Trials@uspto.gov Paper No. 49
`571-272-7822
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` Filed: March 16, 2016
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CISCO SYSTEMS, INC., QUANTUM CORPORATION,
`and ORACLE CORPORATION,
`Petitioners,
`
`v.
`
`CROSSROADS SYSTEMS, INC.,
`Patent Owner.
`____________
`
`Case IPR2014-014631
`Patent 7,934,041 B2
`____________
`
`Before NEIL T. POWELL, KRISTINA M. KALAN, J. JOHN LEE, and
`KEVIN W. CHERRY, Administrative Patent Judges.
`
`POWELL, Administrative Patent Judge.
`
`
`
`FINAL WRITTEN DECISION
`35 U.S.C. § 318(a) and 37 C.F.R. § 42.73
`
`INTRODUCTION
`I.
`We have jurisdiction to hear this inter partes review under 35 U.S.C.
`§ 6(c). This Final Written Decision is issued pursuant to 35 U.S.C. § 318(a)
`and 37 C.F.R. § 42.73. For the reasons discussed below, we determine that
`
`
`1 Case IPR2015-00854 has been joined with this proceeding.
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`IPR2014-01463
`Patent 7,934,041 B2
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`Petitioners have shown by a preponderance of the evidence that claims 1–53
`of U.S. Patent No. 7,934,041 B2 (Ex. 1001, “the ’041 patent”) are
`unpatentable.
`Procedural History
`A.
`Cisco Systems, Inc. and Quantum Corporation filed a Petition
`(Paper 3, “Pet.”) requesting institution of an inter partes review of claims 1–
`53 of the ’041 patent. On December 19, 2014, Crossroads Systems, Inc.
`(“Patent Owner”) filed a Preliminary Response (Paper 7, “Pelim. Resp.”). In
`a Decision to Institute (Paper 9, “Dec. Inst.”) issued March 17, 2015, we
`instituted an inter partes review of claims 1–53 on the following grounds of
`unpatentability:
`1. Claims 1–14, 16–33, 35–50, and 53 under 35 U.S.C. § 103(a) for
`obviousness over CRD-5500 Manual2 and HP Journal3; and
`2. Claims 15, 34, 51, and 52 under 35 U.S.C. § 103(a) for
`obviousness over CRD-5500 Manual, HP Journal, and Fibre
`Channel Standard4.
`After institution of trial, Patent Owner filed a Patent Owner Response
`(Paper 19, “PO Resp.”) and Petitioners filed a Reply (Paper 32, “Pet.
`Reply”). On March 6, 2015, in IPR2015-00854, Oracle Corporation filed a
`
`2 CMD Technology, Inc., CRD-5500 SCSI RAID Controller User’s Manual
`(1996) (Ex. 1004).
`3 Petitioners cite the following articles in Exhibit 1006 as one reference:
`Meryem Primmer, An Introduction to Fibre Channel, 47 HEWLETT-
`PACKARD J. 94–98 (1996) and Judith A. Smith & Meryem Primmer,
`Tachyon: A Gigabit Fibre Channel Protocol Chip, 47 HEWLETT-PACKARD
`J. 99–112 (Oct. 1996) (Ex. 1006).
`4 American National Standards Institute, Inc., Fibre Channel Physical and
`Signaling Interface (FC-PH) X3.230 (June 1, 1994) (“Fibre Channel
`Standard”) (Ex. 1007).
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`Petition requesting inter partes review of claims 1–53 of the ’041 patent,
`along with a motion for joinder. Oracle Corp. v. Crossroads Sys., Inc., Case
`IPR2016-00854, Papers 1 & 3 (PTAB). On September 15, 2015, we granted
`Oracle Corporation’s motion for joinder and joined IPR2015-00854 to this
`proceeding. Case IPR2015-00854, Paper 14. Oral hearing was held on
`October 30, 2015.5
`Petitioners submitted the Declaration of Andrew Hospodor, Ph.D.,
`dated September 5, 2014 (Ex. 1003, “Hospodor Declaration”), in support of
`their Petition.
`Patent Owner submitted the Declaration of Dr. John Levy, Ph.D.,
`dated May 26, 2015 (Ex. 2027, “Levy Declaration”). Patent Owner also
`submitted other declarations in support of its contentions of secondary
`considerations of non-obviousness. See Ex. 2039; Ex. 2043.
