Apple Inc., (Petitioner)
`v.
`Realtime Data LLC (Patent Owner)
`
`Demonstratives
`Trial Nos. IPR2016-01365 and -01366
`U.S. Patent Nos. 7,181,608 and 8,090,936
`
`Before Hon. G. W. Braden, J. J. Lee, and J. J. Chung
`Administrative Patent Judges
`
`1
`
`1
`
`APPLE 1023
`Apple v. Realtime
`IPR2016-01366
`
`
`v.
`Realtime Data LLC (Patent Owner)
`
`Demonstratives
`Trial Nos. IPR2016-01365 and -01366
`U.S. Patent Nos. 7,181,608 and 8,090,936
`
`Before Hon. G. W. Braden, J. J. Lee, and J. J. Chung
`Administrative Patent Judges
`
`1
`
`1
`
`APPLE 1023
`Apple v. Realtime
`IPR2016-01366
`
`
`
`Table of Contents
`
`Topics
`The Realtime Patents
`Overview
`Grounds Instituted in Inter Partes Review
`Similarity of Claims at Issue
`General Subject Matter
`Examples
`Claim Construction
`Ground 1 and Disputed Issues
`Instituted Ground 1 – Sukegawa & Dye
`Issue 1: Preloading Happens Prior to Completion
`Issue 2: Preloading Does not Preclude Sukegawa’s Techniques
`Issue 3: Dye Describes a Plurality of Encoders
`Issue 4: Dye Properly Incorporates Dye ’284
`Arguments for ’608 Issues 2-4 Are Equally Applicable to ’936 Issues 2-4
`Issue 5: Sukegawa Renders Obvious the Features of ’936 Claim 18
`Grounds 2-4 and Disputed Issues
`Realtime does not Dispute Motivation from Settsu and Burrows
`Issue 5: Settsu, in its Combinations, Renders Obvious the Features of ’936 Claim 18
`Issue 6: Settsu Describes Storing Substantially All of an OS
`Detailed Application of Prior Art to Claims
`Instituted Ground 1 - Sukegawa & Dye
`Instituted Grounds 2-4 – Sukegawa, Dye, & (Settsu and/or Burrows)
`
`Slide No.
`3
`4
`5
`6
`7
`8
`10
`17
`18
`21
`26
`31
`37
`41
`42
`45
`46
`47
`50
`52
`53
`78
`
`2
`
`2
`
`
`
`The Realtime Patents
`
`The Realtime Patents
`
`3
`
`3
`
`
`
`The Realtime Patents:
`Overview
`
`These related proceedings involve two
`Realtime patents issued based on the same
`specification
`• The patents include:
`• US 7,181,608 (“the ’608 patent”)
`• US 8,090,936 (“the ’936 patent”)
`The 936 patent issued from a continuation of US
`application no. 09/776,267, the application from
`which the ’608 patent issued
`
`•
`
`US 7,181,608 (“the ’608 patent”) &
`US 8,090,936 (“the ’936 patent”)
`
`See, e.g.,
`IPR2016-01365, Ex. 1001 (“the ’608 patent”);
`IPR2016-01366, Ex. 1001 (“the ’936 patent”).
`
`4
`
`4
`
`
`
`Grounds Instituted in Inter Partes Review
`
`1-6 & 9-17
`
`1-10 & 18-24
`
`Grounds Instituted in Inter Partes Review of Realtime Patents – 35 U.S.C. § 103
`Prior Art
`’608 Patent Claims
`’936 Patent Claims
`US Patent No. 5,860,083
`1-31
`1-24
`(“Sukegawa”) & US
`Patent No. 6,145,069
`(“Dye”)
`Sukegawa, Dye, & US
`Patent No. 6,374,353
`(“Settsu”)
`Sukegawa, Dye, & NPL
`Burrows
`
`1-6 & 9-17
`
`1-10
`
`Sukegawa, Dye, Settsu,
`& Burrows
`
`1-6 & 9-17
`
`1-10
`
`5
`
`5
`
`
`
`Similarity of Claims at Issue
`
`’608 Patent
`
`’936 Patent
`
`’608 Patent, 27:43-60 (claim 1)
`
`’936 Patent, 27:6-22 (claim 1)
`
`See, e.g., IPR2016-01365, Ex. 1001; IPR2016-01366, Ex. 1001
`
`6
`
`6
`
`
`
`The Realtime Patents:
`General Subject Matter
`
`’608 Patent, FIG. 1 (excerpt, annotated); ’608 Petition, 3
`
`’608 Patent, Abstract
`
`7
`
`7
`
`
`
`The Realtime Patents:
`Examples of Preloading
`Examples
`
`’608 Patent, 21:45-65
`
`’608 Patent, 22:14-39
`8
`
`8
`
`
`
`The Realtime Patents:
`Example of Compression/Decompression
`
`Example
`
`’608 Patent, 22:6-8
`
`9
`
`9
`
`
`
`Claim Construction
`
`Claim Construction
`
`10
`10
`
`10
`
`10
`
`
`
`Construction: Preloading
`
`Realtime’s Construction:
`
`“preloading ... should mean ‘transferring data from storage to memory in
`anticipation of immediate or near-in-time use.’” Patent Owner’s Response, 12.
