`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`CROSSROADS SYSTEMS, INC.,
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`Plaintiff,
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`v.
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`NETAPP, INC.,
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`Defendant.
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`CIVIL ACTION NO. 1:14-cv-00149
`
`JURY DEMANDED
`
`
`
`
` §
` §
` §
` §
` §
` §
` §
` §
` §
`
`PLAINTIFF CROSSROADS SYSTEMS, INC.’S
`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`THE PARTIES
`
`1.
`
`Pursuant to Federal Rule of Civil Procedure 15(a)(1)(B), Plaintiff Crossroads
`
`Systems, Inc. (“Crossroads”) hereby submits its First Amended Complaint for Patent
`
`Infringement as a matter of course within 21 days after service of NetApp, Inc.’s Answer and
`
`Affirmative Defenses (Dkt. No. 21).
`
`2.
`
`Crossroads is a corporation incorporated under the laws of the State of Delaware
`
`and has its principal place of business at 11000 North MoPac Expressway, Austin, Texas 78759.
`
`3.
`
`Upon information and belief, Defendant NetApp, Inc. (“Defendant” or “NetApp”)
`
`is a California corporation with a principal place of business of 495 East Java Drive, Sunnyvale,
`
`California 94089.
`
`JURISDICTION AND VENUE
`
`3.
`
`This action arises under the laws of the United States, more specifically under 35
`
`U.S.C. § 100, et seq. Subject matter jurisdiction is proper in this Court pursuant to 28 U.S.C. §§
`
`1331 and 1338.
`
`1
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 1
`
`
`
`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 2 of 12
`
`4.
`
`Personal jurisdiction and venue are proper in this district under 28 U.S.C. §§ 1391
`
`and 1400(b). Upon information and belief, Defendant NetApp has established minimum
`
`contacts with this forum such that the exercise of jurisdiction over Defendant would not offend
`
`traditional notions of fair play and substantial justice.
`
`5.
`
`This Court has personal jurisdiction over NetApp. Upon information and belief,
`
`NetApp regularly conducts business in the State of Texas and in this judicial district and is
`
`subject to the jurisdiction of this Court. Upon information and belief, NetApp has been doing
`
`business in Texas and this judicial district by distributing, marketing, selling and/or offering for
`
`sale its products, including, but not limited to, products that practice the subject matter claimed
`
`in United States Patent Nos. 6,425,035 (“the ’035 Patent”), 7,934,041 (“the ’041 Patent”),
`
`7,051,147 (“the ’147 Patent”), and 7,987,311 (“the ’311 Patent) (collectively “the Patents-In-
`
`Suit”), and/or regularly doing or soliciting business and/or engaging in other persistent courses of
`
`conduct in and/or directed to Texas and this judicial district.
`
`COUNT 1: INFRINGEMENT OF U.S. PATENT NO. 6,425,035
`
`6.
`
`Crossroads incorporates by reference the allegations set forth in the preceding
`
`paragraphs.
`
`7.
`
`On July 23, 2002, the ’035 Patent was duly and legally issued. A true and correct
`
`copy of the ’035 Patent is attached hereto as Exhibit A. Crossroads is the assignee and the owner
`
`of all right, title, and interest in and to the ’035 Patent. The ’035 Patent is entitled to a
`
`presumption of validity.
`
`8.
`
`On information and belief, Defendant has directly infringed the ’035 Patent. On
`
`information and belief, Defendant continues to directly infringe the ’035 Patent.
`
`2
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 2
`
`
`
`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 3 of 12
`
`9.