`Patent Owner filed a Motion to Exclude (Paper 37) and Reply in
`support of its Motion to Exclude (Paper 43). Petitioners filed an Opposition
`to Patent Owner’s Motion to Exclude (Paper 41).
`B. Related Proceedings
`The ’041 patent is the subject of multiple district court proceedings.
`Pet. 1; Paper 6, 2–3. The ’041 patent belongs to a family of patents that are
`the subject of multiple inter partes review petitions, including IPR2014-
`01197, IPR2014-01207, IPR2014-01209, IPR2014-01226, IPR2014-01544,
`IPR2015-00822, and IPR2015-00852.
`
`
`
`5 A transcript of the oral hearing (“Tr.”) is included in the record as
`Paper 48.
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`II. DISCUSSION
`
`A. The ’041 Patent
`The ’041 patent relates to a storage router and method for providing
`virtual local storage on remote Small Computer System Interface (“SCSI”)
`storage devices to Fiber Channel (“FC”) devices. Ex. 1001, 1:44–47. SCSI
`is a storage transport medium that provides for a “relatively small number of
`devices to be attached over relatively short distances.” Id. at 1:51–54. FC is
`a high speed serial interconnect that provides “capability to attach a large
`number of high speed devices to a common storage transport medium over
`large distances.” Id. at 1:56–59. Computing devices can access local
`storage through native low level, block protocols and can access storage on a
`remote network server through network interconnects. Id. at 1:65–2:10. To
`access the storage on the remote network server, the computing device must
`translate its file system protocols into network protocols, and the remote
`network server must translate network protocols to low level requests. Id. at
`2:12–20. A storage router can interconnect the SCSI storage transport
`medium and the FC high speed serial interconnect to provide devices on
`either medium access to devices on the other medium so that no network
`server is involved. Id. at 3:58–4:1.
`Figure 4 of the ’041 patent is reproduced below:
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`Figure 4 is a block diagram of an embodiment of a storage router. Id.
`at 3:22–23, 5:34–35. Storage router 56 can comprise FC controller 80 that
`interfaces with FC 52 and SCSI controller 82 that interfaces with SCSI
`bus 54. Buffer 84 connects to FC controller 80 and SCSI controller 82, and
`provides memory work space. Id. at 5:35–37. Supervisor unit 86 connects
`to FC controller 80, SCSI controller 82, and buffer 84. Id. at 5:37–39.
`Supervisor unit 86 controls operation of storage router 56 and handles
`mapping and security access for requests between FC 52 and SCSI bus 54.
`Id. at 5:39–44.
`Claims 1, 20, and 37 are the independent claims at issue in this trial,
`and claim 1 is reproduced below:
`A storage router for providing virtual local storage on remote
`1.
`storage devices, comprising:
`
`a first controller operable to interface with a first transport medium,
`wherein the first medium is a serial transport media; and
`
`a processing device coupled to the first controller, wherein the
`processing device is configured to:
`
`maintain a map to allocate storage space on the remote storage
`devices to devices connected to the first transport
`medium by associating representations of the devices
`connected to the first transport medium with
`representations of storage space on the remote storage
`devices, wherein each representation of a device
`connected to the first transport medium is associated with
`one or more representations of storage space on the
`remote storage devices;
`
`control access from the devices connected to the first transport
`medium to the storage space on the remote storage
`devices in accordance with the map; and
`
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`allow access from devices connected to the first transport
`medium to the remote storage devices using native low
`level block protocol.
`
`Id. at 9:35–56.
`B. Claim Construction
`In an inter partes review, claim terms in an unexpired patent are given
`their broadest reasonable construction in light of the specification of the
`patent in which they appear. 37 C.F.R. § 42.100(b); In re Cuozzo Speed
`Tech., LLC, 793 F.3d 1268, 1278–79 (Fed. Cir. 2015), cert. granted sub
`nom. Cuozzo Speed Techs., LLC v. Lee, 136 S. Ct. 890 (2016). Under the
`broadest reasonable construction standard, claim terms are given their
`ordinary and customary meaning, as would be understood by one of ordinary
`skill in the art in the context of the entire disclosure. In re Translogic Tech.,
`Inc., 504 F.3d 1249, 1257 (Fed. Cir. 2007). Any special definition for a
`claim term must be set forth with reasonable clarity, deliberateness, and
`precision. In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir. 1994). Only those
`terms which are in controversy need be construed, and only to the extent
`necessary to resolve the controversy. Vivid Techs., Inc. v. Am. Sci. & Eng’g,
`Inc., 200 F.3d 795, 803 (Fed. Cir. 1999).