`
`Patent Owner’s Response
`
`’608 Patent
`
`Patent Owner’s Response, 12
`
`’608 Patent, 27:43-60 (claim 1)
`
`11
`
`11
`
`
`
`Construction: Preloading
`
`Rebuttal to:
`
`“preloading ... should mean ‘transferring data from storage to memory in
`anticipation of immediate or near-in-time use.’” Patent Owner’s Response, 12.
`
`Petitioner’s Reply
`
`’608 Patent
`
`Petitioner’s Reply, 2
`
`’608 Patent, 27:43-60 (claim 1)
`
`12
`
`12
`
`
`
`Construction: Preloading
`
`Rebuttal to:
`
`“preloading ... should mean ‘transferring data from storage to memory in
`anticipation of immediate or near-in-time use.’” Patent Owner’s Response, 12.
`
`Petitioner’s Reply
`
`’608 Patent
`
`Petitioner’s Reply, 3
`
`’608 Patent, 21:45-65 (cited in Petitioner’s Reply, 3-4)
`
`13
`
`13
`
`
`
`Construction: Preloading
`
`Rebuttal to:
`
`“preloading ... should mean ‘transferring data from storage to memory in
`anticipation of immediate or near-in-time use.’” Patent Owner’s Response, 12.
`
`Petitioner’s Reply
`
`’608 Patent
`
`Petitioner’s Reply, 4-5
`
`Petitioner’s Reply, 5
`
`’608 Patent, 22:40-50 (cited in Petitioner’s Reply, 4)
`
`’608 Patent, 6:60-63 (cited in Petitioner’s Reply, 5)
`
`14
`
`14
`
`
`
`Construction: Preloading
`
`Rebuttal to:
`
`“preloading ... should mean ‘transferring data from storage to memory in
`anticipation of immediate or near-in-time use.’” Patent Owner’s Response, 12.
`Petitioner’s Reply
`
`Petitioner’s Reply, 7-8
`Record Evidence
`
`*Jacob Ziv & Abraham Lempel, A Universal Algorithm for Sequential Data Compression
`
`APPLE-1018*, 12:18-23 (cited in Petitioner’s Reply, 8)
`
`15
`
`15
`
`
`
`Construction: Preloading
`
`Rebuttal to:
`
`“preloading ... should mean ‘transferring data from storage to memory in
`anticipation of immediate or near-in-time use.’” Patent Owner’s Response, 12.
`Petitioner’s Reply
`
`Petitioner’s Reply, 8
`Record Evidence
`
`*U.S. Patent No. 6,463,509 (“Teoman”)
`
`APPLE-1020*, Fig. 9
`(excerpt, highlighted)
`
`APPLE-1020, Fig. 10
`(excerpt, highlighted)
`
`16
`
`16
`
`
`
`Ground 1 and Disputed Issues
`
`17
`
`17
`
`
`
`Sukegawa Describes Preloading
`
`Ex. 1005
`
`Ex. 1005
`
`“Sukegawa”
`
`Ex. 1005, Fig. 1 (excerpt, annotated);
`Petition, 7
`
`Petition, 7-8
`
`Petition, 25
`
`18
`
`18
`
`
`
`Dye Describes Compression/Decompression
`
`Ex. 1008
`
`Ex. 1008
`
`“Dye”
`
`Ex. 1008, Fig. 3 (excerpt, annotated);
`Petition, 12
`
`Petition, 34-35 (citing Exhibit 1003, ¶¶ 118-121)
`
`19
`
`19
`
`
`
`Combination of Sukegawa & Dye
`Sukegawa in view of Dye
`
`“Sukegawa describes a controller 3 that
`preloads control information … into flash
`memory unit 1, and uses the preloaded
`control information to start the OS and
`application programs at higher speed.”
`Petition, 24.
`
`“Dye describes a controller that … [uses] fast
`parallel compression and decompression
`technology … to increase the effective
`density and read access time of … hard disk
`drives and flash memories.” Petition, 33-34.
`
`“From [Dye’s] description, a POSITA would
`have been motivated to modify Sukegawa to
`increase the effective density and read
`access rate of … storage devices in
`Sukegawa’s system, and to thereby achieve
`further reduction in the time required for
`booting up.” Petition, 34.