`
`Specifically, on information and belief, Defendant has directly infringed the ’035
`
`Patent by making, using, offering for sale, selling and/or importing into the United States certain
`
`of its products including at least the following: NetApp E5400 Series Storage Arrays (including
`
`but not limited to the E5460, E5424, and E5412), E5500 Series Storage Arrays with FC, iSCSI
`
`and InfiniBand interfaces (including but not limited to the E5560, E5524, and E5512), E2700
`
`Storage Systems with FC and iSCSI interfaces (including but not limited to the E2760, E2724,
`
`E2712), E2600 Storage Systems with FC and iSCSI interfaces (including but not limited to the
`
`E2600-60, E2600-24, E2600-12), EF550 Flash Arrays with FC, iSCSI and InfiniBand Host
`
`interfaces, EF540 Flash Arrays, FAS2200 Series (including but not limited to FAS2220 and
`
`FAS2240), FAS3200 Series (including but not limited to FAS3270, FAS3250, FAS3240,
`
`FAS3220, FAS3210), FAS6200 Series (including but not limited to FAS6210, FAS6220,
`
`FAS6240, FAS6250, FAS6280, FAS6290), FAS8000 Series (including but not limited to
`
`FAS8060, FAS8040, FAS8020), V3200 Series Storage Controllers (including but not limited to
`
`V3220, V3240, V3250, V3270), V6200 Series Storage Controllers (including but not limited to
`
`V6210, V6220, V6240, V6250, V6280, V6290) and the Data ONTAP Operating System
`
`(including but not limited to Data ONTAP 8.2), hereinafter “the Accused Products”.
`
`10.
`
`Further, on information and belief, Defendant has been and now is indirectly
`
`infringing by way of inducing infringement of the ’035 Patent with knowledge of the ’035 Patent
`
`by making, offering for sale, selling, importing into the United States, marketing, supporting,
`
`providing product instruction and/or advertising certain of its products, including the Accused
`
`Products, and Defendant knew that its actions were inducing end users to infringe the ‘035
`
`Patent.
`
`3
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 3
`
`
`
`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 4 of 12
`
`11.
`
`Further, on information and belief, Defendant has been and now is indirectly
`
`infringing by way of contributing to the infringement by end users of the ’035 Patent by selling,
`
`offering to sell and/or importing into the United States components, including the Accused
`
`Products, knowing the components to be especially made or especially adapted for use in the
`
`infringement of the ’035 Patent. Such components are not a staple article or commodity of
`
`commerce suitable for substantial non-infringing uses.
`
`12.
`
`Defendant has been on constructive and/or actual notice of the ’035 Patent since
`
`at least as early as October 2002, and Defendant has not ceased its infringing activities. The
`
`infringement of the ’035 Patent by Defendant has been and continues to be willful and deliberate.
`
`13.
`
`Crossroads has been irreparably harmed by Defendant’s acts of infringement of
`
`the ’035 Patent, and will continue to be harmed unless and until Defendant’s acts of infringement
`
`are enjoined and restrained by order of this Court.
`
`14.
`
`As a result of the acts of infringement of the ’035 Patent by Defendant,
`
`Crossroads has suffered and will continue to suffer damages in an amount to be proven at trial.
`
`COUNT 2: INFRINGEMENT OF U.S. PATENT NO. 7,934,041
`
`15.
`
`Crossroads incorporates by reference the allegations set forth in the preceding
`
`paragraphs.
`
`16.
`
`On April 26, 2011, the ’041 Patent was duly and legally issued. A true and
`
`correct copy of the ’041 Patent is attached hereto as Exhibit B. Crossroads is the assignee and
`
`the owner of all right, title, and interest in and to the ’041 Patent. The ’041 Patent is entitled to a
`
`presumption of validity.
`
`17.
`
`On information and belief, Defendant has directly infringed the ’041 Patent. On
`
`information and belief, Defendant continues to directly infringe the ’041 Patent.
`
`4
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 4
`
`
`
`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 5 of 12
`
`18.
`
`Specifically, on information and belief, Defendant has directly infringed the ’041
`
`Patent by making, using, offering for sale, selling and/or importing into the United States certain
`
`of its products including at least the Accused Products.
`
`19.
`
`Further, upon information and belief, Defendant has been and now is indirectly
`
`infringing by way of inducing infringement of the ’041 Patent with knowledge of the ’041 Patent
`
`by making, offering for sale, selling, importing into the United States, marketing, supporting,
`
`providing product instruction and/or advertising certain of its products, including the Accused
`
`Products, and Defendant knew that its actions were inducing end users to infringe the ’041
`
`Patent.
`
`20.
`
`Further, upon information and belief, Defendant has been and now is indirectly
`
`infringing by way of contributing to the infringement by end users of the ’041 Patent by selling,
`
`offering to sell and/or importing into the United States components, including the Accused
`
`Products, knowing the components to be especially made or especially adapted for use in the
`
`infringement of the ’041 Patent. Such components are not a staple article or commodity of
`
`commerce suitable for substantial non-infringing uses.
