Case 1:14-cv-00148-SS Document 53-2 Filed 09/08/14 Page 2 of 281
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
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`C.A. NO. 1:13-cv-00800-SS
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`C.A. NO. 1:13-cv-00895-SS
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`C.A. NO. 1:13-cv-01025-SS
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`C.A. NO. 1:14-cv-00148-SS
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`C.A. NO. 1:14-cv-00149-SS
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`C.A. NO. 1:14-cv-00150-SS
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`§§§§
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`§
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`§§§§
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`§
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`CROSSROADS SYSTEMS, INC.
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`
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`v.
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`DOT HILL SYSTEMS CORP.
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`CROSSROADS SYSTEMS, INC.
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`
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`v.
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`ORACLE CORPORATION
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`CROSSROADS SYSTEMS, INC.
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`v.
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`HUAWEI TECHS. CO., LTD., ET AL.
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`CROSSROADS SYSTEMS, INC.
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`v.
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`CISCO SYSTEMS, INC.
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`CROSSROADS SYSTEMS, INC.
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`v.
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`NETAPP, INC.
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`CROSSROADS SYSTEMS, INC.
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`v.
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`QUANTUM CORPORATION
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`DECLARATION OF RANDY KATZ REGARDING
`CLAIM CONSTRUCTION OF U.S. PATENT NOS.
`6,425,035, 7,051,147, 7,934,041, AND 7,987,311
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` CROSSROADS EXHIBIT 2033
` Cisco Systems et al v Crossroads Systems, Inc.
` IPR2014-01463
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`Table of Contents
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`Page
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`Qualifications ..................................................................................................................... 1
`Technology Background .................................................................................................... 3
`A.
`Storage Systems ..................................................................................................... 3
`B.
`Storage Interconnects and Controllers ................................................................... 5
`The Patents-in-Suit............................................................................................................. 8
`Summary of Opinions ...................................................................................................... 10
`A.
`Person of Ordinary Skill in the Art ...................................................................... 10
`B.
`“Map” / “Mapping” (’035, ’147, ’041, and ’311 Patents) ................................... 11
`C.
`“Remote” (’035, ’147, ’041, and ’311 Patents) ................................................... 23
`D.
`“Storage Router” (’035, ’147, ’041, and ’311 Patents) ........................................ 29
`E.
`“Supervisor Unit” (’035 and ’147 Patents) .......................................................... 34
`F.
`Patents) ................................................................................................................. 37
`Concluding Remarks ........................................................................................................ 40
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`“Interface Between” / “Interface With [A First Transport Medium]” /
`“Interface With [A Second Transport Medium] (’035, ’147, and ’041
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`I.
`II.
`III.
`IV.
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`V.
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`I, Randy H. Katz, declare as follows:
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`1.
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`I have been retained by Defendants Dot Hill Systems Corp., Oracle Corporation,
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`Huawei Technologies Co., Ltd., Huawei Enterprise USA, Inc., Huawei Technologies USA, Inc.,
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`Cisco Systems, Inc., NetApp, Inc., and Quantum Corporation (collectively “Defendants”) to
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`offer opinions regarding the meanings that certain claim terms in U.S. Patent Nos. 6,425,035 (the
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`“’035 patent”), 7,051,147 (the “’147 patent”), 7,934,041 (the “’041 patent”), and 7,987,311 (the
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`“’311 patent”) (collectively, the “Patents-in-Suit”) would have had to a person of ordinary skill
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`in the art at the time of the alleged invention in those patents. This declaration summarizes my
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`opinions relating to the issues addressed below.
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`I.
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`Qualifications
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`2.
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`I have studied, taught, and practiced computer science and engineering for over
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`forty years. I earned an A.B. in Computer Science from Cornell University in 1976, and a M.S.
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`and Ph.D. in Computer Science from University of California at Berkeley in 1978 and 1980,
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`respectively. I worked in private industry as a computer scientist from 1980-81, and served as an
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`assistant professor of computer science at the University of Wisconsin-Madison from 1981-83. I
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`served as the Program Manager and Deputy Director of the Computer Systems Technology
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`Office for the Advanced Research Projects Agency of the U.S. Department of Defense from
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`1993-94.
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`3.