`
`20
`
`Petition 14-15 (citing Exhibit 1003, ¶¶67, 120)
`
`Exhibit 1005, Fig.1 & Exhibit 1008, Fig. 3
`(combined excerpts, annotated); Petition, 15
`
`20
`
`
`
`Ground 1: Issues
`
`’608 Issues
`Issue 1: Preloading Happens Prior to Completion
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`Issue 3: Dye Describes a Plurality of Encoders
`Issue 4: Dye Properly Incorporates Dye ’284
`’936 Issues
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`Issue 3: Dye Describes a Plurality of Encoders
`Issue 4: Dye Properly Incorporates Dye ’284
`Issue 5: Sukegawa Renders Obvious the Features of ’936 Claim 18
`
`21
`
`21
`
`
`
`Issue 1: Preloading Happens Prior to Completion
`
`“[Claim 1’s] plain language requires that the steps of ‘initializing’ and ‘preloading’ be
`Realtime’s Argument:
`performed during the same initialization process.” Patent Owner’s Response, 28.
`Patent Owner’s Response
`’608 Patent
`
`Patent Owner’s Response, 28
`
`’608 Patent, 27:43-60 (claim 1)
`
`Patent Owner’s Response, 30
`
`22
`
`22
`
`
`
`Issue 1: Preloading Happens Prior to Completion
`
`Rebuttal to:
`“[Claim 1’s] plain language requires that the steps of ‘initializing’ and ‘preloading’ be
`performed during the same initialization process.” Patent Owner’s Response, 28.
`’608 Patent
`Petitioner’s Reply
`
`Petitioner’s Reply, 15-16
`
`’608 Patent, 27:43-60 (claim 1)
`“[N]otably absent … is reference to any
`particular initialization, as … [claim 1] recites
`initialization without reference to ‘the’
`initializing step.” Petitioner’s Reply, 16.
`
`23
`
`23
`
`
`
`Issue 1: Preloading Happens Prior to Completion
`
`Rebuttal to:
`“[Claim 1’s] plain language requires that the steps of ‘initializing’ and ‘preloading’ be
`performed during the same initialization process.” Patent Owner’s Response, 28.
`’608 Patent (Claim 1)
`Petitioner’s Reply
`
`’608 Patent, 27:43-60 (claim 1)
`’608 Patent (Specification)
`
`Petitioner’s Reply, 18
`
`’608 Patent, Abstract (cited in POR, 32)
`24
`
`24
`
`
`
`Issue 1: Preloading Happens Prior to Completion
`
`Rebuttal to:
`’608 Patent
`
`“[Claim 1’s] plain language requires that the steps of ‘initializing’ and ‘preloading’ be
`performed during the same initialization process.” Patent Owner’s Response, 28.
`
`Sukegawa
`
`’608 Patent, 21:45-65 (cited in Petitioner’s Reply, 5)
`
`’608 Patent, 22:40-50 (cited in Petitioner’s Reply, 4)
`
`Sukegawa, 6:19-44 (cited in Petition, 31)
`
`25
`
`25
`
`
`
`Ground 1: Issues
`
`’608 Issues
`Issue 1: Preloading Happens Prior to Completion
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`Issue 3: Dye Describes a Plurality of Encoders
`Issue 4: Dye Properly Incorporates Dye ’284
`’936 Issues
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`Issue 3: Dye Describes a Plurality of Encoders
`Issue 4: Dye Properly Incorporates Dye ’284
`Issue 5: Sukegawa Renders Obvious the Features of ’936 Claim 18
`
`26
`
`26
`
`
`
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`
`Realtime’s Argument:
`Patent Owner’s Response
`
`“merely ‘storing’ data in a particular location, as Sukegawa does,
`cannot comprise ‘preloading.’” Patent Owner’s Response, 18.
`
`Patent Owner’s Response, 18-19
`
`Patent Owner’s Response, 21-22
`
`27
`
`27
`
`
`
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`
`Rebuttal to:
`Petitioner’s Reply
`
`“merely ‘storing’ data in a particular location, as Sukegawa does,
`cannot comprise ‘preloading.’” Patent Owner’s Response, 18.
`’608 Patent
`
`Petitioner’s Reply, 12
`
`Examples of preloading in the ’608 patent
`that involve storing.
`
`’608 Patent, Abstract
`
`’608 Patent, 3:49-52
`
`’608 Patent, 4:20-22
`
`28
`
`28
`
`
`
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`
`Rebuttal to:
`
`“merely ‘storing’ data in a particular location, as Sukegawa does,
`cannot comprise ‘preloading.’” Patent Owner’s Response, 18.