`
`21.
`
`Defendant has been on constructive and/or actual notice of the ’041 Patent since
`
`at least as early as May 2011, and Defendant has not ceased its infringing activities. The
`
`infringement of the ’041 Patent by Defendant has been and continues to be willful and deliberate.
`
`22.
`
`Crossroads has been irreparably harmed by Defendant’s acts of infringement of
`
`the ’041 Patent, and will continue to be harmed unless and until Defendant’s acts of infringement
`
`are enjoined and restrained by order of this Court.
`
`23.
`
`As a result of the acts of infringement of the ’041 Patent by Defendant,
`
`Crossroads has suffered and will continue to suffer damages in an amount to be proven at trial.
`
`5
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 5
`
`
`
`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 6 of 12
`
`COUNT 3: INFRINGEMENT OF U.S. PATENT NO. 7,051,147
`
`24.
`
`Crossroads incorporates by reference the allegations set forth in the preceding
`
`paragraphs.
`
`25.
`
`On May 23, 2006, the ’147 Patent was duly and legally issued. A true and correct
`
`copy of the ’147 Patent is attached hereto as Exhibit C. Crossroads is the assignee and the owner
`
`of all right, title, and interest in and to the ’147 Patent. The ’147 Patent is entitled to a
`
`presumption of validity.
`
`26.
`
`On information and belief, Defendant has directly infringed the ’147 Patent. On
`
`information and belief, Defendant continues to directly infringe the ’147 Patent.
`
`27.
`
`Specifically, on information and belief, Defendant has directly infringed the ’147
`
`Patent by making, using, offering for sale, selling and/or importing into the United States certain
`
`of its products including at least the V3200 Series Storage Controllers (including but not limited
`
`to V3220, V3240, V3250, V3270) and V6200 Series Storage Controllers (including but not
`
`limited to V6210, V6220, V6240, V6250, V6280 and V6290) and the Data ONTAP operating
`
`system, hereinafter “the Accused Fibre-to-Fibre Products”.
`
`28.
`
`Further, upon information and belief, Defendant has been and now is indirectly
`
`infringing by way of inducing infringement of the ’147 Patent with knowledge of the ’147 Patent
`
`by making, offering for sale, selling, importing into the United States, marketing, supporting,
`
`providing product instruction and/or advertising certain of its products, including the Accused
`
`Fibre-to-Fibre Products, and Defendant knew that its actions were inducing end users to infringe
`
`the ’147 Patent.
`
`29.
`
`Further, upon information and belief, Defendant has been and now is indirectly
`
`infringing by way of contributing to the infringement by end users of the ’147 Patent by selling,
`
`6
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 6
`
`
`
`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 7 of 12
`
`offering to sell and/or importing into the United States components, including the Accused Fibre-
`
`to-Fibre Products, knowing the components to be especially made or especially adapted for use
`
`in the infringement of the ’147 Patent. Such components are not a staple article or commodity of
`
`commerce suitable for substantial non-infringing uses.
`
`30.
`
`Defendant has been on constructive and/or actual notice of the ’147 Patent since
`
`at least as early as August 2006, and Defendant has not ceased its infringing activities. The
`
`infringement of the ’147 Patent by Defendant has been and continues to be willful and deliberate.
`
`31.
`
`Crossroads has been irreparably harmed by Defendant’s acts of infringement of
`
`the ’147 Patent, and will continue to be harmed unless and until Defendant’s acts of infringement
`
`are enjoined and restrained by order of this Court.
`
`32.
`
`As a result of the acts of infringement of the ’147 Patent by Defendant,
`
`Crossroads has suffered and will continue to suffer damages in an amount to be proven at trial.
`
`COUNT 4: INFRINGEMENT OF U.S. PATENT NO. 7,987,311
`
`33.
`
`Crossroads incorporates by reference the allegations set forth in the preceding
`
`paragraphs.
`
`34.
`
`On July 26, 2011, the ’311 Patent was duly and legally issued. A true and correct
`
`copy of the ’311 Patent is attached hereto as Exhibit D. Crossroads is the assignee and the owner
`
`of all right, title, and interest in and to the ’311 Patent. The ’311 Patent is entitled to a
`
`presumption of validity.
`
`35.