`In our Decision to Institute, we construed “native low level block
`protocol” and “remote.” Dec. Inst. 8–9. Neither party contests our
`construction for “native low-level block protocol” and “remote.” We adopt
`our previous constructions and analysis for those terms based on the full
`record after trial. See id. at 8–9. Thus, we construe “native low-level block
`protocol” as “a protocol in which storage space is accessed at the block
`level, such as the SCSI protocol.” Id. at 8. We also construe “remote” as
`“indirectly connected through a storage router to enable connections to
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`storage devices at a distance greater than allowed by a conventional parallel
`network interconnect.” Id. at 8–9.
`In the Patent Owner Response, Patent Owner asserts that
`Each of the independent claims includes a “map:
`limitation: “a [storage router] . . . configured to[]
`maintain a map to allocate storage space on the remote
`storage devices to devices connected to the first transport
`medium, by associating representations of the devices
`connected
`to
`the
`first
`transport medium with
`representations of storage space on the remote storage
`devices . . . ” (Claims 1 and 20); “maintaining a map at
`the storage router to allocate storage space on the remote
`storage devices to devices connected to the first transport
`medium by associating representations of the devices
`connected
`to
`the
`first
`transport medium with
`representations of storage space on the remote storage
`devices . . .” (Claim 37).
`PO Resp. 5. Patent Owner proposes a construction for the “map”
`limitations. Id. at 5–10.
`Patent Owner also identifies certain limitations of independent claims
`1, 20, and 37 as “control[ing] access” limitations, stating that “[e]ach of the
`independent claims also recites ‘control[ling] access from the devices
`connected to the first transport medium to the storage space . . . in
`accordance with the map.’” Id. at 10. Patent Owner proposes a construction
`of the “control[ling] access” limitations. Id. at 10–12.
`“map” limitations
`Patent Owner submits that in the “map” limitations, the map
`“specifically identifies the host and storage so that the storage router can
`allocate storage to particular hosts.” PO Resp. 10. Patent Owner argues that
`this understanding is consistent with the testimony of Petitioners’ expert, and
`the intrinsic evidence. Id. at 6–8. Patent Owner asserts that “‘allocate
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`storage space on the remote storage devices to devices connected to the first
`transport medium by associating representations of the devices connected to
`the first transport medium with representations of storage space on the
`remote storage devices’ as claimed means the ‘map’ must identify within the
`map the precise host to which storage has been allocated within the map.”
`Id. at 7 (citing Ex. 2027 ¶¶ 36–38). According to Patent Owner, it is not
`enough to map between a storage device and an intermediate identifier
`associated with a particular device because the identifier is not directly and
`immutably associated with the device itself—in other words, mapping to an
`identifier is insufficient unless the identifier is associated with a particular
`device and cannot be associated with any other device. See id. at 16–21
`(arguing that mapping to a channel identifier does not suffice, even if the
`channel is connected to only one host device, because the channel identifier
`could be associated with another device if another device were connected to
`that channel).
`Petitioners object that, for two reasons, Patent Owner’s proposed
`construction is not the broadest reasonable construction. First, Petitioners
`argue that the claims recite a “map” with “representations” of no specific
`type and that the specification of the ’041 patent simply teaches associating
`hosts and storage. Pet. Reply 3. Petitioners argue that the specification
`contains no implementation details and is silent as to the specific manner in
`which such associations are created. Id. Thus, Petitioners contend that
`Patent Owner’s requirement of a particular map with specific characteristics
`cannot be the broadest reasonable construction. Id. Second, Petitioners
`assert that Patent Owner seeks a construction that not only must the mapping
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`include precise identifiers, but that those identifiers must be intrinsically tied
`to a host. Id. at 3–4.
`The construction proposed by Patent Owner is overly narrow.
`Although Patent Owner emphasizes that the map must identify specific host
`devices, it does not explain persuasively why the claim language should be
`construed to exclude doing so via intermediate identifiers. See PO Resp. 5–
`10. Patent Owner does not identify any disclosure in the ’041 patent’s
`specification that clearly disavows mapping to a device indirectly, or
`mapping to a device via an intermediate identifier that could identify a
`different host if the system were configured differently. See Gillette Co. v.