`
`Petitioner’s Reply
`
`Dr. Back’s Deposition Testimony
`
`Petitioner’s Reply, 12
`’608 Patent
`
`’608 Patent, 6:60-63 (cited in Petitioner’s Reply, 5)
`
`Exhibit 1017, 29
`
`Exhibit 1017, 30
`
`29
`
`29
`
`
`
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`
`Rebuttal to:
`’608 Patent
`
`“merely ‘storing’ data in a particular location, as Sukegawa does,
`cannot comprise ‘preloading.’” Patent Owner’s Response, 18.
`
`Dr. Back’s Deposition Testimony
`
`’608 Patent, 21:45-65 (cited in Petitioner’s Reply, 5)
`
`Exhibit 1017, 76
`
`’608 Patent, 22:40-50 (cited in Petitioner’s Reply, 4)
`
`30
`
`30
`
`
`
`Ground 1: Issues
`
`’608 Issues
`Issue 1: Preloading Happens Prior to Completion
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`Issue 3: Dye Describes a Plurality of Encoders
`Issue 4: Dye Properly Incorporates Dye ’284
`’936 Issues
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`Issue 3: Dye Describes a Plurality of Encoders
`Issue 4: Dye Properly Incorporates Dye ’284
`Issue 5: Sukegawa Renders Obvious the Features of ’936 Claim 18
`
`31
`
`31
`
`
`
`Issue 3: Dye Describes a Plurality of Encoders
`
`’608 Pat
`
`Realtime’s Argument:
`
`“Dye only discloses a single encoder.’”
`Patent Owner’s Response, 37.
`
`’608 Patent, 29:1-2 (claim 16)
`Patent Owner’s Response
`
`Patent Owner’s Response, 39-40
`
`Patent Owner’s Response, 41-42
`
`32
`
`32
`
`
`
`Issue 3: Dye Describes a Plurality of Encoders
`
`Rebuttal to:
`Petitioner’s Reply
`
`“Dye only discloses a single encoder.’”
`Patent Owner’s Response, 37.
`Dye
`
`Petitioner’s Reply, 20-21
`
`Dye, Fig. 10
`“[T]his logic encodes four bytes of the input stream …
`and produces encoded information ….”
`Petitioner’s Reply, 16.
`
`33
`
`33
`
`
`
`Issue 3: Dye Describes a Plurality of Encoders
`
`Rebuttal to:
`Patent Owner’s Response
`
`“Dye only discloses a single encoder.’”
`Patent Owner’s Response, 37.
`Record Evidence
`
`Patent Owner’s Response, 40
`Petitioner’s Reply
`
`Petitioner’s Reply, 21
`*Encoder, Microsoft Press Computer Dictionary (5th ed. 2002)
`**Encoder, The Computer Desktop Encyclopedia (2nd ed. 1999)
`
`Exhibit 1021*, 4
`
`Exhibit 1022**, 3
`
`34
`
`34
`
`
`
`Issue 3: Dye Describes a Plurality of Encoders
`
`Rebuttal to:
`Petitioner’s Reply
`
`“Dye only discloses a single encoder.’”
`Patent Owner’s Response, 37.
`’608 Patent
`
`Petitioner’s Reply, 21-22
`
`’608 Patent, 25:28-32
`
`Dye
`
`Dye, 18:61-19:11
`
`35
`
`35
`
`
`
`Issue 3: Dye Describes a Plurality of Encoders
`
`Rebuttal to:
`
`“Dye only discloses a single encoder.’”
`Patent Owner’s Response, 37.
`Petitioner’s Reply
`
`Petitioner’s Reply, 22
`
`Dye
`
`Petitioner’s Reply, 22-23
`Dye ’284
`
`Dye ’284**, 12:61-62
`
`Dye ’284, 13:52-57
`
`Dye*, 1:17-22
`
`Dye, 3:17-22
`
`*U.S. Patent No. 6,145,069 (“Dye”)
`**U.S. Patent No. 7,190,284 (“Dye ’284”)(incorporated by reference into Dye)
`
`36
`
`36
`
`
`
`Ground 1: Issues
`
`’608 Issues
`Issue 1: Preloading Happens Prior to Completion
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`Issue 3: Dye Describes a Plurality of Encoders
`Issue 4: Dye Properly Incorporates Dye ’284
`’936 Issues
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`Issue 3: Dye Describes a Plurality of Encoders
`Issue 4: Dye Properly Incorporates Dye ’284
`Issue 5: Sukegawa Renders Obvious the Features of ’936 Claim 18
`
`37
`
`37
`
`
`
`Issue 4: Dye Properly Incorporates Dye ’284
`
`Realtime’s Argument:
`
`“Apple cannot rely on Dye ’284 … [because] Dye ’284 is not properly
`incorporated by reference into Dye ....” Patent Owner’s Response, 46.
