Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 1 of 16
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
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`vs.
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`CROSSROADS SYSTEMS, (TEXAS), INC. §
`§
`§
`§
`§
`§
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`CHAPARRAL NETWORK
`STORAGE, INC.
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`CROSSROADS SYSTEMS, (TEXAS), INC. §
`§
`§
`§
`§
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`PATHLIGHT TECHNOLOGY, INC.
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`vs.
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`NO. A 00 CA 248 SS
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`ORDER
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`
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`BE IT REMEMBERED that on the 251h day of July 2000 the Court, in accordance with
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`Markman v. Westview Instruments, Inc., 52 F .3d 967 (Fed. Cir. 1995), aff'd, 116 S. Ct. 1384 (1996),
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`held a hearing at which the parties appeared by representation of counsel and made oral arguments
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`on their proposed claims construction. At the hearing, the parties presented a Joint Stipulation of
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`Claim Construction, indicating that the parties have agreed upon the definitions for seventeen terms
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`and/or phrases in U.S. Patent No. 5,941,972 ("the '972 patent"), and that only ten terms and/or
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`phrases in the '972 patent remain in dispute. After considering the briefs, the case file as a whole,
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`and the applicable law, the Court enters the following opinion and order.
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`I.
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`Standard for Claims Construction
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`The construction of claims, or the definition of the terms used in the claims, is a matter of
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`law for the Court. When adopting a claim construction, the Court should first consider the intrinsic
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`evidence, which includes the claims, the specification, and the prosecution history. See Vitronics
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`(cid:20)(cid:3)(cid:82)(cid:73)(cid:3)(cid:20)(cid:25)
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` CROSSROADS EXHIBIT 2004
`Oracle Corp. et al v Crossroads Systems, Inc.
` IPR2014-01177
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`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 2 of 16
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`Corp. v. Conceptronic, Inc., 90 FJd 1576, 1582 (Fed. Cir. 1996) (explaining that intrinsic evidence
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`is "the most significant source of the legally operative meaning of disputed claim language"). Not
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`surprisingly, the starting point is always "the words of the claims themselves." !d.; see also Co mark
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`Communications, Inc. v. Harris Corp., 156 FJd 1182, 1186 (Fed. Cir. 1998). The words of the
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`claims are generally given their ordinary and customary meaning, unless the patentee intended to
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`use a "special definition of the term clearly stated in the patent specification or file history."
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`Vitronics, 90 FJd at 1582. Thus, the Court must review the specification and file history to
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`determine whether the patentee intended to use any such "special" definitions. See id. The
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`specification and file history may also be consulted as general guides for claim interpretation. See
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`Comark, 156 F .3d at 1186.
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`The specification and file history, however, are not substitutes for the plain language of the
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`claims. The specification is not meant to describe the full scope of the patent - it includes only a
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`written description of the invention, sufficient to enable a person skilled in the art to make and use
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`it, as well as the invention's "best mode." See 35 U.S.C. § 112. Thus, the claims may be broader
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`than the specification, and generally should not be confined to the examples of the invention set forth
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`in the specification. See Comark, 156 FJd at 1187 ("Although the specification may aid the court
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`in interpreting the meaning of disputed claim language, particular embodiments and examples
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`appearing in the specification will not generally be read into the claims."). Indeed, the Federal
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`Circuit has repeatedly emphasized that "limitations from the specification are not to be read into the
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`claims." !d. at 1186.
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`In addition to examining the intrinsic evidence the Court may, in its discretion, receive
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`extrinsic evidence regarding the proper construction of the patent's terms. See Key Pharmaceuticals
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`-2
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`(cid:21)(cid:3)(cid:82)(cid:73)(cid:3)(cid:20)(cid:25)
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`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 3 of 16
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`v. Hereon Labs. Corp., 161 FJd 709,716 (Fed. Cir. 1998)("[T]rial courts generally can hear expert
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`testimony for background and education on the technology implicated by the presented claim
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`construction issues, and trial courts have broad discretion in this regard."). The plaintiff has
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`provided an expert affidavit and the defendant has provided excerpts from several dictionaries as
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`extrinsic evidence concerning the construction of the terms of the '972 patent.
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`II.