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`I joined the faculty of the Computer Science Division of the Electrical
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`Engineering and Computer Sciences Department (EECS) of the University of California at
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`Berkeley in 1983, where I have been to this day. I became a full professor in 1989, and served as
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`the Chairman of the EECS Department from 1996-99. Since 1996, I have been the United
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`Microelectronics Corporation Distinguished Professor in Electrical Engineering and Computer
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`Science. My research interests have included high performance multiprocessor architectures and
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`protocols, storage architectures, transport protocols spanning heterogeneous networks, and
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`network and service architectures. I have taught and continue to teach courses that cover topics
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`relevant to storage systems and protocols, including advanced graduate seminars as well as
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`courses in undergraduate and graduate computer architecture and computer communications
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`networks.
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`4.
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`Beginning in the late 1980s, with colleagues at Berkeley, I developed the essential
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`framework for describing the tradeoff between reliability and performance in storage systems.
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`That work led to the creation and wide-spread adoption of Redundant Arrays of Inexpensive
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`Disks (RAID), which is still widely used today. In 1999, I along with two of my colleagues at
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`Berkeley won the IEEE Reynolds Johnson Storage System Award, the highest professional
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`recognition in the storage systems field, for our foundational work in and development of RAID.
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`I have also earned other honors and awards and have been recognized for my work in the field of
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`computer science and engineering. I am a Fellow of the Association for Computing Machinery
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`(ACM), the Institute of Electrical and Electronics Engineers (IEEE), American Association for
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`the Advancement of Science (AAAS), and American Society for Engineering Education
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`(ASEE). I am a member of the National Academy of Engineering (NAE), the highest
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`recognition that can be bestowed on an engineer in the United States, and the American
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`Academy of Arts and Sciences.
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`5.
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`I have published over 250 technical papers, book chapters, and books in the field
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`of computer science and engineering, including in the field of storage systems, in particular. I
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`authored the textbook entitled Contemporary Logic Design used at over 200 colleges and
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`universities. I have presented at numerous conferences on computer systems and networking,
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`including the keynote addresses of the IEEE International Conference on Distributed Computing
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`Systems and the International Conference on Networking Protocols. I serve and have served on
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`several government and university advisory boards and the technical advisory board of several
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`companies in the computer and storage field. I serve and have served as editor or referee for
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`several academic journals, such as ACM Transactions on Computer Systems and the NSF
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`Computer Engineering Section. I am also a named inventor on three U.S. storage-related
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`patents, Nos.: 5,195,100, 5,475,697, and 5,758,054 (“Non-volatile memory storage of write
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`operation identifier in data storage device”).
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`6.
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`Attached hereto as Exhibit 1 is a true copy of my curriculum vitae, which
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`provides a more complete description of my educational background, experience, publications
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`and other qualifications in the area of computer science, engineering, and storage systems.
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`II.
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`Technology Background
`
`A.
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`7.
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`Storage Systems
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`Generally speaking, storage allows information to persist on computer systems.
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`A storage system is based on technologies—such as magnetic or optical recording manifested in
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`terms of disks and tapes—that allow information to be retained for the long term.
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`8.
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`A disk drive does not usually interface with a host computer directly. At the very
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`least, an intermediary hardware component, called a disk controller, sits between a host computer
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`and the storage device, offloading from the former the details of managing the sequencing of
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`input/output operations. The host specifies an operation to “read” or “write” a sequence of
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`characters at a specified offset into a “logical” (virtual) device, i.e., the logical input/output
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`request. The disk controller is responsible for converting the logical request into detailed “seek”
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`and “transfer” operations at a “physical” level. Generally, given the mechanical overheads
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`associated with the operation of storage devices, they are not efficient at transferring a single
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`character (or byte) at a time. Rather, the device and the operations it supports operate in a natural
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`primitive unit of transfer to and from the device called a block. This is typically 512 bytes or
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`(small) multiples of this amount. Software layers within the operational software between an
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`application and the block-oriented interface to the storage device implement a device-
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`independent character-oriented access interface. The disk controller may also manage an
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`internal semiconductor cache, giving it additional freedom in deciding how to implement the
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`requests from the host.
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`9.
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`By the middle 1980s, the most prevalent high performance disk interface for
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`workstations and personal computers was Small Computer System Interface (SCSI, pronounced
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`“scuzzy”). By the early 1990s, SCSI had become the dominant storage interface. In the SCSI
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`specification, the disk controller initiates operations targeted for specific disks. The SCSI
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`interface is a message-based protocol, which allows individual disk drives to perform their own
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`seeks and transfers into and out of semiconductor memory buffers integrated with the disk.
