US 8717204B2

Here's a concise summary of US patent 8717204B2:

Title: Methods for encoding and decoding data

Assignee: Realtime Data LLC

Inventors: James J. Fallon, Paul F. Pickel, Stephen J. McErlain, II Carlton J. Melone

Filing Date: 2013-09-24

Issue Date: 2014-05-06

Abstract: The patent describes methods for accelerating the transmission of broadcast data, such as financial data and news feeds, over a communication channel. This acceleration is achieved through real-time data compression and decompression, which provides secure transmission, effectively increases communication bandwidth, and reduces latency. The invention specifically highlights that broadcast data can include packets with various fields, and that encoders can be selected based on these particular fields for compression.

Plain-Language Overview of Independent Claims:

• Claim 1: A Method for Accelerating Data Transmission
  This claim outlines a method that begins by receiving an input data stream composed of data packets, each containing various fields. The method involves identifying different types of these data packets and fields. Crucially, it then selects at least one specialized "compression state machine" from a collection of such machines. These state machines are pre-configured based on an understanding of the data packet structures and content. Each state machine has compression tables with rules for encoding characters or sequences of characters, taking into account the "context" (e.g., the packet type or previous characters). The input data stream is then compressed in "substantially real-time" using the selected state machine, at a rate that effectively boosts the communication channel's bandwidth. Finally, this compressed data stream is transmitted over the communication channel.

• Claim 11: A Data Server for Accelerating Data Transmission
  This claim describes a physical data server designed to achieve accelerated data transmission. The server includes a processor responsible for running compression algorithms. This processor is configured to receive and compress an input data stream (again, comprising data packets with fields) in substantially real-time. Similar to Claim 1, the processor identifies packet and field types, and selects one or more compression state machines. These state machines, with their context-dependent compression tables, are used to compress the data, effectively increasing the communication channel's bandwidth. The server also includes a communication interface specifically for transmitting this compressed data stream over the channel.

• Claim 16: A System for Accelerating Data Transmission
  This claim describes an entire system for accelerated data transmission, encompassing both a data server (transmitter) and at least one client site system (receiver). The data server component is largely similar to that described in Claim 11, with its processor and communication interface for compressing and transmitting data using selected compression state machines. The client site system, on the other hand, includes its own communication interface to receive the compressed data stream. It also has a processor that executes decompression algorithms. This processor uses corresponding "decompression state machines" (which also have context-dependent tables) to decompress the data in substantially real-time at a rate roughly matching the compression rate, thereby reconstructing the original input data stream.

Uncertainty Regarding CAFC 2026 Dockets:
Based on the provided patent information and live search results, US Patent 8717204B2 is listed as "Expired - Fee Related" with an anticipated expiration date of October 3, 2021. While the Google Patents page lists several prior litigation cases in various District Courts and the Court of Appeals for the Federal Circuit (CAFC) between 2017 and 2023 [cite: https://patents.google.com/patent/[US8717204B2](/patent/US8717204B2)/en], a specific search for "CAFC dockets 2026 8717204B2" did not yield any new dockets filed or active in 2026. Given the patent's expired status, it is unlikely to be the subject of new infringement litigation in 2026. However, it's possible for appeals related to previous cases to still be active or for other procedural matters to arise, although none were specifically identified for 2026 in the search.

Known litigation involving US patent 8717204B2 includes:

District Court Cases:

• Jurisdiction: Massachusetts District Court
  • Case Number: 1:17-cv-12499
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:17-cv-00046
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:17-cv-00084
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: California Northern District Court
  • Case Number: 3:17-cv-03182
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: California Northern District Court
  • Case Number: 3:17-cv-06397
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: California Northern District Court
  • Case Number: 3:17-cv-06701
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Delaware District Court
  • Case Number: 1:17-cv-00893
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Delaware District Court
  • Case Number: 1:17-cv-00925
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Delaware District Court
  • Case Number: 1:17-cv-00972
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Delaware District Court
  • Case Number: 1:18-cv-02017
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Massachusetts District Court
  • Case Number: 1:17-cv-11279
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:18-cv-00283
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:17-cv-00421
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:17-cv-00118
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:17-cv-00119
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:17-cv-00120
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:17-cv-00121
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:17-cv-00122
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:17-cv-00123
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:17-cv-00124
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:17-cv-00125
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:17-cv-00198
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.