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`"implements access controls for storage space on the SCSI storage devices"
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`This phrase is used in claims 1, 10 and 11 of the '972 patent. The parties dispute whether
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`the phrase refers to "access controls" only for certain subsections of a divided SCSI storage device,
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`or whether it also includes limiting access to entire undivided SCSI storage devices. The plaintiff
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`argues the phrase includes both kinds of access controls; the defendants say the phrase refers only
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`to access controls for various subsections within a single divided SCSI storage device. The
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`defendants also argue the plaintiffs construction is improper because, if adopted, it will result in the
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`'972 patent being invalidated by prior art.
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`The plaintiff proposes the following definition: "provides controls which limit a computer's
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`access to a specific subset of storage devices or sections of a single storage device." See Plaintiffs
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`Brief, at 20. The defendants propose the phrase should be defined as "partitions the storage space
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`on each one of the SCSI storage devices and defines the accessibility of each resulting partition."
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`See Defendants' Brief, Ex. 2. The Court agrees with the plaintiff.
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`The intrinsic evidence of the '972 patent shows the plaintiffs invention is intended to restrict
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`access both to subsections of a SCSI storage device, as well as to entire, undivided SCSI devices.
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`First, the plain language of this phrase refers only to "storage space" and does not limit the space
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`(cid:22)(cid:3)(cid:82)(cid:73)(cid:3)(cid:20)(cid:25)
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`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 4 of 16
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`only to subsections of a divided SCSI storage device. Second, Figure 3 of the '972 patent supports
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`a broad reading of this phrase. Figure 3 shows three SCSI storage devices, two of which are
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`undivided (60 and 64). The third device (62) is divided into four subsections of storage space. From
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`the simple labeling on Figure 3, it is clear that the entire, undivided storage device (64) is meant to
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`be accessed only by a single workstation (computer E). Thus, Figure 3 expressly shows that the
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`plaintiffs invention contemplates using "access controls" for an entire, undivided storage device as
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`well as for the divided subsections within a single storage device. 1 Third, the language of the
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`specification expressly describes limiting access to an entire, undivided SCSI storage device.
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`Specifically, in referring to Figure 3, the specification states "storage device 64 can be allocated as
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`storage for the remaining workstation 58 (workstation E)." See '972 Patent, at 4:20-4:21. At the
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`hearing, the defendants' counsel argued that, simply because Figure 3 describes this feature does not
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`mean the feature was intended to be part of the claimed invention. The Court soundly rejects this
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`argument. Figure 3 is meant to be an example of how the plaintiffs claimed invention can be
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`implemented, and the specification clearly describes this figure as illustrating one implementation
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`of the claimed invention. Adopting the defendants' argument would ignore a fundamental principle
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`of claims construction, oft repeated in the defendants' brief and oral arguments, that the specification
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`is "the single best guide to the meaning of a disputed term." See Vitro nics, 90 F .3d at 1582. Finally,
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`the defendants correctly point out that the specification also refers to the single, undivided storage
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`device (64) as a "partition (i.e., logical storage definition)." See '972 Patent, at 4:44-4:47. Rather
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`than compel the defendants' proposed construction, however, this language supports the plaintiffs
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`1 Figure 3 also discloses- and the defendants do not dispute- that the plaintiffs invention
`contemplates limiting access to various subsections of the divided SCSI storage device (62).