`
`On information and belief, Defendant has directly infringed the ’311 Patent. On
`
`information and belief, Defendant continues to directly infringe the ’311 Patent.
`
`7
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 7
`
`
`
`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 8 of 12
`
`36.
`
`Specifically, on information and belief, Defendant has directly infringed the ’311
`
`Patent by making, using, offering for sale, selling and/or importing into the United States certain
`
`of its products including at least the Accused Products.
`
`37.
`
`Further, on information and belief, Defendant has been and now is indirectly
`
`infringing by way of inducing infringement of the ’311 Patent with knowledge of the ’311 Patent
`
`by making, offering for sale, selling, importing into the United States, marketing, supporting,
`
`providing product instruction and/or advertising certain of its products, including the Accused
`
`Products, and Defendant knew that its actions were inducing end users to infringe the ’311
`
`Patent.
`
`38.
`
`Further, on information and belief, Defendant has been and now is indirectly
`
`infringing by way of contributing to the infringement by end users of the ’311 Patent by selling,
`
`offering to sell and/or importing into the United States components, including the Accused
`
`Products, knowing the components to be especially made or especially adapted for use in the
`
`infringement of the ’311 Patent. Such components are not a staple article or commodity of
`
`commerce suitable for substantial non-infringing uses.
`
`39.
`
`On information and belief, Defendant has been on constructive and/or actual
`
`notice of the ’311 Patent. Thus, the infringement of the ’311 Patent by Defendant has been and
`
`continues to be willful and deliberate.
`
`40.
`
`Crossroads has been irreparably harmed by Defendant’s acts of infringement of
`
`the ’311 Patent, and will continue to be harmed unless and until Defendant’s acts of infringement
`
`are enjoined and restrained by order of this Court.
`
`41.
`
`As a result of the acts of infringement of the ’311 Patent by Defendant,
`
`Crossroads has suffered and will continue to suffer damages in an amount to be proven at trial.
`
`8
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 8
`
`
`
`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 9 of 12
`
`DEMAND FOR JURY TRIAL
`
`Crossroads hereby demands a trial by jury on all issues.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Crossroads requests this Court enter judgment as follows:
`
`A.
`
`B.
`
`C.
`
`That Defendant has infringed the ’035 Patent;
`
`That such infringement of the ’035 Patent by Defendant has been willful;
`
`That Defendant accounts for and pays to Crossroads all damages caused
`
`by the infringement of the ’035 Patent;
`
`D.
`
`That Crossroads receive enhanced damages from Defendant in the form of
`
`treble damages, pursuant to 35 U.S.C. § 284 based on Defendant’s willful
`
`infringement of the ’035 Patent;
`
`E.
`
`That Crossroads be granted pre-judgment and post-judgment interest on
`
`the damages caused to it by reason of Defendant’s infringement of the
`
`’035 Patent, including pre-judgment and post-judgment interest on any
`
`F.
`
`G.
`
`H.
`
`enhanced damages or attorneys’ fees award;
`
`That Defendant has infringed the ’041 Patent;
`
`That such infringement of the ’041 Patent by Defendant has been willful;
`
`That Defendant accounts for and pays to Crossroads all damages caused
`
`by the infringement of the ’041 Patent;
`
`I.
`
`That Crossroads receive enhanced damages from Defendant in the form of
`
`treble damages, pursuant to 35 U.S.C. § 284 based on Defendant’s willful
`
`infringement of the ’041 Patent;
`
`9
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 9
`
`
`
`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 10 of 12
`
`J.
`
`That Crossroads be granted pre-judgment and post-judgment interest on
`
`the damages caused to it by reason of Defendant’s infringement of the
`
`’041 Patent, including pre-judgment and post-judgment interest on any
`
`K.
`
`L.
`
`M.
`
`enhanced damages or attorneys’ fees award;
`
`That Defendant has infringed the ’147 Patent;
`
`That such infringement of the ’147 Patent by Defendant has been willful;
`
`That Defendant accounts for and pays to Crossroads all damages caused
`
`by the infringement of the ’147 Patent;
`
`N.
`
`That Crossroads receive enhanced damages from Defendant in the form of
`
`treble damages, pursuant to 35 U.S.C. § 284 based on Defendant’s willful
`
`infringement of the ’147 Patent;
`
`O.