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`Multiple disk drives can share a common signal pathway to the disk controller, called a SCSI
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`bus. It is called a bus because many devices can share it.
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`10.
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`Using 8- or 16-bit wide data paths, SCSI provides a high level operational
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`interface to storage devices. Devices are viewed as logical streams of bytes, within which an
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`operation can be positioned for the purposes of reading or writing. The bus protocol consists of a
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`sequence of initiating the operation, followed by the initiator disconnecting from the bus, with
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`the target device acquiring the bus when it has completed the requested operation, with a
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`subsequent transfer of data between initiator and target over the bus. These operations are
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`sufficiently generic that the same basic set can be used for magnetic disks, optical disks,
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`CDROMs, DVD, or magnetic tape devices. For example, on a SCSI read, the controller/initiator
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`sends a command to the disk/target with a request for a certain number of bytes from a specified
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`offset into the disk. The target executes this as a seek operation followed by a transfer into its
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`local memory. It then acquires the SCSI bus to transmit the read data back to the individual disk
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`controller.
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`11.
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`The SCSI protocol is sufficiently generic that it can also be used as a general
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`interface to a storage subsystem. As an alternative to placing the storage controller into the host
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`backplane, it is possible to use SCSI as the interface between the host and a storage subsystem.
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`In this configuration, a relatively simple SCSI controller is placed in the host backplane, and a
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`wider/faster version of SCSI is used than that normally deployed between a disk controller and
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`individual storage devices. SCSI as a method of storage device interconnection was well known
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`by the late 1980s. SCSI as a method to connect storage subsystems to multiple hosts, that is, to
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`connect aggregations of storage devices and controllers, was also well known by the early 1990s.
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`B.
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`12.
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`Storage Interconnects and Controllers
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`The various components of a computer system, including the storage system,
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`must be able to communicate with each other as well as with other computer systems. Hardware
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`mechanisms such as buses permit such communication across a short distance, such as within a
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`printed circuit board or within a rack of hardware. A bus is a single electrical pathway,
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`potentially made up of several parallel conductors, that is shared among several system hardware
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`components. Buses typically are associated with interconnection distances in the range of a few
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`meters. To communicate across a distance of tens or hundreds of meters, such as within a
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`computer machine room or within an office building, other interconnection technologies are
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`used, such as channels or local-area networks (LAN). A channel describes the signal carrying
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`pathway and operational protocols for interconnecting storage (and other input/output devices) to
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`a mainframe computer. LAN is a more general technology, in particular in the nature of the
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`protocols used, for interconnecting computers at a distance. Beyond the distance of a small
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`number of kilometers, wide-area network (WAN) technology is used. The distinction between
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`LAN and WAN is mainly in the different switching/signaling mechanisms and signal carrying
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`technologies used; the protocols remain largely the same.
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`13.
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`The computer systems found in the enterprise computing environment fall into
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`three broad categories: the personal computers (PC) or workstations to be found on the desks of
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`individual workers; the file servers managing documents and other electronic files shared by the
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`community of users; and the mainframe computers upon which major enterprise applications
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`(such as order entry or general ledger applications built on top of sophisticated database systems)
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`are executing. Enterprise computing exhibits a mixture of all three kinds of machines. The
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`software systems and methods of storage system attachment in computer systems may be
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`radically different in these machine classes.
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`14.
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`By the 1990s, systems that provided a host computer access to storage across a
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`computer network were well known. The concept behind the file server model—a network-
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`connected subsystem allowing stored data to be shared among many client machines—had long
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`been embraced by storage system architects. In the early 1990s, storage system architectures
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`arose that made use of standard storage system interconnects, such as SCSI, to attach multiple
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`host computers to a shared storage system through a single storage controller. The controller in
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`turn made use of such interconnections to interface storage devices directly to the controller.
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`15.
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`Typically, there are two alternative ways to interconnect computers to shared
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`storage across a network: through the storage system via a storage area network (SAN); or
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`through a more general LAN or WAN. SAN emerged as a storage architecture based on a
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`switched serial interconnection between hosts and the storage controller. SAN is an architecture
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`that allows a storage subsystem to be shared among multiple mainframe host computers by
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`providing multiple channel interfaces. The storage subsystem provides the illusion of a
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`collection of logical units to the hosts to which it is attached. It is responsible for mapping
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`block-level input-output operations presented by the host on logical devices into input-output
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`operations against the actual physical devices attached to the storage subsystem.
