HPE wins data compression patent fight
Hewlett Packard Enterprise has succeeded in its bid to prove that claims in a patent owned by technology company Realtime Data were covered by a prior invention.
In a precedential ruling on Thursday, January 10, The US Court of Appeals for the Federal Circuit upheld a decision by the US Patent and Trademark Office, Patent Trial and Appeal Board that all the challenged claims would have been obvious given the prior art.
The decision concerned Realtime’s ‘812 patent (No 6,597,812) for “systems and methods for providing lossless data compression that exploit various characteristics of run-length encoding, parametric dictionary encoding, and bit packing”.
Run-encoding and dictionary encoding are forms of data compression. Dictionary encoding assigns a code word to a specific data string, while run-encoding replaces a “run” of characters with an identifier for each individual character and the number of times it is repeated.
In April 2016, Hewlett Packard Enterprise, Hewlett Enterprise Services and Teradata Operations sought inter partes review—a review of the patentability of one or more claims in a patent—of 11 claims of the ‘812 patent. The patent had 30 claims in total.
In its petition, HPE alleged that the 11 claims would have been obvious because of the prior art. It alleged that six of the claims would have been obvious due to US patent ‘946 ( No 4,929,946), for “adaptive data compression apparatus including run length encoding for a tape drive system”.
It further said that the other five claims would have been obvious due to ‘946 in view of a textbook, The Data Compression Book, and US patent ‘302 (No 4,558,302) for “high speed data compression and decompression apparatus and method”.
In its appeal to the Federal Circuit, Realtime said that the board erred in its determination that a person of ordinary skill in the art would have been motivated to combine the teachings of the ‘946 patent and the data compression textbook.
The court said it has “long held that when a party claims that a combination of references renders a patented invention obvious”, it must “consider the factual questions of whether a person of ordinary skill in the art would be motivated to combine those references”.
In its consideration, it said that a person of ordinary skill would have looked to The Data Compression Book after the ‘946 patent “because the textbook is well known”.
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