`
`That Crossroads be granted pre-judgment and post-judgment interest on
`
`the damages caused to it by reason of Defendant’s infringement of the
`
`’147 Patent, including pre-judgment and post-judgment interest on any
`
`P.
`
`Q.
`
`R.
`
`enhanced damages or attorneys’ fees award;
`
`That Defendant has infringed the ’311 Patent;
`
`That such infringement of the ’311 Patent by Defendant has been willful;
`
`That Defendant accounts for and pays to Crossroads all damages caused
`
`by the infringement of the ’311 Patent;
`
`S.
`
`That Crossroads receive enhanced damages from Defendant in the form of
`
`treble damages, pursuant to 35 U.S.C. § 284 based on Defendant’s willful
`
`infringement of the ’311 Patent;
`
`10
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 10
`
`
`
`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 11 of 12
`
`T.
`
`That Crossroads be granted pre-judgment and post-judgment interest on
`
`the damages caused to it by reason of Defendant’s infringement of the
`
`’311 Patent, including pre-judgment and post-judgment interest on any
`
`enhanced damages or attorneys’ fees award;
`
`U.
`
`That Defendant pay Crossroads all of Crossroads’ reasonable attorneys’
`
`V.
`
`W.
`
`fees and expenses;
`
`That costs be awarded to Crossroads;
`
`That Defendant, its agents, employees, representatives, successors and
`
`assigns, and those acting in privity or in concert with it, be preliminarily
`
`and permanently enjoined from further infringement of the ’035 Patent;
`
`X.
`
`That Defendant, its agents, employees, representatives, successors and
`
`assigns, and those acting in privity or in concert with it, be preliminarily
`
`and permanently enjoined from further infringement of the ’041 Patent;
`
`Y.
`
`That Defendant, its agents, employees, representatives, successors and
`
`assigns, and those acting in privity or in concert with it, be preliminarily
`
`and permanently enjoined from further infringement of the ’147 Patent;
`
`Z.
`
`That Defendant, its agents, employees, representatives, successors and
`
`assigns, and those acting in privity or in concert with it, be preliminarily
`
`and permanently enjoined from further infringement of the ’311 Patent;
`
`AA.
`
`That this is an exceptional case under 35 U.S.C. § 285; and
`
`BB.
`
`That Crossroads be granted such other and further relief as the Court may
`
`deem just and proper under the circumstances.
`
`11
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 11
`
`
`
`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 12 of 12
`
`Dated: April 15, 2014
`
`Respectfully submitted,
`
`
`
`
`
`
`
`By: /s/ Susan K. Knoll
` Steven Sprinkle
` Texas Bar No. 00794962
` Elizabeth J. Brown Fore
` Texas Bar No. 24001795
` Sprinkle IP Law Group, PC
` 1301 W. 25th Street, Suite 408
` Austin, Texas 78705
` Tel: 512-637-9220
` Fax: 512-371-9088
` ssprinkle@sprinklelaw.com
` ebrownfore@sprinklelaw.com
`
`Susan K. Knoll
`Texas Bar No. 11616900
`Russell T. Wong
`Texas Bar No. 21884235
`James H. Hall
`Texas Bar No. 24041040
`Stephen D. Zinda
`Texas Bar No. 24084147
`WONG, CABELLO, LUTSCH,
`RUTHERFORD & BRUCCULERI, L.L.P.
`20333 SH 249, Suite 600
`Houston, TX 77070
`Tel: 832-446-2400
`Fax: 832-446-2424
`sknoll@counselip.com
`rwong@counselip.com
`jhall@counselip.com
`szinda@counselip.com
`
`ATTORNEYS FOR PLAINTIFF
`CROSSROADS SYSTEMS, INC.
`
`CERTIFICATE OF SERVICE
`
`I certify that on April 15, 2014, I electronically filed the foregoing with the Clerk of
`Court using the CM/ECF system, which will send notification of such filing to all CM/ECF
`participants.
`
`
`
`
`
`/s/ Lynn Marlin
`Lynn Marlin
`
`
`
`12
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 12
`
`
`
`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 1 of 15
`
`EXHIBIT A
`
`(cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3)
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 13
`
`
`
`ease 1:14-cv—ool49—ss Document||IlIlllI||||=|IIII|I|II||II||lL|IlI|||||=|lLII||I||lIlI|IlII||||||||||||
`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 2 of 15
`USUUG425035152
`
`(12) United States Patent
`(10) Patent No;
`US 6,425,035 B2
`
`Hoese et al.