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`16.
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`SAN provides direct and local area interconnection to a large-scale storage
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`controller using interconnection technologies evolved from mainframe channel technology. The
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`mainframe may use either proprietary or open system interconnections. An example of the
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`former is Enterprise Storage Connection (ESCON), developed for IBM mainframes. Fibre
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`Channel (FC) is an example of the latter, intended for vendor-independent interconnections
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`among a broader category of machines and subsystems. The technology of FC was developed in
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`the late 1980s and standardized by the early 1990s as a higher bandwidth and longer distance
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`method of interconnection. A SAN can be constructed from FC links and switches that
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`interconnect hosts to a shared storage controller.
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`17.
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`By the 1990s, there were storage controllers that served as an intermediary
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`between potentially many host machines (i.e., workstations/PCs) and potentially many disk
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`drives. Modern storage controllers support multiple host interfaces, each based on optical
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`interconnections, allowing the storage resource to be shared among many host machines in a
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`SAN. Such storage controllers export to the attached hosts a logical image of the disk drives
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`under the storage controller’s control. The logical images are often called logical units, and may
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`be assigned a Logical Unit Number (LUN). The controller assigns these logical images onto the
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`attached physical drives that are divided into physical extents (i.e., a contiguous region of
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`physical disk) and physical blocks. The host “sees” a logical drive divided into logical extents
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`each consisting of a sequence of logical blocks. A SAN-attached subsystem looks like a
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`collection of logical devices to the hosts to which it is attached; the host machines are
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`responsible for constructing a file system on top of these logical devices.
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`18.
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`Controllers can include buffer memories, providing a mechanism for operational
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`speed matching and asynchronous decoupling between host and storage. For example, if writes
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`come in a short burst from the host at speeds faster than the storage devices can handle them,
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`they could be placed in the buffer memory, waiting to be staged to disk. Likewise, if data comes
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`back from disk at a faster rate than the host can manage, the data can be held in the buffer until
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`the host is ready to accept it.
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`III. The Patents-in-Suit
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`19.
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`The four Patents-in-Suit share the same title (“Storage Router and Method for
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`Providing Virtual Local Storage”), named inventors, and specification. The ’035 patent was
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`filed September 27, 2001 and issued July 23, 2002. The ’147 patent was filed September 9, 2003
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`and issued May 23, 2006. The ’041 patent was filed January 20, 2010 and issued April 26, 2011.
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`The ’311 patent was filed October 22, 2010 and issued July 26, 2011. All four of the Patents-in-
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`Suit are continuations of the application that issued as U.S. Patent No. 5,941,972 (“the “’972
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`patent,” which was filed December 31, 1997).
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`20.
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`The common specification of the Patents-in-Suit purports to describe the
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`invention of a “storage router” that “is a bridge device that connects a Fiber Channel link directly
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`to a SCSI bus and enables the exchange of SCSI command set information between application
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`clients on SCSI bus devices and the Fiber Channel links.” E.g., the ’035 patent, 5:34-38. As
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`depicted in Figure 3 of the specification, “a Fiber Channel high speed serial interconnect 52 and
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`a SCSI bus 54 [are] bridged by a storage router 56. Storage router 56 of FIG. 3 provides for a
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`large number of workstations 58 to be interconnected on a common storage transport and to
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`access common storage devices 60, 62 and 64 through native low level, block protocols.” E.g.,
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`id. at 3:64-4:6. The storage router implements “controls and routing such that each workstation
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`58 can have access to a specific subset of the overall data stored in storage devices 60, 62 and 64.
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`This specific subset of data has the appearance and characteristics of local storage and is referred
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`to herein as virtual local storage.” E.g., id. at 4:7-13. The storage router “combines access
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`control with routing such that each workstation 58 has controlled access to only the specified
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`partition of storage device 62 which forms virtual local storage for the workstation 58.” E.g., id.
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`at 4:7-13.
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`21.
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`Further, according to a disclosed embodiment, the storage router maintains a
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`“configuration” that “maps between” workstations connected to a Fiber Channel and SCSI
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`storage devices connected to a SCSI bus and that “implements access controls for storage space”
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`on the SCSI storage devices. E.g., id. at 2:19-22. The storage router then allows access from
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`Fiber Channel initiator devices to SCSI storage devices using native low level, block protocol “in
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`accordance with” the configuration or mapping. E.g., id. at 2:12-14, 2:19-26. “This can be
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`implemented to allow all generic FCP [Fibre Channel Protocol] and SCSI commands to pass
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`through the storage router to address attached devices.” E.g., id. at 7:19-21. The specification
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`claims that the benefit of this is to “centralize local storage for networked workstations without
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`any cost of speed or overhead,” where the storage devices “can be located in a significantly
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`remote position.” E.g., id. at 2:27-33.
