PTAB

IPR2019-00684

ARRIS Solutions 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 a system and method for compressing and decompressing data based on system throughput. The invention purports to remediate data "bottlenecks" by using different compression algorithms, such as switching between asymmetric and symmetric types, based on access profiles to increase storage capacity and retrieval rates.

3. Grounds for Unpatentability

Ground 1: 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 taught all limitations of the challenged claims. Imai, which was not considered during prosecution, disclosed a system for encoding digital data (including audio and video) by selecting from a plurality of encoders based on data characteristics and network conditions. Imai’s available encoders included known asymmetric algorithms like MPEG and ATRAC. Ishii taught a file compression system that selects a suitable compression method based on the "access frequency" and "type of the file" to manage storage capacity effectively. Specifically, Ishii taught selecting compression methods with shorter decompression times for files with higher access frequency and methods with higher compression ratios for files with lower access frequency. Petitioner contended that Ishii's teaching of selecting a compression method based on "access frequency" directly corresponds to the ’535 patent's limitation of selecting an "access profile" based on a determined parameter. The combination therefore rendered obvious a method of determining a parameter of a data block (file type from Imai/Ishii, access frequency from Ishii), selecting an access profile based on that parameter (from Ishii), and compressing the data using an asymmetric compressor (from Imai) based on the selected profile. For claim 14, Petitioner argued that both Imai and Ishii taught or suggested using asymmetric compressors with a slow compress encoder and fast decompress decoder, such as Lempel-Ziv (disclosed in Ishii) and MPEG/ATRAC (disclosed in Imai).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the teachings of Imai and Ishii to create an improved and more optimized data compression system. Both references are in the same field of data compression and address selecting among multiple compression algorithms. A POSITA would have been motivated to incorporate Ishii’s criteria for algorithm selection (i.e., access frequency) into Imai’s system to better manage system resources and improve performance. Using access frequency to select an appropriate algorithm was a known technique to optimize the trade-off between compression ratio and processing speed, which would have been a predictable improvement to Imai’s system.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these references. The combination involved applying a known selection criterion (access frequency from Ishii) to a known data compression system that used multiple encoders (Imai). This would predictably result in a system with more optimized compression algorithm selection, as the individual components were designed to work in similar technological environments and their integration was straightforward.

4. Key Claim Construction Positions

  • "asymmetric compressors" / "compressors using asymmetric data compression": Petitioner proposed this term means "a compression algorithm in which the execution time for the compression and decompression routines differ significantly." This construction was based on an explicit definition provided in the ’535 patent specification.
  • "data block": Petitioner proposed this term means "a unit of data comprising more than one bit." This construction was based on the claim language and specification, which imply that a data block must be large enough to be compressible.
  • "access profiles": Petitioner proposed this term means "information regarding the number or frequency of reads or writes." This construction was based on the claim language and a table in the specification that explicitly links different access profiles (e.g., "Write few, Read many") to specific compression algorithm types.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate. The petition was filed concurrently with a motion to join a pending inter partes review (IPR), IPR2018-01169, that was already instituted on the same claims and grounds. Petitioner asserted that because the petition was substantively identical to the already-instituted IPR and sought joinder, it would not present an undue burden on the Patent Owner or the Board.

6. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-14 of the ’535 patent as unpatentable.