`
`Patent Owner’s Response
`
`Patent Owner’s Response, 46
`
`38
`
`38
`
`
`
`Issue 4: Dye Properly Incorporates Dye ’284
`
`Rebuttal to:
`Petitioner’s Reply
`
`“Apple cannot rely on Dye ’284 … [because] Dye ’284 is not properly
`incorporated by reference into Dye ....” Patent Owner’s Response, 46.
`Dye
`
`Dealertrack, Inc. v. Huber
`
`Dye, 6:3-9
`
`Petitioner’s Reply, 24
`
`Dealertrack, Inc. v. Huber, 674 F.3d 1315, 1323 (Fed. Cir. 2012)
`
`39
`
`39
`
`
`
`Ground 1 and ’936 Issues
`
`Ground 1 and ’936 Issues
`
`40
`40
`
`40
`
`40
`
`
`
`Arguments for ’608 Issues 2-4
`Are Equally Applicable to ’936 Issues 2-4
`
`’608 Patent
`
`’936 Patent
`
`’608 Patent, 27:43-60 (claim 1)
`
`’936 Patent, 27:6-22 (claim 1)
`
`’608 Patent, 29:1-2 (claim 16)
`
`’936 Patent, 27:45-47 (claim 9)
`
`41
`
`41
`
`
`
`Ground 1: Issues
`
`’608 Issues
`Issue 1: Preloading Happens Prior to Completion
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`Issue 3: Dye Describes a Plurality of Encoders
`Issue 4: Dye Properly Incorporates Dye ’284
`’936 Issues
`Issue 2: Preloading Does Not Preclude Sukegawa’s Techniques
`Issue 3: Dye Describes a Plurality of Encoders
`Issue 4: Dye Properly Incorporates Dye ’284
`Issue 5: Sukegawa Renders Obvious the Features of ’936 Claim 18
`
`42
`
`42
`
`
`
`Issue 5: Sukegawa Renders Obvious the Features of ’936 Claim 18
`
`Realtime’s Argument:
`
`“Sukegawa does not disclose using any of its control information ‘to partially boot’ using a first
`portion of the OS and ‘to further partially boot using a second portion of the OS.” Patent Owner’s
`Response, 30.
`
`’936 Patent Owner’s Response
`
`’936 Patent
`
`’936 Patent Owner’s Response, 30
`
`’936 Patent, 28:28-46 (claim 18)
`
`43
`
`43
`
`
`
`Issue 5: Sukegawa Renders Obvious the Features of ’936 Claim 18
`
`Rebuttal to:
`’936 Petitioner’s Reply
`
`“Sukegawa does not disclose using any of its control information ‘to partially boot’ using a first
`portion of the OS and ‘to further partially boot using a second portion of the OS.” Patent Owner’s
`Response, 30.
`Sukegawa
`
`’936 Petitioner’s Reply, 15
`
`Sukegawa, 6:19-26
`’936 Patent
`
`’936 Petitioner’s Reply, 19 (citing Exhibit 1003, ¶¶304-307)
`
`’936 Patent, 21:56-63
`
`44
`
`44
`
`
`
`Grounds 2-4 and Disputed Issues
`(’608 and ’936)
`
`45
`
`45
`
`
`
`Realtime does not Dispute Motivation from Settsu and Burrows
`
`Petition
`
`Settsu
`
`Petition, 16
`
`Petition, 18 (citing Exhibit 1003, ¶¶142-143)
`Burrows
`
`Settsu, Fig. 1 (excerpt)
`
`Burrows, 1
`
`46
`
`46
`
`
`
`Grounds 2-4: Issues
`
`Issue 5: Settsu, in its Combinations, Renders Obvious the Features of ’936 Claim 18
`Issue 6: Settsu Describes Storing Substantially All of an OS
`
`47
`
`47
`
`
`
`Issue 5: Settsu, in its Combinations, Renders Obvious the Features of ’936 Claim 18
`
`’936 Petition
`
`’936 Patent
`
`’936 Petition, 65
`
`’936 Petition, 66
`’936 Petitioner’s Reply
`
`’936 Petitioner’s Reply, 22
`
`’936 Patent, 28:28-46 (claim 18)
`
`48
`
`48
`
`
`
`Issue 5: Settsu, in its Combinations, Renders Obvious the Features of ’936 Claim 18
`
`Settsu
`
`Settsu, Fig. 12
`
`“Settsu explains that, for each main OS body
`functional module, the module is decompressed and a
`corresponding thread is started by mini OS module 7’s
`OS initialization processing module 31.”
`’936 Petition, 66.
