UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CROSSROADS SYSTEMS, INC.
`Patent Owner
`____________
`Patent No. 7,051,147
`____________
`
`DECLARATION OF BRIAN BIANCHI
`
` CROSSROADS EXHIBIT 2351
`Oracle Corp., et al v. Crossroads Systems, Inc.
` IPR2014-01207 and IPR2014-1209
`
`1 of 8
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`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CROSSROADS SYSTEMS, INC.
`Patent Owner
`____________
`Patent No. 7,051,147
`____________
`
`DECLARATION OF BRIAN BIANCHI
`
` CROSSROADS EXHIBIT 2351
`Oracle Corp., et al v. Crossroads Systems, Inc.
` IPR2014-01207 and IPR2014-1209
`
`1 of 8
`
`
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`I, Brian Bianchi, state and declare as follows:
`
`1.
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`I am an employee of Crossroads Systems, Inc. I started my
`
`employment with Crossroads in 1998 in the position of Software Engineering
`
`Manager. I am currently in the position of Chief Operating Officer. My knowledge
`
`of the facts stated here is based on my employment with Crossroads.
`
`2.
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`I understand the exhibits listed in Exhibit A to this declaration were
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`filed by Crossroads in certain proceedings before the Patent Trial and Appeal
`
`Board. Regarding those exhibits:
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`a) Exhibits 2303 and 2323 (with the exception of the exhibit labels and
`
`Bates label numbers) are duplicate copies of documents contained in
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`Crossroads’ patent files and kept during the ordinary course of business.
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`b) Exhibits 2307, 2308, 2309, 2312, 2314, 2316, 2317, 2318, 2319, 2320,
`
`and 2321 are duplicate copies of Crossroads’ business records which
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`were created or modified during the course of the “Verrazano” project.
`
`3. While employed at Crossroads I worked on the “Verrazano” project,
`
`which ultimately became Crossroad’s first storage bridge product. Through that
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`experience, as well as my subsequent time at Crossroads, I became familiar with
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`Crossroads recordkeeping practices, and specifically Crossroads’ practices
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`2 of 8
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`regarding the creation, modification, and retention of documents and records,
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`including those referenced in Exhibit A. My familiarity with Crossroads’ record-
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`keeping practices includes not only the time period beginning with my
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`employment, but also the time period preceding my employment, specifically with
`
`regard to the Verrazano project. I became familiar with the practices in use prior to
`
`my employment because I was instructed on those practices as I was working at
`
`Crossroads. I also learned Crossroads’ practices prior to my employment through
`
`interaction and instruction from Crossroads employees that were hired before me.
`
`4.
`
`All of the statements below regarding Crossroads’ recordkeeping
`
`practices apply to the Crossroads’ documents listed in Exhibit A, and are true both
`
`as of the time of the Verrazano project before I was hired, and subsequent to my
`
`hiring:
`
`a. It was Crossroads’ regular practice to create these and similar records;
`
`b. It was Crossroads’ regular practice that these and similar records be
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`made at or near the time of a the recorded act or event by someone
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`with knowledge, or from information provided by someone with
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`knowledge;
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`3 of 8
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`c. It was Crossroads’ regular practice that these and similar records be
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`kept, in the course of Crossroads’ regularly conducted activity (here,
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`product design and development).
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`5.
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`I have reviewed the declaration of John Middleton, a former
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`Crossroads employee, regarding Crossroads’ recordkeeping practices during his
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`employment from 1997 to 2001, and executed on June 8, 2015. I agree with every
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`statement in Mr. Middleton’s declaration regarding Crossroads’ recordkeeping
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`practices. His declaration is fully consistent with my understanding of Crossroads’
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`practices during the time the Crossroads documents listed in Exhibit A were
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`created, modified, and retained. Furthermore, Crossroads’ recordkeeping practices
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`have not changed and have remained the same during my time at Crossroads, and
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`are consistent with Mr. Middleton’s declaration.
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`6.
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`I also understand that there have been objections to the documents
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`attached as Exhibit C to my April 20, 2015 declaration (Bates labeled CRDS
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`504194-95, CRDS 504202-06, and CRDS 506658-59). Each of these documents is
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`a true and correct copy of a Crossroads brochure or sales guidance document, and
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`each accurately describes the features of the products referenced therein.
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`4 of 8
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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 16, 2015
`
`Kay
`
`Brian Bianchi
`
`5 of 8
`5of8
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`Exhibit
`No.
`2303
`
`EXHIBIT A
`
`Title / Description
`
`July 11, 1997 Letter and Draft Patent Application from Mr. Anthony
`Peterman (Baker & Botts LLP) to Mr. Geoffrey Hoese
`
`(Plaintiff’s Exhibit 266 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`2307
`
`Verrazano FC-SCSI Bridge Product Overview Presentation, June 19,
`1996
`
`(Plaintiff’s Exhibit 4 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`2308
`
`Verrazano Software Development, Sept. 10, 1996
`
`(Plaintiff’s Exhibit 5 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`2309
`
`Verrazano: System Structure Drawings, Document Number DS04100,
`Jan. 22, 1997
`
`(Plaintiff’s Exhibit 6 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`2312
`
`Verrazano Bare Board Drawings (latest revisions Sept. 3, 1997)
`CRDS 50579
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`6 of 8
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`Exhibit
`No.
`2314
`
`Title / Description
`
`Verrazano Enclosure Specification, Revision 2.1, June 5, 1997
`
`(Plaintiff’s Exhibit 264 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`2316
`
`CP4x00 Product Specification (Preliminary)
`
`(Plaintiff’s Exhibit 267 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`(Exhibit 10 to Deposition of Jeffry Russell, Sept. 26, 2000, taken in
`Crossroads Systems, (Texas), Inc. v. Chaparral Network Storage, Inc.,
`Docket No. A 00-CA-217 SS (W.D. Tex. 2001)).
`
`2317
`
`Verrazano Hardware Architecture, Revision 1.0, Aug. 25, 1997
`
`(Plaintiff’s Exhibit 268 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`(Exhibit 2 to Deposition of Jeffry Russell, Sept. 26, 2000, taken in
`Crossroads Systems, (Texas), Inc. v. Chaparral Network Storage, Inc.,
`Docket No. A 00-CA-217 SS (W.D. Tex. 2001)).
`
`2318
`
`2319
`
`2320
`
`Verrazano: System Structure Drawings, Document Number DS04100,
`Sept. 3, 1997
`
`Verrazano Software Architecture, Revision 1.1, Aug. 27, 1997
`
`Verrazano Programmable Device Instructions, Version 1.1, Sept. 5,
`1997
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`7 of 8
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`Exhibit
`No.
`2321
`
`2323
`
`Title / Description
`
`Verrazano Component List and Insertion List Report, Sept. 29, 1997
`
`December 31, 1997 Letter and Patent Application from Mr. William
`Hulsey (Baker & Botts LLP) to Mr. Dale Quisenberry
`
`(Plaintiff’s Exhibit 275 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`8 of 8
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