PTAB

IPR2019-00786

Comcast Cable Communications LLC v. Realtime Adaptive Streaming LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression/Decompression Based on Throughput
  • Brief Description: The ’477 patent discloses systems and methods for dynamically selecting different data compression encoders based on the measured or expected throughput of a communications channel. The invention aims to optimize the balance between compression speed and compression ratio to overcome system bottlenecks.

3. Grounds for Unpatentability

Ground 1: Claims 1, 3-5, and 12-14 are obvious over Imai

  • Prior Art Relied Upon: Imai (Japanese Patent Application Publication No. H11331305).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Imai taught all limitations of the challenged claims. Imai disclosed a data transmission system with a plurality of different asymmetric encoders (e.g., MPEG layers 1-3, ATRAC) that are selected by a processor (CPU). The selection was based on data parameters, including the determined throughput of a communications channel, which Imai taught to measure in bits per second (bps) to ensure the output bit rate did not exceed the network's transmission rate. While Imai’s primary embodiment concerned audio, Petitioner asserted it expressly taught applicability to video signals, and a POSITA would have found it obvious to apply the system to video data.
    • Motivation to Combine (for §103 grounds): This ground relied on a single reference.
    • Expectation of Success (for §103 grounds): Not applicable (single reference).

Ground 2: Claims 1, 3-6, and 9-14 are obvious over Pauls

  • Prior Art Relied Upon: Pauls (European Patent Application Publication No. EP0905939A2).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended Pauls taught an adaptive communications system that rendered the claims obvious. Pauls disclosed an access server with a plurality of transcoders for different data types, including video and image data. These transcoders utilized various well-known, asymmetric compression algorithms (e.g., H.263, MPEG, MPEG2). A microprocessor selected the appropriate transcoder based on data parameters, including the "nature of the communications network," which explicitly included factors like "available bandwidth" and "bit rate." Pauls further taught selecting encoders based on data type (content-dependency) and adapting compression for real-time applications over distributed networks like the Internet.
    • Motivation to Combine (for §103 grounds): This ground relied on a single reference.
    • Expectation of Success (for §103 grounds): Not applicable (single reference).

Ground 3: Claims 2, 11, 20-22, and 25-27 are obvious over Imai in view of Pauls and Chao

  • Prior Art Relied Upon: Imai (Japanese Patent Application Publication No. H11331305), Pauls (European Patent Application Publication No. EP0905939A2), and Chao (International Publication No. WO 98/40842).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims requiring an arithmetic compression algorithm. Petitioner argued that Imai and Pauls collectively taught a system for selecting from a plurality of asymmetric video encoders based on network throughput. While Pauls disclosed encoders (H.263, JPEG) with optional arithmetic coding modes, Chao was introduced as an explicit example of an asymmetric video encoder that used a primary arithmetic algorithm. Petitioner asserted Chao’s wavelet-based encoder was asymmetric and used arithmetic coding for entropy compression. The remaining limitations of the dependent claims were argued to be taught by the combination of Imai and Pauls for the same reasons as in other grounds.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the base system of Imai and Pauls with Chao to gain the known benefits of arithmetic coding, which the ’477 patent itself admitted was a "popular compression technique" with a "high degree of algorithmic effectiveness." Chao presented its arithmetic-based approach as an improvement over the H.263 and MPEG encoders used in Pauls, providing a clear reason to substitute or incorporate its teachings to create a more efficient system.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success, as substituting one known type of video encoder (Chao) for another (one of Pauls' encoders) in a modular compression system was a predictable and well-understood design choice.

  • Additional Grounds: Petitioner asserted that claims 1, 3-6, and 9-14 are also obvious over the combination of Imai and Pauls, arguing that Pauls' explicit teachings on video compression would obviously supplement Imai's broader framework.

4. Key Claim Construction Positions

  • "asymmetric data compression encoder[s]": Petitioner proposed this term be construed as “an encoder(s) configured to utilize a compression algorithm in which the execution time for the compression and decompression routines differ significantly.” This construction was based directly on the patent’s explicit definition of an “asymmetrical data compression algorithm” and its examples (e.g., Lempel-Ziv is asymmetric, Huffman is symmetric).
  • "data blocks": Petitioner proposed this term means “a unit of data comprising more than one bit.” This construction was based on the principle that compression requires a unit of data larger than a single bit to achieve any reduction in size. The specification’s discussion of processing files, fixed-size blocks, and variable-size blocks supported this interpretation.

5. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-6, 9-14, 20-22, and 25-27 of the ’477 patent as unpatentable.