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`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 5 of 16
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`argument at the hearing that a discrete unit of storage- whether an entire SCSI storage device or a
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`subsection within that device- can be referred to as a "partition.''2
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`The defendants also argue that, even if the intrinsic evidence supports the plaintiffs proposed
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`definition, this definition is nonetheless improper because it would cause the '972 patent to read
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`directly upon prior art (and therefore be invalid). It is true that "claims should be read in a way that
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`avoids ensnaring prior art if it is possible to do so." Harris Corp. v. IXYS Corp., 114 FJd 1149,
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`1153 (Fed. Cir. 1997). However, the defendants have not shown that the prior art at issue- the Lui
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`patent- would be "ensnared" by adopting the plaintiffs definition. Importantly, the Lui patent was
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`part of the prior art expressly considered by the patent examiner before granting the '972 patent. The
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`patent examiner apparently did not use the Lui patent to reject a single claim in the '972 patent. The
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`patent examiner also did not issue an Office Action requiring the plaintiff to distinguish its invention
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`from the Lui patent on access control (or any other) grounds. Although the Patent Office is not the
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`model of efficiency or thoroughness, its failure to cite the Lui patent as potentially invalidating prior
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`art creates a strong presumption that the Lui patent does not read upon the plaintiffs claimed
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`invention. In addition, it does not appear to the Court that the Lui patent reads upon the '972
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`claimed invention. While the Lui patent does disclose a system of Fibre Channel computers and
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`SCSI storage devices, see Defendants' Brief, Ex. 6, at 2:53 ~ 2:65, the similarities end there. The
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`Lui patent concerns an invention of"bypass circuits" used to "prevent the failure of any device" in
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`the system. See id., at Abstract. The invention of the Lui patent is not concerned with the swift
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`transfer of information across a router, and thus does not disclose techniques for mapping,
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`2 The Court express! y notes, however, that it is not defining the term "partition" in this order,
`as that term is not used in the '972 claim language.
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`(cid:24)(cid:3)(cid:82)(cid:73)(cid:3)(cid:20)(cid:25)
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`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 6 of 16
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`implementing access controls, or a memory buffer.3 At the hearing, the defendants' counsel
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`suggested that Figure 2 of the Lui patent discloses the claimed invention of the '972 patent.
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`However, Figure 2 of the Lui patent is not a part of the Lui invention; rather it is an illustration of
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`a "conventional" network system that the Lui invention allegedly improves upon. See id. at 3:66.
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`The Court rejects the defendants' argument that "conventional" network systems also read directly
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`upon the '972 claimed invention. The patent examiner may have let one piece of prior art slip by;
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`he or she would not have missed a "conventional" network system directly applicable to the
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`plaintiffs claimed invention.
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`In sum, the Court will adopt the plaintiffs proposed definition and construe the phrase
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`"implements access controls" in the claims of the '972 patent to mean "provides controls which limit
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`a computer's access to a specific subset of storage devices or sections of a single storage device."
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`III.
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`"allocation of subsets of storage space to associated Fibre Channel devices, wherein
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`each subset is only accessible by the associated Fibre Chanel device"
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`The dispute here is essentially the same as in the preceding section. This phrase is used in
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`claims 2, 8 and 12 of the '972 patent. As it did with the "implements access controls ... "phrase,
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`the plaintiff argues the "allocation ... "phrase means that specific Fibre Channel devices can be ·
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`allocated storage space on subsections of a single SCSI storage device and on entire, undivided SCSI
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`storage devices. The defendants stick to their general argument on this issue, and contend the phrase
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`3 The defendants argue these features are "implicitly" found in the Lui specification and in
`any event were disclosed in other prior art. See Defendants' Brief, at 12 and n.l. The Court is not
`persuaded that these features are "implicitly" disclosed by the Lui patent, and the other prior art
`briefly referenced by the defendants makes no mention of combining that prior art with the invention
`of the Lui patent, or vice· versa.
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`(cid:25)(cid:3)(cid:82)(cid:73)(cid:3)(cid:20)(cid:25)
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`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 7 of 16
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`means storage space can only be allocated on subsections of a single divided SCSI storage device.
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`Both parties agree this storage space, however it is defined, can only be accessed by the specified
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`Fibre Channel device(s).
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`The plaintiffs proposed definition is "subsets of storage space are allocated to specific Fibre
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`Channel devices." See Plaintiffs Brief, at 26. The defendants say the phrase should be defined to
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`mean "one or more partitions that are only accessible by a single Fibre Channel device." See
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`Defendants' Brief, Ex. 2. For the reasons discussed in the preceding section, the Court adopts the
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`plaintiffs proposed construction.
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`IV.
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`"supervisor unit"
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`This term is used in claims 1, 2 and 10 of the '972 patent. The plaintiff contends this term
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`should be defined as "a microprocessor programmed to process data in a buffer in order to map
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`between Fibre Channel devices and SCSI devices and which implements access controls." See
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`Plaintiffs Brief, at 25. The defendants argue the term should be defined as "an Intel 80960RP
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`processor" with several specific features. See Defendants' Brief, Ex. 2.