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`IV.
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`Summary of Opinions
`
`A.
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`22.
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`Person of Ordinary Skill in the Art
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`I have been asked to consider the level of ordinary skill in the art at the time of the
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`patent. I understand that a person of ordinary skill is a hypothetical person ordinarily (as
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`opposed to expertly) skilled in the art relating to the subject matter of the invention and who is
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`presumed to be aware of all pertinent prior art.
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`23.
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`As described above, the subject matter of the Patents-in-Suit involves storage
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`system architectures. It is my opinion therefore that someone of ordinary skill in the field at the
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`time of the Patents-in-Suit likely would be an engineer with experience equivalent to an
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`undergraduate degree in electrical engineering, computer science, or computer engineering, with
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`two years of industrial experience designing and implementing hardware and software for
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`storage subsystems.
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`24. My opinion as to the level of ordinary skill in the art is based upon my personal
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`knowledge and experience, and my consideration of such things as the level of education and
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`experience of persons of skill working in the field, the sophistication of the technology, and the
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`rapidity with which innovations are made in this field.
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`25.
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`I have been informed that the plaintiff alleges that the asserted claims of the
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`Patents-in-Suit were conceived as early as May 1997. I have considered the level of ordinary
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`skill in the art at the time in and around that date as well as the filing dates of the Patents-in-Suit
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`and the applications to which the Patents-in-Suit allegedly claim priority, and my opinions are
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`the same regardless of which date is the appropriate priority date. Moreover, regardless of which
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`date is chosen, I personally had at least the level of ordinary skill in the art at that time.
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`B.
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`26.
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`“Map” / “Mapping” (’035, ’147, ’041, and ’311 Patents)
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`It is my opinion that one of ordinary skill in the art would understand the term
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`“map” / “mapping” as used in all of the claims of the Patents-in-Suit to refer to creating a
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`designated path for block-level communications from a device on one side of the storage router
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`to a remote storage device on the other side of the router. I also agree that a “map,” as used in
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`the claims of the Patents-in-Suit, contains a representation of devices on each side of the storage
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`router, so that when a device on one side of the storage router wants to communicate via block-
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`level communications with a device on the other side of the storage router, the storage router can
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`designate a path to connect the devices by routing requests and data between the devices.
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`Specifically, as discussed below, it is my opinion that “map” / “mapping” as claimed in the
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`Patents-in-Suit requires at least three aspects: (1) a designated path, i.e., a path that is established
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`and known by the storage router prior to controlling access requests; (2) the path is specified for
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`block-level communications, i.e., data and commands are addressed to the block-level location
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`on the target device; and (3) the path enables the storage router to route requests and data
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`between the devices, i.e., pass requests and data from a device on one side of the storage router
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`through to a device on the other side of the storage router.
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`27.
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`First, it is my opinion that the “map” referred to in the claims of the Patents-in-
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`Suit comprises a set of designated path(s) between each host device on one side of the storage
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`router and, on the other side of the storage router, the particular remote storage device(s) to
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`which the host device has access. The paths in the map must be designated so as to enable the
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`storage router to route and control access from host devices to storage devices in accordance
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`with the map. Put differently, one of ordinary skill in the art at the time of the Patents-in-Suit
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`would not understand the term “map” / “mapping” in the claims to refer to a path that is not
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`designated, is only transiently designated for each access request, or is designated only after each
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`access request is received by the storage router, because one of ordinary skill in the art would
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`understand that the storage router cannot control access from hosts to remote storage devices in
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`accordance with the map, as required by the claims, unless the path from host to remote storage
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`device in the map is designated prior to the time that the access is requested.
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`28. My opinion is based in part on the claim language itself. For example, the
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`apparatus claims of the ’035 patent all require a storage router “operable to map between”
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`“devices” or “workstations” “connected to” a “first transport medium,” on the one hand, and
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`“remote” “storage devices” “connected to” a “second transport medium,” on the other hand.