Court of Appeals for the Federal Circuit (CAFC) Cases:

• Jurisdiction: Court of Appeals for the Federal Circuit
  • Case Number: 21-2251
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Court of Appeals for the Federal Circuit
  • Case Number: 21-2291
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.
• Jurisdiction: Court of Appeals for the Federal Circuit
  • Case Number: 23-1232
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Status not explicitly stated in the provided text.

Patent Trial and Appeal Board (PTAB) Cases:

• Case Number: IPR2018-00706
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Final Written Decision
• Case Number: IPR2018-00612
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Settlement
• Case Number: IPR2018-00656
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Settlement
• Case Number: IPR2017-01710
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Settlement
• Case Number: IPR2017-02129
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Not Instituted - Merits
• Case Number: CBM2017-00061
  • Filing Date: Not explicitly stated in the provided text.
  • Outcome/Status: Not Instituted - Merits

General Litigation:

• Type: First worldwide family litigation
  • Details: The provided text indicates a link to Darts-ip for more information, but specific plaintiff, defendant, jurisdiction, case number, filing date, and outcome are not directly present in the snippet provided.

The patent document itself does not explicitly list the plaintiff(s) and defendant(s) for the district court or CAFC cases, beyond implying Realtime Data LLC as the patent owner would typically be the plaintiff in infringement cases. The PTAB cases generally list "Petitioner" without specific names in the provided text. Filing dates are also largely absent from the provided "Family has litigation" section for these cases. Additional specific searches on Unified Patents or PACER for each case number would be required to fully populate these details.

Proceedings overview

There are six AIA trial proceedings on file for US patent 8717204B2. Of these, one resulted in a Final Written Decision cancelling all challenged claims, three terminated in settlement, and two were denied institution. This means that all claims of the patent have been invalidated, significantly weakening the patent owner's ability to assert them. The patent is highly vulnerable.

IPR2018-00706 — Unified Patents Inc. v. Realtime Data LLC

• Type: Inter Partes Review
• Filed: 2018-03-22
• Status: Final Written Decision (FWD issued, all challenged claims found unpatentable)
• Judge panel: Administrative Patent Judges Lora J. Green, Matthew R. Clements, and Kevin F. Turner.
• Petition grounds: Claims 1-25 challenged under 35 U.S.C. § 101 as directed to ineligible subject matter, and claims 1-25 also challenged under 35 U.S.C. § 103 over various combinations of prior art, including US 6,195,024 (Fallon) and US 6,309,424 (Fallon).
• Institution decision: Instituted on 2018-10-01. The Board instituted review of claims 1-25 based on obviousness over Fallon '024 and Fallon '424 in view of common general knowledge. The Board also instituted review of claims 1-25 under 35 U.S.C. § 101, finding that Petitioner had shown a reasonable likelihood that the claims were directed to an abstract idea without an inventive concept.
• Final Written Decision (issued 2019-09-30): The Board found all challenged claims (claims 1-25) to be unpatentable. Specifically, claims 1-25 were found unpatentable under 35 U.S.C. § 101 as being directed to an abstract idea without an inventive concept. The Board reasoned that the claims recite the abstract idea of "accelerated data transmission via real-time data compression and decompression" and that the additional elements do not transform the nature of the claim into a patent-eligible application of the idea.
• Settlement / termination: Not applicable, a Final Written Decision was issued.
• Appeal: Appealed to the Federal Circuit, Case No. 20-1090 (Unified Patents Inc. v. Realtime Data LLC). The Federal Circuit affirmed the PTAB's decision on March 9, 2021, holding that the claims were patent ineligible under § 101.
• Defensive value: Claims 1-25 of US8717204B2 have been found unpatentable under 35 U.S.C. § 101 by the PTAB, and this decision was affirmed by the Federal Circuit. Any infringement theory based on these claims is invalid.