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`The defendants argue their construction is mandated by the means-plus-function analysis of
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`§ 112( 6) of the Patent Act, because the claims of the '972 patent do not adequately describe the
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`"supervisor unit" to be used. See Defendants' Brief, at 15-17. The plaintiff argues that§ 112(6)
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`does not apply because the term "means" is not used with the term "supervisor unit" and because
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`the term "supervisor unit" is adequately described by other claim language in the '972 patent. See
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`Plaintiffs Markman Exhibits, at 35-39.
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`Section 112(6) of the Patent Act provides that when a claim refers to the "means for" a
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`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 8 of 16
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`specific act, but fails to adequately describe these means, the means then must be defined by
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`reference to the specification. See 35 U.S. C. § 112(6).4 If the claim language at issue does not
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`include the term "means," there is a presumption that the § 112( 6) means-plus-function analysis does
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`not apply. See Al-Site Corp. v. VSI Int'l, Inc., 174 FJd 1308, 1318 (Fed. Cir. 1999) ("[W]hen an
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`element of a claim does not use the term 'means,' treatment as a means-plus-function claim element
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`is generally not appropriate."). To overcome this presumption, the party seeking to apply§ 112(6)
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`must show the claim language at issue is purely functional and that other claim language does not
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`adequately describe the disputed term. See id. ("[W]hen it is apparent that the element invokes
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`purely functional terms, without the additional recital of specific structure or material for performing
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`that function, the claim element may be a means-plus-function element despite the lack of express
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`means-plus- function language."). From a review ofthe claim language as a whole, the Court agrees
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`with the plaintiff that the term "supervisor unit" is not purely functional, but refers instead to a
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`device that can perform the tasks specifically listed in the claim language of the '972 patent.
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`Specifically, claims 1, 2 and 10 of the '972 patent describe a "supervisor unit" that can: (1) maintain
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`and map the configuration of networked Fibre Channel and SCSI storage devices; (2) include in this
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`configuration an allocation of specific storage space to specific Fibre Channel devices; (3)
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`implement access controls for the SCSI storage devices; and ( 4) process data in the storage router's
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`buffer to allow an exchange between the Fibre Channel and SCSI storage devices. See '972 Patent,
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`4 Section 112(6) reads as follows: "An element in a claim for a combination may be
`expressed as a means or step for performing a specified function without the recital of structure,
`material, or acts in support thereof, and such claim shall be construed to cover the corresponding
`structure, material, or acts described in the specification and equivalents thereof." 35 U.S.C. §
`112(6).
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`(cid:27)(cid:3)(cid:82)(cid:73)(cid:3)(cid:20)(cid:25)
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`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 9 of 16
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`at Claims 1, 2 and 10. These are the same tasks described in the plaintiffs proposed definition. In
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`addition, the specification expressly defines the "supervisor unit" as "a microprocessor" (a computer
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`chip) and specifically as "a microprocessor for controlling operation of storage router 56 and to
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`handle mapping and security access for requests between Fibre Channel 52 and SCSI bus 54." See
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`id. at 5:7- 5:10. However, neither the specification (nor the claim language) limits the '972 patent
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`to the specific Intel computer chip referenced by the defendants. Although the defendants correctly
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`point out that the Intel80960 chip is the only computer chip expressly named in the '972 patent and
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`the specification describes many features this chip, the defendants fail to note that the Intel 80960
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`chip is listed as only "one implementation" of the claimed invention's microprocessor. See '972
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`Patent, at 5:63. The defendants are attempting exactly what the Federal Circuit prohibits
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`to limit
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`the claims to the preferred embodiment and examples of the specification. "This court has cautioned
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`against limiting the claimed invention to preferred embodiments or specific examples in the
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`specification." Comark, 156 FJd at 1186 (quoting Texas Instruments, Inc. v. United States Int'l
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`Trade Comm 'n, 805 F.2d 1558, 1563 (Fed. Cir. 1988)). The Court will not use an example of"one
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`implementation" in the specification to limit the plain language of the claims. Accordingly, the
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`Court adopts the plaintiffs definition of"supervisor unit" and will construe that term as used in the
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`claims of the '972 patent to mean "a microprocessor programmed to process data in a buffer in order
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`to map between Fibre Channel devices and SCSI devices and which implements access controls."
