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` CROSSROADS EXHIBIT 2350
`Oracle Corp., et al v. Crossroads Systems, Inc.
` IPR2014-01207 and IPR2014-1209
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`I, John Middleton, state and declare as follows:
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`1.
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`I was an employee of Crossroads Systems, Inc. from 1997 until 2001.
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`I started at Crossroads in February of 1997. For most of my tenure at Crossroads I
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`was a Vice—president of engineering.
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`2.
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`During 1997, I worked on the “Verrazano” project, which ultimately
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`became Crossroad’s first storage bridge product. During this time period, I worked
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`with both Geoffrey Hoese and Jeffrey Russell on the Verrazano project. My role
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`on Verrazano was hardware engineering manager.
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`3.
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`During my employment at Crossroads, including my work on the
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`Verrazano project, I became familiar with Crossroads’ recordkeeping practices.
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`Specifically, I became familiar with Crossroads’ practices regarding the creation,
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`modification, and keeping of documents. Documents related to the Verrazano
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`project, such as presentations, drawings, product specifications, product
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`instructions, reports, and the like, were created by Crossroads employees during
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`the regular course of business.
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`4.
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`Both during and after the Verrazano project, it was the regular
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`practice of Crossroads’ employees to create such records at or near the time the
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`recorded act, event, condition, or opinion occurred. For example, if a particular
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`drawing were updated or changed, the change was generally noted by inclusion of
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`a revision date and a description of the reason for the change. If a document was
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`revised, generally this would be reflected by a new revision number and the date of
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`the revision. It was the general practice of Crossroads’ personnel to date such
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`documents as of the date the record was created or modified. I do not recall any
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`instance in which documents related to the Verrazano project were dated in the
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`future or the past, and doing so would have been inconsistent with Crossroads’
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`normal practice.
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`5.
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`It was Crossroads’ normal practice that documents and records could
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`only be made or revised by someone with knowledge or based on information
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`transmitted by someone with knowledge. Documents and records like those
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`mentioned in paragraph 3 were regularly made and kept in the course of
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`Crossroads’ regularly conducted business activity—specif1cally, the design and
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`creation of new products.
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`6.
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`The above practices were in place at Crossroads in 1997, and
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`afterwards. During the time I was at Crossroads, Crossroads practices regarding the
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`creation, modification, and keeping of documents and records, as previously stated,
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`did not change.
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`7.
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`I was at Crossroads when it sued Chaparral Network Storage. I recall
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`gathering documents related to the lawsuit and providing them for Crossroads’
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`attorneys. When doing so, I made available only true and correct copies of
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`Crossroads’ documents, without any changes. I am unaware of anyone making any
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`changes to any documents that were provided to Crossroads’ attorneys.
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`I declare under penalty of perjury under the laws of the United States of America
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`that the foregoing is true and correct.
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`Executed on: June __§, 2015
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