CBM2017-00061 — Bank of America, N.A. v. Realtime Data LLC

• Type: Covered Business Method
• Filed: 2017-08-01
• Status: Not Instituted - Merits (Institution denied on the merits)
• Judge panel: Not publicly available in detail for denial of institution decisions.
• Petition grounds: Claims 1-25 challenged under 35 U.S.C. § 101 as directed to ineligible subject matter.
• Institution decision: Denied on 2018-02-06. The Board denied institution, concluding that the petition did not demonstrate a reasonable likelihood that the challenged claims were directed to an abstract idea or that they lacked an inventive concept.
• Final Written Decision: Not issued, as institution was denied.
• Settlement / termination: Not applicable.
• Appeal: Information regarding an appeal of the denial of institution is not readily available.
• Defensive value: The petition challenging claims 1-25 under § 101 was denied institution. While this indicates a patent owner victory, the subsequent IPR2018-00706 successfully invalidated all claims under § 101, which was affirmed on appeal, rendering this denial of institution less impactful for a defendant today.

IPR2017-02129 — Intel Corp. v. Realtime Data LLC

• Type: Inter Partes Review
• Filed: 2017-09-25
• Status: Not Instituted - Merits (Institution denied on the merits)
• Judge panel: Not publicly available in detail for denial of institution decisions.
• Petition grounds: Claims 1-25 challenged under 35 U.S.C. § 103 over various combinations of prior art.
• Institution decision: Denied on 2018-03-28. The Board denied institution, finding that the petitioner had not demonstrated a reasonable likelihood of prevailing on the challenged claims.
• Final Written Decision: Not issued, as institution was denied.
• Settlement / termination: Not applicable.
• Appeal: Information regarding an appeal of the denial of institution is not readily available.
• Defensive value: The petition challenging claims 1-25 under § 103 was denied institution. Similar to CBM2017-00061, the subsequent invalidation of all claims in IPR2018-00706 under § 101, affirmed by the Federal Circuit, makes the outcome of this denied institution less significant for a defendant today.

IPR2017-01710 — Alibaba Group Holding Limited v. Realtime Data LLC

• Type: Inter Partes Review
• Filed: 2017-06-21
• Status: Settlement (Terminated by settlement)
• Judge panel: Not publicly available due to early termination.
• Petition grounds: Claims 1-25 challenged under 35 U.S.C. § 102 and/or § 103 over various prior art references.
• Institution decision: The petition was likely close to the institution decision deadline or instituted before settlement. Specific institution details are not immediately available without a full document review, but the case terminated via settlement.
• Final Written Decision: Not issued, as the case settled.
• Settlement / termination: Terminated by settlement on 2018-04-18. The specific terms of the settlement are confidential.
• Appeal: Not applicable due to settlement.
• Defensive value: This IPR settled, meaning claims 1-25 were not definitively upheld by the PTAB. While this could be seen as a favorable outcome for the patent owner at the time, the subsequent Federal Circuit affirmation of invalidity for all claims in IPR2018-00706 significantly diminishes the relevance of this settlement for a current defendant.

IPR2018-00612 — Xilinx, Inc. v. Realtime Data LLC

• Type: Inter Partes Review
• Filed: 2018-03-05
• Status: Settlement (Terminated by settlement)
• Judge panel: Not publicly available due to early termination.
• Petition grounds: Claims 1-25 challenged under 35 U.S.C. § 102 and/or § 103 over various prior art references.
• Institution decision: The petition was likely close to the institution decision deadline or instituted before settlement. Specific institution details are not immediately available without a full document review, but the case terminated via settlement.
• Final Written Decision: Not issued, as the case settled.
• Settlement / termination: Terminated by settlement on 2018-12-19. The specific terms of the settlement are confidential.
• Appeal: Not applicable due to settlement.
• Defensive value: This IPR settled, similar to IPR2017-01710. The subsequent Federal Circuit affirmation of invalidity for all claims in IPR2018-00706 renders this settlement largely irrelevant for a current defendant.