`Energizer Holdings, Inc., 405 F.3d 1367, 1374 (Fed. Cir. 2005) (holding that
`“words of manifest exclusion or explicit disclaimers in the specification are
`necessary to disavow claim scope” (internal quotations omitted)). Patent
`Owner’s discussion of Figure 3, for example, is insufficient to compel a
`narrow construction of the term because Patent Owner analyzes only a
`preferred embodiment of the invention. See PO Resp. 8–10; see, e.g., In re
`Am. Acad. of Sci. Tech Ctr., 367 F.3d 1359, 1369 (Fed. Cir. 2004) (holding
`that limitations should not be imported from preferred embodiments into the
`claims absent a clear disclaimer of claim scope in the specification).
`Moreover, the ’041 patent specifically discusses mapping with
`identifiers that are not immutable. For example, the specification discusses
`addressing devices on an FC loop using an AL_PA (arbitrated loop physical
`address) identifier, and the possibility of “FC devices changing their AL-PA
`due to device insertion or other loop initialization.” Ex. 1001, 8:51–56; see
`Tr. 54:5–55:15 (counsel for Patent Owner acknowledging an AL_PA is a
`“temporarily assigned ID” that can point to different devices); Pet. Reply 4–
`
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`8 (discussing evidence supporting the use of intermediate identifiers,
`including testimony by Patent Owner’s proffered expert).
`For the reasons above, we are not persuaded that the broadest
`reasonable interpretation of the “map” limitations mandates mapping
`directly or immutably to a host device itself, or excludes mapping to devices
`using intermediate identifiers.
`The ’041 patent is related to a number of other patents, including U.S.
`Patent No. 6,425,035 B2 (“the ’35 patent”) and U.S. Patent No. 7,051,147
`(“the ’147 patent”). The ’041 patent, the ’035 patent, and the ’147 patent are
`related to one another because each is a continuation of one or more patent
`applications that are continuations of application No. 09/001,799, filed on
`December 31, 1997, now U.S. Patent No. 5,941,972. We note that a district
`court in a related case construed the claim terms “map” and “mapping” in
`the ’035 patent as follows:
`To create a path from a device on one side of the storage router
`to a device on the other side of the router. 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.
`
`Ex. 1010, 12. In IPR2014-01226 and IPR2014-01544 we concluded that the
`district court’s construction reproduced above is the broadest reasonable
`interpretation of certain claim limitations in the ’035 patent and the ’147
`patent similar to the “map” limitations in the ’041 patent. Cisco Sys., Inc. v.
`Crossroads Sys., Inc., Case IPR2014-01266, slip op. at 10 (PTAB Jan. 29,
`2016) (Paper 51); Cisco Sys., Inc. v. Crossroads Sys., Inc., Case IPR2014-
`01544, slip op. at 8–9 (PTAB Jan. 29, 2016) (Paper 50). After considering
`the evidence of record, we determine the above claim construction from the
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`district court also corresponds to the broadest reasonable interpretation of
`the “map” limitations of claims 1, 20, and 37 of the ’041 patent and adopt it
`for purposes of this Decision.
`“control access”/“controlling access” limitations
`Patent Owner also seeks to have us construe the various limitations
`that include the language “control access” or “controlling access.” PO
`Resp. 10–12. Patent Owner contends that “‘[c]ontrol[ling] access’ refers to
`the use of ‘access controls’ that limit a device’s access to a specific subset of
`storage devices or sections of a single storage device according to a map.”
`Id. at 10. In other words, Patent Owner asserts that “controlling access is
`device specific in that it involves controlling a particular device’s access to
`specified storage according to the map.” Id. at 12 (citing Ex. 2027 ¶ 43).
`Patent Owner argues that, as described in the specification of the ’041
`patent, the storage router implements access controls according to the map
`so that the allocated storage can only be accessed by the host(s) associated
`with that storage in the map. Id.
`Petitioners disagree with Patent Owner’s understanding of the
`meaning of these limitations. Pet. Reply 8–10. In particular, Petitioners
`argue that Patent Owner seeks to impermissibly narrow the “control access”
`limitations by arguing that to meet these limitations the prior art must
`additionally provide different storage access to different hosts. Id. at 8.
`Petitioners also submit that “Patent Owner seeks to read into the ‘control
`access’ limitation a requirement that access to storage by particular hosts
`must be maintained between physical reconfigurations of the hosts.” Id.