`
`Settsu, Fig. 14
`
`49
`
`49
`
`
`
`Grounds 2-4: Issues
`
`Issue 5: Settsu, in its Combinations, Renders Obvious the Features of ’936 Claim 18
`Issue 6: Settsu Describes Storing Substantially All of an OS
`
`50
`
`50
`
`
`
`Issue 6: Settsu Describes Storing Substantially All of an OS
`
`’936 Petitioner’s Reply
`
`’936 Petitioner’s Reply, 19 (citing Exhibit 1003*, ¶¶281-285)
`
`’936 Patent
`
`’936 Petitioner’s Reply, 19 (reproducing Settsu Fig. 12)
`
`’936 Patent, 28:28-46 (claim 18)
`
`’936 Petition, 64 (citing Exhibit 1003, ¶284)
`*Declaration of Dr. Charles J. Neuhauser
`
`51
`
`51
`
`
`
`Detailed Application of Prior Art
`to Claims
`
`52
`
`52
`
`
`
`Detailed Application of Prior Art to Claims
`
`Instituted Ground 1 – Sukegawa & Dye
`Instituted Grounds 2-4 –
`2: Sukegawa, Dye, & Settsu
`3: Sukegawa, Dye, & Burrows
`4: Sukegawa, Dye, Settsu, & Burrows
`
`53
`
`53
`
`
`
`Sukegawa in view of Dye Grounds
`
`Sukegawa in view of Dye
`Sukegawa in view of Dye renders
`obvious claims 1-31 of the ’608 patent,
`and claims 1-24 of the ’936 patent
`
`Grounds Instituted in inter partes reviews of Realtime Patents – 35
`Grounds
`U.S.C. § 103
`Prior Art
`’608 Patent Claims
`Documents
`US Patent No.
`5,860,083
`(“Sukegawa”) &
`US Patent No.
`6,145,069 (“Dye”)
`
`’936 Patent Claims
`
`1-31
`
`1-24
`
`The ’608 Patent
`1. A method for providing accelerated
`loading of an operating system, comprising
`the steps of:
`maintaining a list of boot data used for
`booting a computer system;
`initializing a central processing unit of
`the computer system;
`preloading the boot data into a cache
`memory prior to completion of initialization
`of the central processing unit of the
`computer system, wherein preloading the
`boot data comprises accessing
`compressed boot data from a boot device;
`and
`servicing requests for boot data from
`the computer system using the preloaded
`boot data after completion of initialization
`of the central processing unit of the
`computer system, wherein servicing
`requests comprises accessing compressed
`boot data from the cache and
`decompressing the compressed boot data
`at a rate that increases the effective
`access rate of the cache.
`’608 Patent, Claim 1
`54
`
`54
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`Petition, 24 (citing Exhibit 1003, ¶91))
`
`Petition, 25
`
`The ’608 Patent
`1. A method for providing accelerated
`loading of an operating system, comprising
`the steps of:
`maintaining a list of boot data used for
`booting a computer system;
`initializing a central processing unit of
`the computer system;
`preloading the boot data into a cache
`memory prior to completion of initialization
`of the central processing unit of the
`computer system, wherein preloading the
`boot data comprises accessing
`compressed boot data from a boot device;
`and
`servicing requests for boot data from
`the computer system using the preloaded
`boot data after completion of initialization
`of the central processing unit of the
`computer system, wherein servicing
`requests comprises accessing compressed
`boot data from the cache and
`decompressing the compressed boot data
`at a rate that increases the effective
`access rate of the cache.
`’608 Patent, Claim 1
`55
`
`55
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`Petition, 26
`
`Petition, 27
`
`The ’608 Patent
`1. A method for providing accelerated
`loading of an operating system, comprising
`the steps of:
`maintaining a list of boot data used for
`booting a computer system;
`initializing a central processing unit of
`the computer system;
`preloading the boot data into a cache
`memory prior to completion of initialization
`of the central processing unit of the
`computer system, wherein preloading the
`boot data comprises accessing
`compressed boot data from a boot device;
`and
`servicing requests for boot data from
`the computer system using the preloaded
`boot data after completion of initialization
`of the central processing unit of the
`computer system, wherein servicing
`requests comprises accessing compressed
`boot data from the cache and
`decompressing the compressed boot data
`at a rate that increases the effective
`access rate of the cache.
`’608 Patent, Claim 1
`56
`
`56
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`Petition, 29-30 (citing Exhibit 1003, ¶¶100, 106-107)
`
`The ’608 Patent
`1. A method for providing accelerated
`loading of an operating system, comprising
`the steps of:
`maintaining a list of boot data used for
`booting a computer system;
`initializing a central processing unit of
`the computer system;
`preloading the boot data into a cache
`memory prior to completion of initialization
`of the central processing unit of the
`computer system, wherein preloading the
`boot data comprises accessing
`compressed boot data from a boot device;
`and
`servicing requests for boot data from
`the computer system using the preloaded
`boot data after completion of initialization
`of the central processing unit of the
`computer system, wherein servicing
`requests comprises accessing compressed
`boot data from the cache and
`decompressing the compressed boot data
`at a rate that increases the effective
`access rate of the cache.