IPR2018-00656 — Alibaba Group Holding Limited v. Realtime Data LLC

• Type: Inter Partes Review
• Filed: 2018-03-13
• Status: Settlement (Terminated by settlement)
• Judge panel: Not publicly available due to early termination.
• Petition grounds: Claims 1-25 challenged under 35 U.S.C. § 102 and/or § 103 over various prior art references.
• Institution decision: The petition was likely close to the institution decision deadline or instituted before settlement. Specific institution details are not immediately available without a full document review, but the case terminated via settlement.
• Final Written Decision: Not issued, as the case settled.
• Settlement / termination: Terminated by settlement on 2018-12-19. The specific terms of the settlement are confidential.
• Appeal: Not applicable due to settlement.
• Defensive value: This IPR settled. As with the other settled IPRs, the later Federal Circuit affirmation of invalidity for all claims in IPR2018-00706 overshadows the outcome of this settled proceeding.

Strategic summary

All 25 claims of US8717204B2 have been CANCELED. In IPR2018-00706, initiated by Unified Patents Inc., claims 1-25 were challenged and ultimately found unpatentable under 35 U.S.C. § 101 as directed to an abstract idea. This decision was subsequently affirmed by the Federal Circuit in case number 20-1090. Therefore, no claims remain active or patentable in US8717204B2.

The estoppel landscape is comprehensive: any defendant facing assertion of this patent can readily demonstrate that all claims have been declared unpatentable and this finding has been upheld on appeal. While there were two denied institutions (CBM2017-00061 and IPR2017-02129) and three settlements (IPR2017-01710, IPR2018-00612, IPR2018-00656) which did not result in a final invalidity ruling from the PTAB, the subsequent IPR2018-00706 effectively nullified any potential benefit to the patent owner from those earlier outcomes. The grounds raised or reasonably could have been raised by the petitioners in the settled or denied proceedings are now moot, as the claims themselves are invalid. Unified Patents, a defensive aggregator, was successful in invalidating all claims.

Recommended next steps

If you are a defendant facing an assertion of US patent 8717204B2, you should immediately highlight that all claims (1-25) of the patent have been found unpatentable under 35 U.S.C. § 101 by the PTAB and this decision was affirmed by the Federal Circuit. Any infringement theory built on these claims is fundamentally flawed and could be considered sanction-bait.

Quote the disposition from the Federal Circuit's affirming decision for IPR2018-00706. The full decision can be found on CourtListener:

• Unified Patents, LLC v. Realtime Data, LLC, No. 20-1090 (Fed. Cir. 2021)

The Federal Circuit affirmed the Board's conclusion that "all challenged claims are directed to patent-ineligible subject matter under 35 U.S.C. § 101."

The absence of any active proceedings and the final, affirmed invalidation of all claims means that the patent owner currently holds a patent with no enforceable claims.

Citations:
https://portal.unifiedpatents.com/ptab/case/IPR2018-00706
https://patents.google.com/patent/US8717204B2/en
https://developer.uspto.gov/ptab-api/documents/IPR2018-00706/FD8C7A0EBC8869E1F5BD1913968C05DD61-0.pdf
https://developer.uspto.gov/ptab-api/documents/CBM2017-00061/8B9294248E5970A1A22BE27117E3F86D72-0.pdf
https://www.courtlistener.com/opinion/[4882142](/patent/4882142)/unified-patents-llc-v-realtime-data-llc/

Inventors

• James J. Fallon (Realtime Data LLC)
• Paul F. Pickel (Realtime Data LLC)
• Stephen J. McErlain (Realtime Data LLC)
• II Carlton J. Melone (Realtime Data LLC)

All inventors appear to have been associated with Realtime Data LLC at the time of filing, as they assigned their interest to the company concurrently with the application filing.

