PTAB

IPR2019-01280

Netflix Inc v. Realtime Adaptive Streaming LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Data Compression Method and System
  • Brief Description: The ’046 patent discloses methods and systems for dynamically switching between different data compression routines based on their respective compression rates. The selection of a routine is determined by tracking the overall throughput of a data processing system, specifically by monitoring a number of pending requests for data transmission, to ensure performance remains above a predetermined threshold.

3. Grounds for Unpatentability

Ground 1: Obviousness over Imai and Couwenhoven - Claims 1, 4, 8, 10-11, 13-14, 16-17, 19, 21, 23, 26-27, 29-32, and 34-35 are obvious over Imai in view of Couwenhoven.

  • Prior Art Relied Upon: Imai (Japanese Patent Application Publication No. H11331305) and Couwenhoven (Patent 5,596,602).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Imai taught a streaming media system that selects an encoder from a plurality of available encoders, each employing different coding methods (e.g., MPEG, ATRAC) with varying bitrates and computational demands. This disclosure met the limitations of using a first compression routine with a first compression rate. Petitioner then asserted that Couwenhoven taught the remaining key limitations. Couwenhoven described a data compression system that controlled throughput by monitoring the fill conditions of a rate buffer, which held compressed data pending transmission over a fixed-rate channel. Petitioner argued that monitoring the amount of data in this buffer was equivalent to the claimed "tracking a number of pending requests for data transmission." When system throughput fell below a threshold (i.e., the buffer level dropped), Couwenhoven’s rate controller would modify a control signal to increase the compression module's output bit rate, including by switching to a different compression configuration. This taught the claimed step of switching to a second, faster compression routine to increase throughput when the tracked throughput falls below a predetermined level.
    • Motivation to Combine: Petitioner argued a POSITA would combine these references as they addressed the same technical field of streaming media and were highly complementary. Imai provided the foundational system with multiple selectable encoders, while Couwenhoven provided a well-known, simple, and efficient feedback mechanism (buffer monitoring) to automate the selection among those encoders to control throughput. This combined approach was presented as superior to Imai's method of measuring channel speed, as it avoided the round-trip network delays inherent in Imai’s packet-based measurement technique.
    • Expectation of Success: The petition asserted a reasonable expectation of success because using buffer feedback to control data rates was a common and well-understood technique for streaming systems at the time. The combination represented the application of a known technique (Couwenhoven's rate control) to a similar system (Imai's multi-encoder platform) to yield predictable results.

Ground 2: Obviousness over Imai, Couwenhoven, and Ishii - Claim 24 is obvious over Imai and Couwenhoven in view of Ishii.

  • Prior Art Relied Upon: Imai (Japanese Patent Application Publication No. H11331305), Couwenhoven (Patent 5,596,602), and Ishii (Patent 5,675,789).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground incorporated the teachings of Imai and Couwenhoven from Ground 1 and added Ishii to address the specific limitations of claim 24. Claim 24 requires "a plurality of access profiles, operatively accessible by the controller, to determine a compression routine that is associated with a data type of data to be compressed." Petitioner argued that Ishii directly taught this element by disclosing a system that selects a "suitable compression method corresponding to the access frequency and the type of the file." Petitioner equated Ishii's use of "access frequency" (e.g., classifying files as high, medium, or low access) with the claimed "plurality of access profiles." Ishii taught using this information, along with the file type, to select an appropriate compression algorithm.
    • Motivation to Combine: Petitioner contended that a POSITA would be motivated to integrate Ishii's teachings into the Imai/Couwenhoven system to introduce a further layer of optimization. Imai already suggested selecting encoders based on data type; Ishii provided a known, complementary factor (access frequency) to refine that selection process. Applying Ishii's teachings would allow the system to choose compression algorithms more precisely tailored to a file's specific usage pattern, thereby improving overall compression efficiency and reducing system load, a known goal in the art.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because all three references were directed to improving data compression systems by intelligently selecting from multiple available algorithms. Integrating Ishii's selection criteria into the control logic of the Imai/Couwenhoven system was a predictable design choice to enhance performance.

4. Key Claim Construction Positions

  • "asymmetric" or "asymmetrical algorithm": Petitioner argued this term means "an algorithm in which the execution time for the compression and decompression routines differ significantly." This construction was based on an express definition in the ’046 patent's specification and was crucial for demonstrating that prior art algorithms disclosed in Imai (e.g., MPEG, ATRAC) met this claim limitation.
  • "access profile": Petitioner proposed this term means "information regarding the number or frequency of reads or writes." This construction, asserted as being consistent with the ’046 patent’s disclosure, was central to Ground 2. It created a direct link between the language of claim 24 and Ishii's disclosure of selecting compression methods based on "access frequency."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 4, 8, 10-11, 13-14, 16-17, 19, 21, 23-24, 26-27, 29-32, and 34-35 of the ’046 patent as unpatentable.