Comcast Cable Communications, LLC v. Realtime Adaptive Streaming, LLC

1. Case Identification

• Case #: IPR2019-00786
• Patent #: 9,769,477
• Filed: March 4, 2019
• Petitioner(s): Comcast Cable Communications, LLC
• Patent Owner(s): Realtime Adaptive Streaming, LLC
• Challenged Claims: 1-6, 9-14, 20-22, and 25-27

2. Patent Overview

• Title: System for Adaptive Data Compression Based on Channel Throughput
• Brief Description: The ’477 patent discloses a system for compressing data by dynamically selecting among a plurality of different asymmetric data compression encoders. The selection is based on the determined throughput of a communications channel, allowing the system to switch algorithms to balance compression speed and compression ratio, thereby overcoming data transmission 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 teaches a data transmission system that addresses the core limitations of independent claim 1. Imai discloses a server with a plurality of different encoders (e.g., MPEG, ATRAC) that utilize asymmetric compression algorithms. A processor in Imai’s system determines the network's transmission rate (throughput) in bits per second and selects the most appropriate encoder to ensure the output bit rate does not exceed the channel's capacity. Although Imai primarily discusses audio data, it explicitly states its invention is applicable to video signals, making its teachings relevant.
  • Motivation to Combine (for §103 grounds): Not applicable (single reference ground).
  • Expectation of Success (for §103 grounds): Not applicable (single reference ground).

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 asserted that Pauls teaches a system for adaptive communications formatting that renders the claims obvious. Pauls discloses an access server with a plurality of transcoders for various data types, including video and image, that use standardized asymmetric algorithms like H.263, MPEG, and MPEG2. The system selects a transcoder based on factors including the "nature of the communications network," which explicitly includes the "available bandwidth" and "bit rate" (throughput). This selection is performed by a microprocessor, which meets the "one or more processors" limitation.
  • Motivation to Combine (for §103 grounds): Not applicable (single reference ground).
  • Expectation of Success (for §103 grounds): Not applicable (single reference ground).

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 (WO 98/40842).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground targets claims requiring an arithmetic compression algorithm. Petitioner argued that the combination of Imai and Pauls establishes the foundational system of selecting a video encoder based on network throughput. Pauls itself discloses H.263 and JPEG, which have optional arithmetic coding modes. To strengthen the argument, Petitioner introduced Chao, which explicitly teaches an asymmetric, wavelet-based video compression system that uses an arithmetic algorithm for entropy coding.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Imai and Pauls because they address the same problem of encoding data for network transmission, and Pauls provides the explicit video-centric teachings that complement Imai's detailed throughput-detection methods. A POSITA would further incorporate Chao because it was known to improve upon the compression ratio and speed of the very standards (H.263, MPEG) used in Pauls. Replacing an existing encoder with Chao's arithmetic encoder would be a simple substitution to gain the known benefits of a more effective compression technique.
  • Expectation of Success (for §103 grounds): A POSITA would have had a reasonable expectation of success in combining the references given their compatible systems and the well-understood nature of audio and video compression technologies at the time.

• Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 3) for claims 1, 3-6, and 9-14 based on the combination of Imai and Pauls, arguing that Pauls supplies the explicit video compression teachings to complement Imai’s system.

4. Key Claim Construction Positions

• "asymmetric data compression encoder[s]": Petitioner argued this term should 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 is based directly on the definition provided for an "asymmetrical data compression algorithm" in the ’477 patent’s specification.
• "data blocks": Petitioner proposed construing this term as "a unit of data comprising more than one bit." This construction is based on the principle that compression reduces data size, which is impossible for a single bit of information. The specification’s discussion of compressing files and using data units as small as 2 bits supports this interpretation.

5. Relief Requested

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