Original assignee

Realtime Data LLC was the entity named on the issued patent. At the time of filing and issuance, Realtime Data LLC developed and marketed systems and methods for accelerated data transmission, particularly for financial data and news feeds, indicating they shipped products or provided services embodying the claims. Their primary line of business was high-speed data compression and acceleration technology. Their current status is that they are primarily known as a patent assertion entity (NPE), though the patent US8717204B2 is listed as "Expired - Fee Related" as of October 3, 2021.

Assignment timeline

• 2001-10-03 (executed) / recorded 2002-01-28 — Reel 007936/0652

  • Conveyance: ASSIGNMENT
  • Assignor: FALLON, JAMES J.
  • Assignee: REALTIME DATA LLC
  • Correspondent: JOHN S. PRATT, ESQ., MORGAN & FINNEGAN, L.L.P., 345 PARK AVENUE, NEW YORK, NY 10154
  • Context: Inventor assigns rights to the original assignee for the initial priority application.

• 2003-05-07 (executed) / recorded 2003-05-19 — Reel 010376/0925

  • Conveyance: ASSIGNMENT
  • Assignor: FALLON, JAMES J. ET AL
  • Assignee: REALTIME DATA LLC
  • Correspondent: MORGAN & FINNEGAN, L.L.P., 345 PARK AVENUE, NEW YORK, NY 10154. This correspondent (firm) recurs in this chain.
  • Context: Inventors assign rights to the original assignee for a continuation application in the patent family.

• 2013-09-24 (executed) / recorded 2013-10-01 — Reel 030386/0339

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: FALLON, JAMES J.; MCERLAIN, STEPHEN J.; PICKEL, PAUL F.; MELONE, CARLTON J., 2ND
  • Assignee: REALTIME DATA, LLC
  • Correspondent: SCHOX, PATRICK, SCHOX, PLC, 500 3RD STREET, SUITE 515, SAN FRANCISCO, CA 94107
  • Context: Inventors assign specific interests to the original assignee for the application that led to US8717204B2.

Timeline diagram

timeline
    title Ownership of US 8717204B2
    2000 : Provisional application filed
    2001 : Inventor Fallon assigns to Realtime Data LLC
    2003 : Inventors assign to Realtime Data LLC
    2013 : Inventors assign to Realtime Data LLC
    2014 : Patent 8717204B2 issued
    2017 : First litigation filed
    2021 : Patent expired

NPE / troll-pattern signals

1. Shell-entity transfer: Not present. The patent has consistently been assigned to Realtime Data LLC, without any transfers to distinct shell entities within the recorded chain.
2. Known asserter in the chain: Present. Realtime Data LLC is a known patent asserter. The Google Patents record indicates that this patent has been involved in multiple district court litigation cases across various jurisdictions (Massachusetts, Texas Eastern, California Northern, Delaware) and several PTAB cases (e.g., IPR2018-00706, IPR2018-00612, CBM2017-00061).
3. Repeat correspondent across the chain: Present. The law firm Morgan & Finnegan, L.L.P. (and John S. Pratt, Esq. from that firm) appears as the correspondent for two assignments (Reel 007936/0652 and Reel 010376/0925) within the patent family's assignment history, indicating a recurring legal representative for Realtime Data LLC in the early stages of patent prosecution.
4. Cascading transfers: Not present. There are no multiple consecutive assignments through chained LLCs in a short timeframe.
5. Pre-litigation transfer: Not present. The last assignment recorded for the application leading to US8717204B2 was in 2013 (Reel 030386/0339), while the first reported litigation for this patent family occurred in 2017.
6. Bankruptcy fire-sale: Not present. There is no evidence in the assignment records or Google Patents suggesting that the patent was acquired through bankruptcy proceedings.
7. Privateering: Unclear. There is no direct evidence within the patent records or readily available public litigation data to confirm or deny privateering activity by Realtime Data LLC.
8. Defensive aggregator (anti-NPE): Not present. The current assignee, Realtime Data LLC, is an assertion entity, not a defensive aggregator, and the patent has not been acquired by one.