`(45) Date of Patent:
`*Jul. 23, 2002
`
`m
`
`8/1999 Ofer
`5,935,260 A *
`7l4142
`811999
`[*Ioese el al.
`$941,972 A *
`7101129
`911999 Boggs ct a1.
`5,959,994 A *
`3701399
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`2.35:1(33; 2 "
`iiijii:
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`_ 3),) 2
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`512000 Keaveny et al.
`0.005.087 A *
`7101129
`(112L100 Krishnnn et at.
`0.075.803 A *
`..... 380149
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`0098,14) A $
`711/112
`912000 Akers
`0,118,700 A 4‘
`3701249
`0.143.004 A * 1112000 Nelson etnl
`37014153
`0.135.203 Bl
`*
`212001 Berman
`3701351
`0,209,024 Bl
`4‘
`312001 Dimitroff el al.
`7091211
`0.230.218 Bl
`*
`512001 Caspers el al.
`..... 710120
`
`6,341,315 BI
`“
`[12002 Arroyo et al.
`7091230
`
`.. 7091229
`112002 Hubis el al. A.
`15,343,324 Bl
`"
`A
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`* cited by examiner
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`
`
`(54) STORAGE ROUTER AND METHOD FOR
`PROVIDING VIRTUAL LOCAL STORAGE
`
`(75)
`
`.
`.
`(73) Assignee.
`
`*
`
`(
`
`.
`) Nome:
`
`Inventors: Geoffrey B. H0952, Austin; Jefi‘ry T.
`.1
`H1
`1
`Russell, (113010. bolh “1 IX (U5)
`.
`..
`.
`_
`.
`_
`_
`,
`-
`(Jose-roads Systems. Inc.,Austin,TX
`(U5)
`_
`.
`_
`,
`.
`SubJCCIVI0 any (1154313111105th 10““ 0111115
`Palcm IS cxlcndcd or adjusted under 35
`U.S.(I. 154(1))13311] days.
`
`This patent is subject to a terminal dis—
`claimer.
`
`21
`
`)
`(
`(22)
`
`A l.No.: 09 965 35
`pp
`I
`’3
`Filed:
`Sep. 27, 2001
`
`Related U.S. Application Data
`
`(63
`
`)
`
`lication No. [191354.681 filed on Jul. 15.
`Continuation ofa
`1999. which Baogititinualion ofapplication No.0910l')1,799.
`
`filed on Dec. 31, 1907, now Pat. No. 3,941,912.
`
`Int. Cl.7
`(EMF [3/00
`(51)
`7
`7
`(5“ U'S' C"
`71011129; 71011.18; HUM;
`‘
`..
`710/30. 7109105
`(58) held “I. beareh
`71011—5) 8—13!
`710/36—38- 105: 100—101, 126—1313 7111100!
`112: “3; 714/42
`
`(56)
`
`..
`References (.lted
`U.S. PA'I'EN'I' DOCUMEN'I‘S
`
`511998 Llorcns el al.
`7101129
`5.748.924 A *
`611998 Judd et all
`710137
`5,768,621 A ‘
`
`911998 Nogales et al
`71015
`5,809,328 A *
`
`911998 Llli elal. ........
`71416
`5.812.154 A ‘F
`. 3701514
`5.835.496 A * 1111998 ‘r’euttg et al.
`
`5,848,251 A * 1211998 Lorne-lino el al.
`........... 710/129
`
`Primary harrminer—Christopher I3. Shin
`(74) Adamo); Agent, or Finn—Gray Cary Ware &
`Friedrich LLP
`
`(5'1)
`
`ABSTRACT
`
`.