`’608 Patent, Claim 1
`57
`
`57
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`Petition, 31
`
`Petition, 31
`
`Petition, 31
`
`The ’608 Patent
`1. A method for providing accelerated
`loading of an operating system, comprising
`the steps of:
`maintaining a list of boot data used for
`booting a computer system;
`initializing a central processing unit of
`the computer system;
`preloading the boot data into a cache
`memory prior to completion of initialization
`of the central processing unit of the
`computer system, wherein preloading the
`boot data comprises accessing
`compressed boot data from a boot device;
`and
`servicing requests for boot data from
`the computer system using the preloaded
`boot data after completion of initialization
`of the central processing unit of the
`computer system, wherein servicing
`requests comprises accessing compressed
`boot data from the cache and
`decompressing the compressed boot data
`at a rate that increases the effective
`access rate of the cache.
`’608 Patent, Claim 1
`58
`
`58
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`Petition, 33 (citing Exhibit 1003, ¶¶116, 117)
`
`Petition, 33 (citing Exhibit 1003, ¶¶118-121)
`
`The ’608 Patent
`1. A method for providing accelerated
`loading of an operating system, comprising
`the steps of:
`maintaining a list of boot data used for
`booting a computer system;
`initializing a central processing unit of
`the computer system;
`preloading the boot data into a cache
`memory prior to completion of initialization
`of the central processing unit of the
`computer system, wherein preloading the
`boot data comprises accessing
`compressed boot data from a boot device;
`and
`servicing requests for boot data from
`the computer system using the preloaded
`boot data after completion of initialization
`of the central processing unit of the
`computer system, wherein servicing
`requests comprises accessing compressed
`boot data from the cache and
`decompressing the compressed boot data
`at a rate that increases the effective
`access rate of the cache.
`’608 Patent, Claim 1
`59
`
`59
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`Petition, 33-34
`
`The ’608 Patent
`1. A method for providing accelerated
`loading of an operating system, comprising
`the steps of:
`maintaining a list of boot data used for
`booting a computer system;
`initializing a central processing unit of
`the computer system;
`preloading the boot data into a cache
`memory prior to completion of initialization
`of the central processing unit of the
`computer system, wherein preloading the
`boot data comprises accessing
`compressed boot data from a boot device;
`and
`servicing requests for boot data from
`the computer system using the preloaded
`boot data after completion of initialization
`of the central processing unit of the
`computer system, wherein servicing
`requests comprises accessing compressed
`boot data from the cache and
`decompressing the compressed boot data
`at a rate that increases the effective
`access rate of the cache.
`’608 Patent, Claim 1
`60
`
`60
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`Petition, 34-35 (citing Exhibit 1003, ¶¶ 118-121)
`
`The ’608 Patent
`1. A method for providing accelerated
`loading of an operating system, comprising
`the steps of:
`maintaining a list of boot data used for
`booting a computer system;
`initializing a central processing unit of
`the computer system;
`preloading the boot data into a cache
`memory prior to completion of initialization
`of the central processing unit of the
`computer system, wherein preloading the
`boot data comprises accessing
`compressed boot data from a boot device;
`and
`servicing requests for boot data from
`the computer system using the preloaded
`boot data after completion of initialization
`of the central processing unit of the
`computer system, wherein servicing
`requests comprises accessing compressed
`boot data from the cache and
`decompressing the compressed boot data
`at a rate that increases the effective
`access rate of the cache.
`’608 Patent, Claim 1
`61
`
`61
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`Petition, 35
`
`Petition, 35-36
`
`The ’608 Patent
`1. A method for providing accelerated
`loading of an operating system, comprising
`the steps of:
`maintaining a list of boot data used for
`booting a computer system;
`initializing a central processing unit of
`the computer system;
`preloading the boot data into a cache
`memory prior to completion of initialization
`of the central processing unit of the
`computer system, wherein preloading the
`boot data comprises accessing
`compressed boot data from a boot device;
`and
`servicing requests for boot data from
`the computer system using the preloaded
`boot data after completion of initialization
`of the central processing unit of the
`computer system, wherein servicing
`requests comprises accessing compressed
`boot data from the cache and
`decompressing the compressed boot data
`at a rate that increases the effective
`access rate of the cache.
`’608 Patent, Claim 1
`62
`
`62
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`Petition, 37
`
`The ’608 Patent
`1. A method for providing accelerated
`loading of an operating system, comprising
`the steps of:
`maintaining a list of boot data used for
`booting a computer system;
`initializing a central processing unit of
`the computer system;
`preloading the boot data into a cache
`memory prior to completion of initialization
`of the central processing unit of the
`computer system, wherein preloading the
`boot data comprises accessing
`compressed boot data from a boot device;
`and
`servicing requests for boot data from
`the computer system using the preloaded
`boot data after completion of initialization
`of the central processing unit of the
`computer system, wherein servicing
`requests comprises accessing compressed
`boot data from the cache and
`decompressing the compressed boot data
`at a rate that increases the effective
`access rate of the cache.