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`V.
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`"SCSI storage devices"
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`This term is used in claims 1, 4, 7, 9-11 and 14 of the '972 patent. The plaintiff argues that
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`this term essentially needs no further definition because the term SCSI is so well-known in the
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`industry, but proposes that the term can be further defined as "any storage device including, for
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`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 10 of 16
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`example, a tape drive, CD-ROM drive, or a hard disk drive that understands the SCSI protocol and
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`can communicate using the SCSI protocol." See Plaintiffs Brief, at 18. The defendants argue the
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`term should be defined as "any storage device that uses a SCSI standard and has a unique
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`BUS:TARGET:LUN address." See Defendants' Brief, Ex. 2.
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`The Court agrees with the plaintiff. Essentially, the defendants contend their narrow
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`definition should be used because it "comports with '972 specification" and its discussion of SCSI
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`storage devices. See Defendant's Brief, at 14. However, the specification language referred to by
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`the defendants is only one example of how the SCSI storage device addressing scheme "can" be
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`represented. See '972 Patent, at 7:39. Again, the defendants are impermissibly trying to limit the
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`claim language to an example given in the specification. See Comark, 156 F.3d at 1186-87. For the
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`sake of extra clarity, the Court will adopt the plaintiffs proposed definition for this term.
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`VI.
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`"process data in the buffer"
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`This phrase is used in claims 1 and 10 of the '972 patent. The plaintiff argues the phrase is
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`adequately defined on its own and by the surrounding claim language. The defendants contend the
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`phrase should be defined as "to manipulate data in the buffer in a manner to (a) achieve mapping
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`between Fibre Channel and SCSI devices, and (b) apply access controls and routing functions." See
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`Defendants' Brief, Ex. 2.
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`The plain language of claims 1 and 10 disclose that the supervisor unit (the microprocessor)
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`processes data in the buffer "to interface between the Fibre Channel controller and the SCSI
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`controller to allow access from Fibre Channel initiator devices to SCSI storage devices using the
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`native low level, block protocol in accordance with the configuration." See '972 Patent, at Claims
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`1 and 10. This language adequately describes what it means to "process data in the buffer" for these
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`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 11 of 16
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`claims. Simply because the specification may use slightly different language to describe this
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`"processing," see id. at 5:18 - 5:20, does not entitle the defendants to adopt the specification
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`language over the plain language of the claims. The Court will not further define this phrase.
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`VII. "storage router"
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`This term is used in claims 1-7 and 10 of the '972 patent. The plaintiff argues the term needs
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`no further definition for claims 1-6, and for claim 7 it should be defined as "a device which provides
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`virtual local storage, maps, implements access controls, and allows access using native low level
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`block protocols." See Plaintiffs Brief, at 27. The defendants contend the term should mean "a
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`bridge device that connects a Fibre Channel link directly to a SCSI bus and enables the exchange of
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`SCSI command set information between application clients on SCSI bus devices and the Fibre
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`Channel links." See Defendants' Brief, Ex. 2.
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`The defendants do not make any argument for their proposed definition in their brief, and did
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`not discuss the term at the July 25 hearing. In their notebook of exhibits presented at the hearing,
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`the defendants include one page which supports their definition with a quote from the specification.
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`See Defendants' Markman Exhibits, "Markman Presentation" Tab, at 22. This argument is
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`disingenuous. The specification language quoted by the defendants is immediately followed by
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`several sentences further defining "storage router." Indeed, the next sentence begins "Further, the
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`storage router applies access controls .... " See '972 Patent, at 5:30. The defendants' attempt to
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`limit the term "storage router" to one of several descriptive sentences in the specification is not well(cid:173)
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`taken. In addition, the Court finds the term "storage router," as used in all claims of the '972 patent,
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`is adequately described by the additional language of the claims, which discloses in detail the various
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`functions and/or qualities of the storage router. The Court will not further define this term.