`A storage router (56) and storage network (50) PmV‘dC
`Vtrtual local storage on remote SCSI storage (lcvtces (60, 62,
`611) IIO‘FIIJGI' Channel devices. Aplurahty ol‘F1ber Channel
`dcvrces, such as workstations (58), are connected to a Flber
`Channel
`transport medium (52), and a plurality of SCSI
`storage devices (60, 62, 64) are connected to a SCSI bus
`transport medium (54}. The storage router (56) interfaces
`between the Fibre Channel transport medium (52) and the
`SCSI bus transport medium (54). The storage router (56)
`maps between the workstations (58) and the SCSI storage
`devices (60. 62, 64) and implements access controls [or
`storage space on the SCSI storage devices (60, 62. 64). The
`storage router (56) then allows access from the workstations
`(58) t0 the SCSI storage devices (60, 62, 64) using native
`low level, block protocol in accordance with the mapping
`and the access. controls.
`
`14 Claims, 2 Drawing Sheets
`
`SIORAGE DEVICE
`
`
`
`
`
`
`STORAGE DEVICE
`WORKSTATION
`A STORAGE
`
`WORKSTATION
`B STORAGE
`WORKSTAUON
`C STORAGE
`NORKSTAT ION
`D STORAGE
`
`50
`
`64
`
`STORAGE DEVICE
`
`llt'URKSTtItTIOI‘u'
`E SFORAGE
`
`
`74
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 14
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 14
`
`
`
`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 3 of 15
`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 3 of 15
`
`US. Patent
`
`Jul. 23, 2002
`
`Sheet 1 0f2
`
`US 6,425,035 B2
`
`12
`12
`12
`
`
`10
`
` FIG.
`
`
`
` 58
`
`
` .*
`STORAGE DEVICE
`
`WORKSTATION
`C
`
`52
`
`WORKSTATION
`D
`
`WORKSTATION
`E
`
`58
`
`58
`
`WORKSTATION
`A STORAGE
`
`WORKSTATION
`
`4a
`
`STATION
`
`?6
`
`WORKSTATION
`c STORAGE
`
`WORKSTATION
`
`70
`
`
`
`
`--
`
`
`
`I B STORAGE
`
`
`I D STORAGE I 72
`STORAGE DEVICE
`
`WORKSTATION
`
`E STORAGE
`
`
`55'
`
`FIG. 3
`
`54
`
`74
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 15
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 15
`
`
`
`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 4 of 15
`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 4 of 15
`
`US. Patent
`
`Jul. 23, 2002
`
`Sheet 2 of 2
`
`US 6,425,035 32
`
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`Oracle-Huawei-NetApp Ex. 1036, pg. 16
`
`Oracle-Huawei-NetApp Ex. 1036, pg. 16
`
`
`
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`
`
`
`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 5 of 15
`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 5 of 15
`
`US 6,425,035 132
`
`1
`STORAGE ROUTER AND METHOD FOR
`PROVIDING VIRTUAL LOCAL STORAGE
`
`RE] .A'I'L‘D APPLICATIONS
`
`This application claims the benefit of the filing date of
`U.S. patent application Ser. No. [IQ/354,682 by inventors
`(ieoll‘rey B. Iloese and Jeffry T. Rupasel], entitled “Storage
`Router and Method for Providing Virtual Local Storage“
`filed on Jul. 15, 1999. which is a continuation of US. patent
`application Ser. No. 091001399, filed on Dec. 31, 1997,
`nowI U.S. Pat. No. $941,972, and hereby incorporates these
`applications by reference in their entireties as if they had
`been fully set forth herein.
`'I'L'CIINICAI. ME] .1) ()1: THE INVENTION
`
`to network storage
`This invention relates in general
`devices, and more particularly to a storage router and
`method for providing virtual local storage on remote SCSI
`storage devices to Fiber Channel devices.
`BACKGROUND OI" THE INVENTION
`
`Typical storage transport mediums provide for a relatively
`small number ol‘ devices to be attached over relatively short
`distances. One such transport medium is a Small Computer
`System Interface (SCSI) protocol, the structure and opera—
`tion ol‘ which is generally well known as is described, for
`example, in the SCSI-l, SCSI-2 and SCSI-3 specifications.
`High speed serial interconnecLs provide enhanced capability
`to attach a large number of high speed devices to a common
`storage transport medium over large distances. One such
`serial interconnect is Fibre Channel, the structure and opera-
`tion of which is described, for example, in Fiber Channel
`Physical and Signaling Interface (FC—PH), ANSI X3230
`Fiber Channel Arbitrated Loop (FC—AL), and ANSI X3272
`Fiber Channel Private Loop Direct Attach (FC—PLDA).