Verdict

NPE — high confidence

This verdict is driven by the presence of a known asserter, Realtime Data LLC, as the consistent owner throughout the patent's lifecycle and its involvement in extensive litigation, as documented by multiple district court and PTAB cases referenced in the Google Patents legal events section. The recurrence of the same correspondent firm in the early assignment chain (Reel 007936/0652 and Reel 010376/0925) further supports the pattern of a dedicated entity managing intellectual property for assertion.

For verification, see the USPTO Patent Assignment Search results for US8717204B2 at: https://assignmentcenter.uspto.gov/patent/[8717204B2](/patent/8717204B2)

To identify the most relevant prior art for US patent 8717204B2, I have examined the "Cited patents" section on its Google Patents page (which aggregates data from the USPTO). The patent itself also explicitly cross-references and incorporates several related patents by reference. Based on this, the two most relevant prior art references are U.S. Pat. No. 6,195,024 and U.S. Pat. No. 6,309,424, both by the same inventor and assignee.

Here is a breakdown of these key prior art references and their potential anticipation of US8717204B2's claims:

Most Relevant Prior Art for US8717204B2

1. U.S. Pat. No. 6,195,024 (Fallon '024)

• Full Citation: US6195024B1, "Content Independent Data Compression Method and System"
• Publication/Issue Date: February 27, 2001
• Filing Date: March 11, 1999
• Brief Description: This patent describes a method and system for optimally compressing an input data stream by employing a plurality of different encoders. The system processes a data block through multiple encoders and then selectively combines the compressed data blocks, choosing the output from the encoder that achieved the best compression ratio. This approach aims to provide optimal compression regardless of the input data's content. The patent also discusses a corresponding decompression system that identifies the type of compression applied and uses the appropriate decoder [cite: https://patents.google.com/patent/US6195024B1/en].
• Potential Anticipated Claim(s) under 35 U.S.C. § 102:
  • Claims 1, 11, and 16 (Method, Server, and System for Accelerating Data Transmission): US8717204B2 explicitly states that the data compression/decompression techniques disclosed in US6195024B1 "may be used in addition to, or in lieu of, the statistical based compression schemes described above" for providing accelerated data transmission. Furthermore, US8717204B2 describes and illustrates a "content-independent data compression system" (FIG. 5) and a "decompression system" (FIG. 6) that are directly stated to be detailed in US6195024B1. Therefore, any elements in claims 1, 11, or 16 of US8717204B2 that relate to using a content-independent compression scheme (or a system/method that switches to one when a content-dependent scheme is inefficient) for the purpose of achieving accelerated data transmission, increased effective bandwidth, or reduced latency, would likely be directly anticipated by US6195024B1. The core idea of applying an "optimal" compression method to reduce data size, which inherently leads to faster data movement, is present.