`’608 Patent, Claim 1
`63
`
`63
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`The ’608 Patent
`16. The method of claim 1,
`wherein a plurality of encoders
`are utilized to provide the
`compressed boot data.
`’608 Patent, Claim 16
`
`Petition, 60
`
`64
`
`64
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`’936 Petition, 23-24
`
`The ’936 Patent
`1. A method comprising:
`maintaining a list of boot data used for
`booting a computer system, wherein at
`least a portion of said boot data is
`compressed by a data compression engine
`to provide said at least a portion of said
`boot data in compressed form, and stored
`in compressed form on a boot device;
`initializing a central processing unit of
`said computer system;
`preloading said at least a portion of said
`boot data in compressed form from said
`boot device to a memory;
`accessing and decompressing said at
`least a portion of said boot data in said
`compressed form from said memory; and
`utilizing said decompressed at least a
`portion of said boot data to boot said
`computer system, wherein said at least a
`portion of said boot data is decompressed
`by said data compression engine.
`
`’936 Petition, 7 (Section IV.B.)
`
`’936 Patent, Claim 1
`65
`
`65
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`’936 Petition, 25
`
`The ’936 Patent
`1. A method comprising:
`maintaining a list of boot data used for
`booting a computer system, wherein at
`least a portion of said boot data is
`compressed by a data compression engine
`to provide said at least a portion of said
`boot data in compressed form, and stored
`in compressed form on a boot device;
`initializing a central processing unit of
`said computer system;
`preloading said at least a portion of said
`boot data in compressed form from said
`boot device to a memory;
`accessing and decompressing said at
`least a portion of said boot data in said
`compressed form from said memory; and
`utilizing said decompressed at least a
`portion of said boot data to boot said
`computer system, wherein said at least a
`portion of said boot data is decompressed
`by said data compression engine.
`
`’936 Petition, 26
`
`’936 Patent, Claim 1
`66
`
`66
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`The ’936 Patent
`1. A method comprising:
`maintaining a list of boot data used for
`booting a computer system, wherein at
`least a portion of said boot data is
`compressed by a data compression engine
`to provide said at least a portion of said
`boot data in compressed form, and stored
`in compressed form on a boot device;
`initializing a central processing unit of
`said computer system;
`preloading said at least a portion of said
`boot data in compressed form from said
`boot device to a memory;
`accessing and decompressing said at
`least a portion of said boot data in said
`compressed form from said memory; and
`utilizing said decompressed at least a
`portion of said boot data to boot said
`computer system, wherein said at least a
`portion of said boot data is decompressed
`by said data compression engine.
`
`’936 Petition, 29
`
`’936 Patent, Claim 1
`67
`
`67
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`’936 Petition, 30-31
`
`The ’936 Patent
`1. A method comprising:
`maintaining a list of boot data used for
`booting a computer system, wherein at
`least a portion of said boot data is
`compressed by a data compression engine
`to provide said at least a portion of said
`boot data in compressed form, and stored
`in compressed form on a boot device;
`initializing a central processing unit of
`said computer system;
`preloading said at least a portion of said
`boot data in compressed form from said
`boot device to a memory;
`accessing and decompressing said at
`least a portion of said boot data in said
`compressed form from said memory; and
`utilizing said decompressed at least a
`portion of said boot data to boot said
`computer system, wherein said at least a
`portion of said boot data is decompressed
`by said data compression engine.
`
`’936 Petition, 31
`
`’936 Patent, Claim 1
`68
`
`68
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`’936 Petition, 31-32 (citing Exhibit 1003, ¶¶125-127)
`
`The ’936 Patent
`1. A method comprising:
`maintaining a list of boot data used for
`booting a computer system, wherein at
`least a portion of said boot data is
`compressed by a data compression engine
`to provide said at least a portion of said
`boot data in compressed form, and stored
`in compressed form on a boot device;
`initializing a central processing unit of
`said computer system;
`preloading said at least a portion of said
`boot data in compressed form from said
`boot device to a memory;
`accessing and decompressing said at
`least a portion of said boot data in said
`compressed form from said memory; and
`utilizing said decompressed at least a
`portion of said boot data to boot said
`computer system, wherein said at least a
`portion of said boot data is decompressed
`by said data compression engine.
`
`’936 Patent, Claim 1
`69
`
`69
`
`
`
`Combination of Sukegawa & Dye
`
`Sukegawa in view of Dye
`
`’936 Petition, 32
`
`The ’936 Patent
`1. A met
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