`at 9. Thus, Petitioners argue that the “control access” limitations “should be
`at least as broad as the District Court’s construction of ‘limit a device’s
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`access to a specific subset of storage devices or sections of a single storage
`device according to a map.” Id. at 10.
`
`We agree with Petitioners that the “control access”/“controlling
`access” limitations are not as limited as Patent Owner contends. Patent
`Owner fails to point us to any express or implicit disclaimer in the
`specification of the ’041 patent that would limit “control
`access”/“controlling access” to using only device-specific access controls
`that can only limit a particular device’s access to specified storage. For
`example, the discussion of Figure 3 of the ’041 patent is insufficient to
`compel a narrow construction of the term because it analyzes only a
`preferred embodiment of the invention. See Thorner v. Sony Computer
`Entm’t Am. LLC, 669 F.3d 1362, 1366–67 (Fed. Cir. 2012) (“To constitute
`disclaimer, there must be a clear and unmistakable disclaimer . . . It is
`likewise not enough that the only embodiments, or all of the embodiments,
`contain a particular limitation.”).
`
`Thus, we agree with Petitioners that the broadest reasonable
`interpretation of the terms “control access”/“controlling access” is “limit a
`device’s access to a specific subset of storage devices or sections of a single
`storage device according to a map.” Ex. 1026, 14, 40; Ex. 2027 ¶ 34.
`C. Obviousness of Claims 1–14, 16–33, 35–50, and 53 over CRD-
`5500 Manual and HP Journal
`
`
`
`CRD-5500 Manual (Ex. 1004)
`The CRD-5500 Manual describes the features and operation of the
`CRD-5500 SCSI RAID Controller. Ex. 1004, 9. In general, the CRD-5500
`RAID controller routes commands and data between hosts (i.e., initiators)
`and storage devices (i.e., targets) coupled to the controller. Id. at 9, 12.
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`Figure 1-2, as annotated by Petitioners, illustrates the architecture of the
`storage network in which the CRD-5500 RAID controller operates:
`
`
`Figure 1-2 shows the architecture of a network using the CRD-5500 with
`hosts attached to SCSI buses on one side of the controller and storage
`devices also attached to SCSI buses on the other side. Id. at 10–13.
`
`The CRD-5500 Manual describes a Host LUN (Logical Unit Number)
`Mapping feature that allows a user to assign redundancy groups to a
`particular host. Id. at 10. The logical unit number is the number that the
`host uses to address the drive. Id. at 18. A redundancy group is defined as
`each RAID (Redundant Array of Independent Disks) set or partition of a
`RAID set (i.e., storage space). Id. at 19. The CRD-5500 Manual describes
`that the Host LUN Mapping feature is part of the Monitor Utility included in
`the firmware of the controller. Id. at 40, 44. The CRD-5500 Manual
`includes a screen shot of the Monitor Utility’s Host LUN Mapping feature:
`
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`Id. at 44. This screen shot shows a table matching the various Host LUNs to
`different redundancy groups for the host on Channel 0 of a CRD-5500. Id.
`Each “host channel” corresponds to an I/O module that provides an external
`interface port for the CRD-5500. Id. at 21; Ex. 2027 ¶ 68.
`HP Journal
`
`Volume 47, issue 5 of the Hewlett-Packard Journal includes a number
`of articles that address the growing problem in 1997 of “I/O channels
`becom[ing] bottlenecks to system performance.” Ex. 1006, 5. Specifically,
`one article in the issue provides an introduction to the Fibre Channel I/O
`interface and describes it as “a flexible, scalable, high-speed data transfer
`interface that can operate over a variety of both copper wire and optical fiber
`at data rates up to 250 times faster than existing communications interfaces.”
`Id. at 94. The article additionally provides many reasons a Fibre Channel
`communication link is superior to a SCSI bus (e.g., longer distances and
`higher bandwidth, smaller connectors). Id. It further notes that SCSI
`commands may be “encapsulated and transported within Fibre Channel
`frames” to support existing storage hardware. Id. at 94–95.
`
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`The HP Journal describes a Fibre Channel protocol chip made by HP
`called “Tachyon.” Id. at 99–112. The article states that the Tachyon chip
`implements the Fibre Channel standard and “enables low-cost gigabit host
`adapters on industry-standard buses.” Id. at 101.
