PTAB

IPR2019-00712

Adobe Inc v. Realtime Adaptive Streaming LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Methods for Video and Audio Data Distribution
  • Brief Description: The ’442 patent discloses a system to accelerate data storage and retrieval by balancing compression speed against compression level. The system monitors the throughput of a communication channel and selects from a plurality of compression algorithms to optimize performance, considering both system throughput and attributes of the data being processed.

3. Grounds for Unpatentability

Ground 1: Anticipation and/or Obviousness over Tso - Claims 1-15 are anticipated and/or rendered obvious by Tso.

  • Prior Art Relied Upon: Tso (Patent 6,185,625).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tso discloses all limitations of the challenged claims. Tso describes a client-server system that enhances data access over a communications link by adaptively compressing data before transmission. The server includes a plurality of "encode service providers" (a plurality of compression algorithms) and an "encode manager" that selects the appropriate provider based on predetermined characteristics, including the "speed and/or quality of [the] client/server communications link" (throughput) and the "type of data content" (an attribute of the data). After receiving the compressed data, Tso's client uses a corresponding "decode service provider" to perform decompression and stores the decompressed data in a "client-side cache memory," meeting the limitations of independent claims 1 and 8. Petitioner contended that Tso’s disclosure of using MPEG and fractal compression, both known to be asymmetric, meets the asymmetric algorithm limitation.
    • Motivation to Combine (for §103 grounds): While primarily an anticipation ground, Petitioner argued in the alternative for obviousness. For example, a person of ordinary skill in the art (POSITA) would have understood that data transmission over a network like the one Tso describes inherently involves data blocks (packets). A POSITA would also have found it obvious that retrieving data over a communication channel is necessarily based on the throughput of that channel, as data can only be retrieved as fast as it can be transmitted.
    • Expectation of Success (for §103 grounds): Petitioner argued that implementing Tso’s system with well-known techniques, such as real-time transmission protocols, was a simple application of a known technique to a known system that would have yielded predictable results.

Ground 2: Obviousness over Vishwanath and Kidder - Claims 1-15 are obvious over Vishwanath in view of Kidder.

  • Prior Art Relied Upon: Vishwanath (Patent 6,216,157) and Kidder (Patent 5,898,833).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Vishwanath teaches the core inventive concept: an adaptive transmission system that selects an appropriate compression algorithm from a plurality of options (e.g., MPEG, H.263) based on the "input data type" (a data attribute) and "resources available," such as the "bandwidth" (throughput) of the transmission medium. This system modifies multimedia data and delivers it to a client, which then decodes it. While Vishwanath discloses the benefits of "incremental reconstruction of the output at the client," it lacks specific details on implementation. Kidder was argued to supply this missing element by teaching a system that improves data quality through iterative transmissions of differently compressed versions of the data. Kidder explicitly discloses receiving adaptively compressed data, decompressing it, and caching the decompressed data in client-side memory to combine with subsequent transmissions, thereby teaching the claimed "storing" limitation.
    • Motivation to Combine (for §103 grounds): A POSITA, seeking to implement Vishwanath's system for "incremental reconstruction" to "improve the user experience," would combine its teachings with Kidder. Kidder’s detailed disclosure of an iterative process using cached data to improve quality directly addresses the goal stated in Vishwanath. The combination would improve data quality and user experience by leveraging Kidder’s caching and iterative improvement techniques within Vishwanath’s adaptive, bandwidth-sensitive compression framework.
    • Expectation of Success (for §103 grounds): Petitioner argued a POSITA would have had a reasonable expectation of success because both references address adaptive data compression for transmission over networks of varying quality. The significant technical overlap, including the use of similar asymmetric compression algorithms like MPEG, would have made integrating Kidder's caching and iterative transmission techniques into Vishwanath's system a matter of routine engineering, leading to predictable improvements in performance.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-15 of the ’442 patent as unpatentable.