optimizing storage and retrieval performance. Incorporating Ishii’s access frequency criterion into Imai’s selection logic would have been a predictable improvement to better manage system processing loads, a concern explicitly noted in Imai.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success. The combination involved applying a known optimization technique (selecting algorithms based on access frequency from Ishii) to a known type of system (an adaptive multi-algorithm compression system from Imai). The result—a system that selects a compression algorithm based on both data content and access patterns—was predictable and would have been expected to yield a more efficient compression process.

4. Key Claim Construction Positions

  • “asymmetric compression algorithm”: Petitioner argued this term should be construed as "a compression algorithm in which the execution time for the compression and decompression routines differ significantly." This construction was based on the patent’s explicit definition and was crucial for mapping prior art algorithms like Lempel-Ziv, MPEG, and ATRAC, which were known to have this property.
  • “data block”: Petitioner proposed this term means "a unit of data comprising more than one bit." This broad construction was supported by the specification and was necessary to show that the prior art’s processing of "files" (Ishii) or "units of frame" (Imai) met this limitation.
  • “access profile”: Petitioner contended this term means "information regarding the number or frequency of reads or writes." This construction was based on the specification’s examples (e.g., "Write few, Read many") and was key to linking Ishii’s teaching of "access frequency" directly to this claim limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of the ’535 patent as unpatentable.