`Conventional computing devices, such as computer
`workstations, generally access storage locally or through
`network interconnects. Local storage typically consists of a
`disk drive,
`tape drive, CD—ROM drive or other storage
`device contained within, or locally connected to the work
`station. The workstation provides a file system structure, that
`includes security controls, with access to the local storage
`device through native low level, block protocols. These
`protocols map directly to the mechanisms used by the
`storage device and consist of data requests without security
`controls. Network interconnects typically provide access for
`a large number of computing devices to data storage on a
`remote network server. The remote network server provides
`file system structure, access control, and other miscellaneous
`capabilities that include the network interface. Access to
`data through the network server is through network proto-
`cols that the server must translate into low level requests to
`the storage device. A workstation with access to the server
`storage must translate its file system protocols into network
`protocols that are used to communicate with the server.
`Consequently,
`from the perspective of a workstation, or
`other computing device, seeking to access such server data.
`the access is much slower than access to data on a local
`storage device.
`SUMMARY OF THE INVENTION
`
`In accordance with the present invention, a storage router
`and method for providing virtual local storage on remote
`SCSI storage devices to Fiber Channel devices are disclosed
`that provide advantages over conventional network storage
`devices and methods.
`
`5
`
`It]
`
`15
`
`10
`
`I'ur."
`
`40
`
`bl]
`
`2
`invention, a
`According to one aspect of the present
`storage router and storage network provide virtual
`local
`storage on remote SCSI storage devices to Fiber Channel
`devices. A plurality of Fiber Channel devices, such as
`workstations, are connected to a Fiber Channel transport
`medium, and a plurality of SCSI storage devices are con—
`nected to a SCSI bus transport medium. The storage router
`interfaces between the liiber Channel transport medium and
`the SCSI bus transport medium. 'II'Ie storage router maps
`between the workstations and the SCSI storage devices and
`implements access controls for storage space on the SCSI
`storage devices. The storage router then allows access from
`the workstations to the SCSI storage devices using native
`low level, block protocol in accordance with the mapping
`and the access controls.
`According to another aspect of the present invention,
`virtual
`local storage on remote SCSI storage devices is
`provided to Fiber Channel devices. A Fibre Channel trans—
`port medium and a SCSI bus transport medium are inter—
`faced with. A configuration is maintained for SCSI storage
`devices connected to the SCSI bus transport medium. The
`configuration maps between Fiber Channel devices and the
`SCSI storage devices and implements access controls for
`storage space on the SCSI storage devices. Access is then
`allowed from Fiber Channel initiator devices to SCSI stor-
`age devices using native Iow level, block protocol in accor—
`dance with the configuration.
`invention is the
`A technical advantage of the present
`ability to centralize local storage for networked workstations
`without any cost of speed or overhead. Each workstation
`access its virtual local storage as if it work locally con—
`nected. Further,
`the centralized storage devices can be
`located in a significantly remote position even in excess of
`ten kilometers as defined by Fibre Channel standards.
`Another technical advantage of the present invention is
`the ability to centraily control and administer storage space
`[or connected users without limiting the speed with which
`the users can access local data. In addition, global access to
`data, backups, virus scanning and redundancy can be more
`easily accomplished by centrally located storage devices.
`A further technical advantage of the present invention is
`providing support for SCSI storage devices as local storage
`for Fiber Channel hosts. In addition, the present invention
`helps to provide extended capabilities for Fiber Channel and
`[or management of storage subsystems.
`BRIEF DESCRIPTION Oli THE DRAWINGS
`
`A more complete understanding ol‘ the present invention
`and the advantages thereof may be acquired by referring to
`the following description taken in conjunction with the
`accompanying drawings,
`in which like reference numbers
`indicate like features, and wherein:
`FIG. I is a block diagram ol‘ a conventional network that
`provides storage through a network server;
`I'IG. 2 is a block diagram 01‘ one embodiment of a storage
`network with a storage router that provides global access
`and routing;
`FIG. 3 is a block diagram of one embodiment of a storage
`network with a storage router that provides virtual local
`storage;
`FIG. 4 is a block diagram of one embodiment of the
`storage router of FIG, 3; and
`FIG. 5 is a block diagram of one embodiment of data flow
`wi