`Analysis
`
`1. Reason to Combine the CRD Manual and the HP Journal
`Applicable to all of the challenged claims, the Petition provides a
`
`detailed analysis of why a person of ordinary skill in the art would have been
`motivated to combine the CRD Manual and the HP Journal6 in the manner
`asserted by Petitioners. Pet. 17–21 (citing Ex. 1003 ¶¶ 48–57). Specifically,
`Petitioners contend: (1) the CRD Manual explains that the disclosed CRD-
`5500 controller has a modular design capable of accepting various I/O
`modules; (2) the HP Journal describes the benefits of FC technology over
`SCSI technology; (3) the HP Journal discloses the replacement of SCSI with
`FC, including the use of SCSI commands with FC frames. Id. For example,
`the HP Journal discusses various advantages of FC over SCSI as a transport
`medium technology, including advantages in bandwidth and addressability,
`and explains how some FC controllers are compatible with SCSI devices.
`Id.; see, e.g., Ex. 1006, 94–95, 99–101. Patent Owner does not dispute in its
`
`
`6 These portions of the HP Journal relied on by Petitioners share a common
`author (Meryem Primmer), and similar subject matter (FC technology and its
`implementation), as well as the same apparent publication date in the same
`issue of the journal. Patent Owner did not dispute that one of ordinary skill
`would have combined the teachings of the different articles in the HP
`Journal. Based on the full record after trial, we agree and consider the
`articles collectively, as the parties have done throughout the proceeding.
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`Patent Owner Response that a person of ordinary skill7 would have had
`reason to combine the teachings of these references.
`Based on the full record after trial, Petitioners have articulated a
`sufficient reason to combine the CRD Manual and the HP Journal with
`rational underpinnings supported by the evidence. See KSR Int’l Co. v.
`Teleflex Inc., 550 U.S. 398, 418 (2007) (citing In re Kahn, 441 F.3d 977,
`988 (Fed. Cir. 2006)).
`2.
`Claims 1–14, 16–33, 35–50, and 53
`
`
`a.
`Claim 1
`Petitioners explain how the CRD Manual and the HP Journal, in
`
`combination, render obvious each of the limitations of independent claim 1.
`Pet. 21–29; Pet. Reply 10–20. Petitioners contend the CRD Manual teaches
`a storage router, the CRD-5500 controller, which routes data between host
`computers (“a device”) and SCSI disk drives (“remote storage devices”).
`Pet. 22–23; Ex. 1004, 9–11. With respect to the “first controller operable to
`interface with a first transport medium, wherein the first transport medium is
`a serial transport medium,” Petitioners rely on teachings from the
`combination of the CRD Manual and the HP Journal, as follows. Pet. 23–
`24. First, the CRD Manual discloses multiple “I/O modules,” which
`interface with SCSI buses that connect to the hosts and the disk drives.
`Ex. 1004, 9, 21, 24, 32. Second, the HP Journal discusses the Tachyon FC
`controller chip, which enables interfacing with a high-speed FC connection.
`Ex. 1006, 101, 111. The HP Journal further discloses that the Tachyon
`controller is designed to be compatible with SCSI commands as well. Id.
`
`
`7 The level of ordinary skill in the art is reflected by the prior art of record.
`See Okajima v. Boudreau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).
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`at 101. Based on these disclosures and the testimony of their proffered
`expert, Dr. Andrew Hospodor, Petitioners argue:
`[T]he CRD-5500 Controller’s ability to accept different
`I/O modules that interface with different transport media
`to communicate with hosts, as taught by the CRD
`Manual, in view of the Fibre Channel I/O module and
`Fibre Channel transport medium (which is a serial
`transport medium), as taught by the HP Journal, render
`obvious ‘a first controller operable to interface with a
`first transport medium, wherein the first medium is a
`serial transport media’ as recited in the claim.
`Pet. 23–24 (citing Ex. 1003, 40–46).8 Dr. Hospodor explains that “one of
`ordinary skill in the art would have been motivated to replace the SCSI I/O
`host modules in the CRD-5500 RAID controller with a Fibre Channel I/O
`module based on the Tachyon chip.” Ex. 1004, 33.
`
`Next, the Petition identifies the central processor, system circuitry,
`and firmware disclosed in the CRD Manual as teaching the recited
`“processing device.” Pet. 24 (citing Ex. 1004, 9, 11, 21; Ex. 1003, 46–48).