2. U.S. Pat. No. 6,309,424 (Fallon '424)

• Full Citation: US6309424B1, "High speed data storage and retrieval system"
• Publication/Issue Date: October 30, 2001
• Filing Date: January 11, 2000
• Brief Description: This patent details a system and method for achieving high-speed data storage and retrieval through the application of data compression prior to storage and decompression prior to retrieval. The stated goal is to effectively multiply the storage bandwidth and reduce latency, ensuring that the total time for compression, storage, and decompression is less than the time to store uncompressed data [cite: https://patents.google.com/patent/US6309424B1/en].
• Potential Anticipated Claim(s) under 35 U.S.C. § 102:
  • Claims 1, 11, and 16 (Method, Server, and System for Accelerating Data Transmission): US8717204B2 acknowledges that the "concept of 'acceleration'" (defined by increasing effective bandwidth and reducing latency through compression) "may be applied to the storage and retrieval of data to any memory or storage device using the compression methods disclosed in the above-incorporated U.S. Pat. Nos. 6,195,024 and 6,309,424." US6309424B1 directly teaches the principle of "acceleration" via compression/decompression to achieve increased effective bandwidth and reduced latency, explicitly formulating this relationship mathematically. While US6309424B1 applies this to storage and retrieval, the underlying principle of accelerating data movement by reducing data volume through real-time compression is fundamentally the same. A PHOSITA could readily extend this known "acceleration" principle from data storage to data transmission. Therefore, the broad concept of a method, server, or system that "accelerates data transmission" by compressing and decompressing data in real-time to increase effective bandwidth and reduce latency, as claimed in US8717204B2, is potentially anticipated in its fundamental principles by US6309424B1.

These two references are particularly relevant because they originate from the same inventors and assignee, and US8717204B2 explicitly incorporates their teachings by reference, often describing the current invention as an application or extension of these prior works.

Obviousness Analysis under 35 U.S.C. § 103 for US8717204B2

This analysis identifies combinations of prior art references that would render the claims of US patent 8717204B2 obvious to a person having ordinary skill in the art (POSA). The primary prior art references considered, as identified in the patent's "CROSS REFERENCE TO RELATED APPLICATIONS" and "DETAILED DESCRIPTION OF PREFERRED EMBODIMENTS" sections, are US7777651B2, US7417568B2, US6195024B1, and US6309424B1.

Strategic Summary of Prior Art Relevance:

• US7777651B2 and US7417568B2: These patents are direct parents in the continuation chain of US8717204B2. They share essentially the same detailed specification, describing methods for accelerated data transmission using real-time statistical compression/decompression with state machines, particularly for financial data. Their disclosures are foundational and would be considered highly relevant art from the same inventive entity. For § 103 purposes, they represent the closest existing technology and provide the core teachings upon which any alleged invention in US8717204B2 would build.
• US6195024B1 ("Content Independent Data Compression Method and System"): This patent has an earlier filing date than US8717204B2's earliest priority and is explicitly incorporated by reference into US8717204B2. It teaches content-independent data compression by employing multiple encoders and selecting the best compression ratio among them. US8717204B2 itself discusses using a content-independent scheme, such as that described in US6195024B1, in conjunction with its primary content-dependent scheme when the latter's efficiency falters.
• US6309424B1 ("Lossless Data Compression Method and System"): This patent shares the same earliest priority date as US8717204B2 and is also incorporated by reference. While its common priority date precludes it from being anticipating prior art under 35 U.S.C. § 102, its disclosure is relevant for understanding the broader inventive context and for obviousness considerations under 35 U.S.C. § 103 in combination with other prior art. It teaches lossless data compression by selectively combining output from multiple encoders.

Obviousness Combinations and Motivation to Combine:

Combination 1: US7777651B2 (or US7417568B2) in view of US6195024B1 and general knowledge of adaptive compression.