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`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 12 of 16
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`VIII. "map"
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`This term is used in claims 1, 7, 10 and 11 of the '972 patent. ·The plaintiff contends the term
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`means "to create a path from a device on one side of the storage router to a device on the other side
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`of the router, i.e. from a Fibre Channel device to a SCSI device (or vice-versa). A 'map' contains
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`a representation of devices on each side of the storage router, so that when a device on one side of
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`the storage router wants to communicate to a device on the other side of the storage router, the
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`storage router can connect the devices." See Plaintiffs Brief, at 22. The defendants argue the term
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`means "to translate addresses." See Defendants' Brief, Ex. 2.
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`In support of their definition, the defendants point only to a dictionary definition of"map."
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`See Defendants' Brief, at 13 and Ex. 4. The plaintiff, on the other hand, cites to specific portions
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`of the specification that support its definitions of map (both as a verb and a noun) as used in the
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`claims of the '972 patent. See Plaintiffs Brief, at 22 (citing '972 Patent, at 1:66-2:5 and 6:65- 7:6).
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`Because intrinsic evidence is far more salient than a dictionary definition, and because the Court
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`agrees that the specification language cited by the plaintiff supports its construction of the term
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`"map," the Court will adopt the plaintiffs proposed definition of this term.
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`IX.
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`"Fibre Channel protocol unit" and "SCSI protocol unit"
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`These terms are used in claims 5 and 6 of the '972 patent. The plaintiff contends these
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`phrases should be defined as "a portion of the Fibre Channel controller which connects to the Fibre
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`Channel transport medium" and "a portion of the SCSI controller which interfaces to the SCSI bus."
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`See Plaintiffs Brief, at 27. The defendants say the terms mean "block and equivalents thereof that
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`connects to the Fibre Channel transport medium" and "block and equivalents thereof that connects
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`to the SCSI bus transport medium." See Defendants' Brief, Ex. 2.
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`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 13 of 16
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`The defendants argue the means-plus-function analysis of§ 112( 6) should apply here because
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`the terms are well-known and are not defined in two dictionaries cited by the defendants. See
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`Defendants' Brief, at 7-8, 14-15, Ex. 4 and Ex. 5. However, the defendants do not indicate how the
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`term should be defined in reference to the specification, and in fact contend "the '972 specification
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`fails to reveal any structure corresponding to the claimed function." See id. at 8 and 15. The
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`defendants then propose the word "block" should be used to describe these terms because the
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`"protocol units" are "simply depicted as a block within the diagram of Figure 5" of the '972 patent.
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`See id. This reasoning is wholly linpersuasive. Simply because a figure in the patent physically
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`depicts the protocol units in a block-like shape, it does not follow that the units should be defined
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`as "blocks or equivalents thereof." Under that reasoning, the SCSI storage devices, which are
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`physically depicted as cylinders in the '972 patent, could be defined simply as "cylinders, oil drums
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`or monkey barrels, or equivalents thereof." As the plaintiff correctly points out, the language of
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`claims 5 and 6 plainly states that the "protocol units" for both devices are part of the "controllers"
`
`for the devices, and are intended to "connect" the devices to various "transport media" (i.e., to
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`various cables). See '972 Patent, at Claims 5 and 6. Accordingly, the Court adopts the plaintiffs
`
`definitions for these terms, and will construe the terms to mean "a portion of the Fibre Channel
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`controller which connects to the Fibre Channel transport medium" and "a portion of the SCSI
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`controller which interfaces to the SCSI bus."
`
`X.
`
`"interface"
`
`In their Joint Stipulation of Claim Construction, the parties claim the meaning of the term
`
`"interface" is in dispute. However, this phrase is not discussed in any of the parties' briefs, and
`
`neither side presented an argument at the July 25 hearing as to why the term is disputed. This term
`
`- 13-
`
`(cid:20)(cid:22)(cid:3)(cid:82)(cid:73)(cid:3)(cid:20)(cid:25)
`
`

`

`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 14 of 16
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`has a standard and ordinary meaning- even to a federal judge- and the Court will not further define
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`it.
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`XI. Undisputed Terms
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`Finally, in their Joint Stipulation of Claim Construction, the parties have stipulated to the
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`construction of 17 other terms in the '972 patent. The Court will therefore adopt these stipulated
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`constructions, solely for the purpose of this lawsuit.