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`E.g., ’035 patent, claims 1 & 7. The plain language of the claims and the context of the other
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`claim language makes clear that this “map” is intimately linked to the other requirements of the
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`claims, namely to allow the storage router “to implement access controls for storage space on the
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`storage devices” and to “allow access from devices [or workstations] connected to the first
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`transport medium to the storage devices” on the “second transport medium” “in accordance with
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`the mapping.” E.g., id. Similarly, the method claims of the ’035 patent require performing a
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`step of “mapping between devices connected to the first transport medium,” on the one hand, to
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`“storage devices connected to another transport medium,” on the other hand. E.g., ’035 patent,
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`claim 11. The context of the other claim language further establishes that “mapping” is a
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`prerequisite for “implementing access controls for storage space on the storage devices” and
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`“allowing access from devices connected to the first transport medium to the storage devices,” as
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`required by the claims. E.g., id. The same is true of all of the other claims of the Patents-in-Suit.
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`See, e.g., ’147 patent, claims 1, 6, 10 & 34 (requiring a “configuration for remote storage devices
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`connected to [a] second Fibre Channel transport medium” “that maps between” “Fibre Channel
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`initiator devices” and the remote storage devices and “that implements access controls,” in order
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`“to allow access from” the initiator devices to the remote storage devices “in accordance with the
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`configuration”); id., claims 21 & 28 (requiring an “access control device operable to” “map
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`between” “at least one device connected to [a] first transport medium” and “storage space on”
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`“at least one storage device connected [a] second transport medium,” in order to “control access
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`from the at least one device to the at least one storage device…in accordance with the map”);
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`’041 patent, claims 1, 20 & 37 (requiring “maintain[ing] a map to allocate storage space on []
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`remote storage devices to devices connected to [a] first transport medium by associating
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`representations of the devices connected to the first transport medium with representations of
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`storage space on the remote storage devices,” in order to “control access from the devices
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`connected to the first transport medium to the storage space on the remote storage devices in
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`accordance with the map”).
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`29.
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`In sum, the plain language and context of the claims confirm that the storage
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`router must “maintain” a “map” that contains a specific “association” between host devices on
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`one side of the storage router and particular remote storage devices on the other side of the
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`storage router, so that the storage router can “allow” and “control” “access” between the devices
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`“in accordance with” the “map.” One of ordinary skill in the art at the time of the Patents-in-Suit
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`therefore would understand from such claim language and context that to “map” requires
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`specifying a designated path between the host devices and remote storage devices. One of
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`ordinary skill in the art at the time furthermore would understand that, in order for the storage
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`router to “allow” and “control” access “in accordance with” such a map, such paths must be
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`fixed and known by the storage router prior to performing any such access control.
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`30. My opinion is also based on the shared specification of the Patents-in-Suit. The
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`specification describes the “map” as designated paths between the host devices and remote
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`storage devices that permit the storage router to control access “in accordance with” the map.
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`See, e.g., ’035 patent, 2:8-13 (“The storage router maps between the workstations and the SCSI
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`storage devices and implements access controls for storage space on the SCSI storage devices.
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`The storage router then allows access from the workstations to the SCSI storage devices…in
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`accordance with the mapping.”); id. at 2:19-26 (“A configuration is maintained for SCSI storage
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`devices connected to the SCSI bus transport medium. The configuration maps between Fiber
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`Channel devices and the SCSI storage devices….Access is then allowed from Fiber Channel
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`initiator devices to SCSI storage devices…in accordance with the configuration.”). The
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`specification confirms that, to do so, the map must designate the path from each host to the
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`particular storage device, or portion thereof, to which that host has access. See, e.g., ’035 patent,
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`8:67-9:3 (“The storage router can use tables to map, for each initiator, what storage access is
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`available and what partition is being addressed by a particular request.”).
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`31.
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`The specification states that the purpose of providing the map is to allow the
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`centralized control and administration of storage space using the storage router. See, e.g., ’035
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`patent, 2:34-35 (A “technical advantage of the present invention is the ability to centrally control
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`and administer storage space.”); id. at 4:13-16 (“Storage router 56 allows the configuration and
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`modification of the storage allocated to each attached workstation 58 through the use of mapping
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`tables or other mapping techniques.”); id. at 4:48-51 (“Storage router 56 provides centralized
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`control of what each workstation 58 sees as its local drive, as well as what data it sees as global
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`data accessible by other workstations 58.”). As discussed further below, a person of ordinary
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`skill in the art at the time wou