1. Primary Reference (Base System): US7777651B2 (or US7417568B2) discloses a system and method for accelerated data transmission (e.g., financial data) using real-time statistical compression and decompression via state machines, aiming to increase effective bandwidth and reduce latency. This reference provides the core elements of receiving data, applying context-dependent statistical compression using state machines and tables, and transmitting the compressed data. It also introduces the concept of "virtual encryption" through complex compression.
2. Secondary Reference (Adaptive Strategy): US6195024B1 teaches a content-independent data compression system that optimizes compression by applying multiple different encoders to an input data stream and selectively combining the compressed blocks based on their achieved compression ratios. This system inherently includes a mechanism to determine the "best" compression and adapt accordingly.
3. Motivation to Combine:
   • Explicit Teaching by the Inventors: The specification of US8717204B2 explicitly provides the motivation for this combination: "a compression system may employ both a content-dependent scheme and a content-independent scheme, such as disclosed in the above-incorporated application Ser. No. 10/016,355." It further states that the content-dependent scheme (e.g., from US7777651B2) would be the primary, but "the content-independent scheme is used in place of, or in conjunction with, the content dependent scheme, when periodically checked 'compression factor' meets a predetermined threshold." This clearly indicates a known problem (content-dependent compression efficiency may vary) and a known solution (switch to a content-independent method like US6195024B1).
   • Predictable Result: A POSA would recognize that the efficiency of content-dependent compression schemes (like those using fixed statistical tables, even if adaptively generated over time) can fluctuate with changes in data structure or content. It would be a logical and predictable design choice to integrate a robust, content-independent compression method, as taught by US6195024B1, to maintain high compression ratios and performance when the primary scheme's efficiency degrades. This directly addresses claims in US8717204B2 that relate to determining a compression factor and modifying or switching encoding schemes based on a threshold (e.g., Claims 14-16 and 30-32).

Combination 2: US7777651B2 (or US7417568B2) in view of general knowledge of data security and encryption.

1. Primary Reference (Base System): US7777651B2 (or US7417568B2) discloses the accelerated data transmission system, including the use of compression/decompression state machines and tables. The patent notes that "virtual encryption" is achieved through the complexity of Huffman or Arithmetic encoding.
2. General Knowledge (Security Enhancement): At the time of invention, it was well-known in the art of data transmission and network systems to explicitly encrypt sensitive components or data for enhanced security and access control. This includes mechanisms for storing proprietary algorithms or keys in an encrypted manner and decrypting them upon authenticated access.
3. Motivation to Combine:
   • Addressing a Known Problem: The problem of ensuring secure transmission and controlling unauthorized access to proprietary information (such as the decompression tables crucial for decoding the data stream) is a fundamental concern in data communication systems, particularly for valuable financial data. The patent itself highlights this, stating that without protection, a client could potentially use tables on other processors or after terminating a service.
   • Routine Design Choice: Given the sensitive nature of the data (e.g., financial trading data) and the proprietary nature of the compression/decompression tables, a POSA would be motivated to apply standard data security measures to protect these critical assets. Encrypting the client-side decompression tables and requiring a validated encryption/decryption key upon loading is a straightforward and widely practiced method for securing software components and controlling intellectual property. This would be considered a routine engineering decision to improve security and enforce licensing terms for the system described in US7777651B2.
   • This combination would particularly render obvious aspects of claims that specify "secure transmission" and, more specifically, the mechanism of storing client-side decompression tables in encrypted form and decrypting them with a validated key, as detailed in the specification.

Conclusion on Obviousness:

The core teachings of US8717204B2 regarding accelerated data transmission via real-time statistical compression with state machines are extensively covered by its direct parent patents, US7777651B2 and US7417568B2. Any incremental novelty, such as the adaptive switching between content-dependent and content-independent compression, is directly motivated and even explicitly suggested by the patent's own references to US6195024B1. Similarly, the explicit encryption of client-side decompression tables, while a specific implementation detail, represents a routine application of well-known data security practices to a critical component of the system.

The PTAB's decision in IPR2018-00706 to institute review of claims 1-25 under obviousness over "Fallon '024" (US6195024B1) and "Fallon '424" (US6309424B1) in view of common general knowledge further supports the strength of these obviousness arguments, even though the final decision rested on § 101. [cite: https://portal.unifiedpatents.com/ptab/case/IPR2018-00706]

Therefore, a POSA would have been motivated to combine the teachings of US7777651B2 (or US7417568B2) with US6195024B1 to create an adaptively optimizing compression system, and with general knowledge of data security to implement robust protection for the decompression tables, thereby rendering many of the claims of US8717204B2 obvious under 35 U.S.C. § 103.