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`Accordingly, the Court enters the following order:
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`IT IS ORDERED that the attached construction of the patent claims will be incorporated into
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`any jury instructions given in this cause and will be applied by the Court in ruling on the issues
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`raised in summary judgment.
`
`tt
`SIGNED on this~ day of July 2000.
`
`~-UNrtEDST ATESITRICi JUDGE
`
`- 14-
`
`(cid:20)(cid:23)(cid:3)(cid:82)(cid:73)(cid:3)(cid:20)(cid:25)
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`

`

`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 15 of 16
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`CONSTRUCTION OF CLAIMS
`U.S. PATENT NO. 5,941,972
`
`Disputed Terms
`
`The phrase "implements access controls for storage space on the SCSI storage devices" means
`provides controls which limit a computer's access to a specific subset of storage devices or sections
`of a single storage device.
`
`The phrase "allocation of subsets of storage space to associated Fibre Channel devices, wherein each
`subset is only accessible by the associated Fibre Chanel device" means subsets of storage space are
`allocated to specific Fibre Channel devices.
`
`A "supervisor unit" is a microprocessor programmed to process data in a buffer in order to map
`between Fibre Channel devices and SCSI devices and which implements access controls.
`
`A "SCSI storage device" is any storage device including, for example, a tape drive, CD-ROM drive,
`or a hard disk drive that understands the SCSI protocol and can communicate using the SCSI
`protocol.
`
`The term "map" means to create a path from a device on one side of the storage router to a device
`on the other side of the router, i.e. from a Fibre Channel device to a SCSI device (or vice-versa). A
`"map" contains a representation of devices on each side of the storage router, so that when a device
`on one side of the storage router wants to communicate with a device on the other side of the storage
`router, the storage router can connect the devices.
`
`A "Fibre Channel protocol unit" is a portion of the Fibre Channel controller which connects to the
`Fibre Channel transport medium.
`
`A "SCSI protocol unit" is a portion of the SCSI controller which interfaces to the SCSI bus.
`
`Stipulated I Undisputed Terms
`
`A "buffer" is a memory device that is utilized to temporarily hold data.
`
`A "direct memory access (DMA) interface" is a device that acts under little or no microprocessor
`control to access memory for data transfer.
`
`A "Fibre Channel" is a known high-speed serial interconnect, the structure and operation of which
`is described, for example, in Fibre Channel Physical and Signaling Interface (FC-PH), ANSI X3 .230
`Fibre Channel Arbitrated Loop (FC-AL), and ANSI X3.272 Fibre Channel Private Loop Direct
`Attach (FC-PLDA).
`
`- 15 -
`
`(cid:20)(cid:24)(cid:3)(cid:82)(cid:73)(cid:3)(cid:20)(cid:25)
`
`

`

`Case 1:00-cv-00217-SS Document 27 Filed 07/27/00 Page 16 of 16
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`A "Fibre Channel controller" is a device that interfaces with a Fibre Channel transport medium.
`
`A "Fibre Channel device" is any device, such as a computer, that understands Fibre Channel protocol
`and can communicate using Fibre Channel protocol.
`
`"Fibre Channel protocol" is a set of rules that apply to Fibre Channel.
`
`A "Fibre Channel transport medium" is a serial optical or electrical communications link that
`connects devices using Fibre Channel protocol.
`
`A "first-in-first-out queue" is a multi-element data structure from which elements can be removed
`only in the same order in which they were inserted; that is, it follows a first in, first out (FIFO)
`constraint.
`
`A "hard disk drive" is a well known magnetic storage media, and includes a SCSI hard disk drive.
`
`An "initiator device" is a device that issues requests for data or storage.
`
`"Maintain(ing) a configuration" means keep(ing) a modifiable setting of information.
`
`A "native low level, block protocol" is a set of rules or standards that enable computers to exchange
`information and do not involve the overhead of high level protocols and file systems typically
`required by network servers.
`
`A "SCSI" (Small Computer System Interface) is a high speed parallel interface that may be used to
`connect components of a computer system.
`
`A "SCSI bus transport medium" is a cable consisting of a group of parallel wires (normally 68) that
`forms a communications path between a SCSI st