`As to the requirements that the “processing device is configured to:
`maintain a map to allocate storage space . . . [and] control access . . . in
`accordance with the map,” Petitioners rely on the CRD Manual’s discussion
`of the Host LUN Mapping feature. Id. at 24–27. Specifically, the CRD
`Manual describes a feature of its Monitor Utility used to “map LUNs on
`
`8 Patent Owner argues that Dr. Hospodor’s testimony should be accorded
`“diminished” weight due to his alleged bias and certain deposition testimony
`that Patent Owner believes undermines his credibility. PO Resp. 55–59. All
`of these considerations were taken into account, and Dr. Hospodor’s
`testimony was accorded the weight appropriate in light of the full record.
`Further, we determine that Dr. Hospodor was a credible witness overall,
`despite the issues identified by Patent Owner, because his testimony
`generally was supported by the record as explained in this Decision.
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`each host channel to a particular redundancy group.” Ex. 1004, 44. A host
`channel corresponds to an I/O module, which is assigned to a host. Id. Each
`host channel has multiple LUNs, each of which can be mapped to a specific
`redundancy group. Id. Redundancy groups may be one or more disk drives,
`or partitions thereof. Id. at 19. Thus, Petitioners assert the CRD Manual
`teaches maintaining Host LUN Mapping settings that map hosts (the recited
`“devices”) and redundancy groups (the recited “remote storage devices”).
`Pet. 25 (citing Ex. 1003, 48–53). With respect to the processing device
`controlling access, Petitioners identify the CRD Manual’s discussion of
`using host LUN mapping settings to make certain redundancy groups
`available to certain host channels while blocking access to other host
`channels. Id. at 27 (citing Ex. 1004, 9, 44 Ex. 1003, 54–55).
`With respect to the limitation that “the processing device is configured
`to . . . allow access from devices connected to the first transport medium to
`the remote storage devices using native low level block protocol,”
`Petitioners cite the CRD Manual’s disclosure of using SCSI messages on
`host and drive channels, as well as the HP Journal’s disclosure of
`transmitting SCSI commands “encapsulated and transported within Fibre
`Channel frames.” Id. at 27–28 (citing Ex. 1004, 57; Ex. 1006, 94–95;
`Ex. 1003, 55–57; Ex. 1001, 5:59–63). Specifically, Petitioners assert that
`Thus, the CRD-5500 Controller allowing access from
`hosts to disk drives on a SCSI bus using SCSI I/O
`commands, as taught by the CRD Manual, in view of the
`encapsulation of SCSI I/O commands within Fibre
`Channel communications, as taught by the HP Journal,
`renders obvious “allow access from devices connected to
`the first transport medium to the remote storage devices
`using native low level, block protocol” as recited in the
`claim.
`
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`Id. at 28 (citing Ex. 1003, 55–57).
`
`Based on the full record after trial, we find that the combination of the
`CRD Manual and the HP Journal, as described above with Petitioners’
`citations and arguments, which we adopt, teach or suggest each limitation of
`claim 1 of the ’041 patent. Patent Owner’s counterarguments are
`unpersuasive.
`
`First, Patent Owner argues the asserted combination does not teach
`the “map” limitation of claim 1. PO Resp. 23–33; see also id. at 12–21
`(arguing the CRD Manual fails to teach mapping). According to Patent
`Owner, the CRD Manual fails to teach the recited mapping because the Host
`LUN Mapping feature only maps storage devices to host channels, not to the
`specific hosts themselves. Id. at 13–14, 23–27 (citing Ex. 2027 ¶¶ 53, 55,
`68, 75–76, 82, 84–86). This argument, however, relies on the overly narrow
`claim construction rejected above, and is unpersuasive as a result. For
`example, Patent Owner addresses Figure 1-2 of the CRD Manual, which is
`reproduced below:
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`Figure 1-2 of the CRD Manual depicts a configuration of the CRD-5500
`controller where each of four different hosts is assigned to a different
`channel, i.e., channel 0 through channel 3. Ex. 1004, 10. These hosts may
`then access redundancy groups via the CRD-5500 controller. Id.
`
`The specific configuration depicted in Figure 1-2 meets the mapping
`limitation because each host channel is dedicated to a single host—thus, in
`effect, mapping to a host channel is tantamount to mapping to a particular
`host. See Pet. Reply 12–13 (citing Ex. 1004, 44; Ex. 1025, 129:16–17). The
`CRD Manual explicitly refers to mapping to hosts and host channels
`interchangeably, whi