`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CROSSROADS SYSTEMS, INC.
`Patent Owner
`
`Case IPR2014-01177 (Patent 7 ,934,041)
`Case IPR2014-01197 (Patent 6,425,035)
`Case IPR2014-01207 (Patent 7,051,147)
`Case IPR2014-01233 (Patent 7,987,311)
`
`DECLARATION OF JANICE PAMPELL
`
`I, Janice Pampell, state and declare as follows:
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`1.
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`2.
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`I am a paralegal at Sprinkle IP Law Group (SIPLG).
`
`SIPLG submitted an information disclosure statement dated March 23, 2005.
`
`One of the disclosed references submitted to the Office was Cite No. C3,
`
`"CRD-5500, RAID DISK ARRAY CONTROLLER Product Insert, pp. 1-
`
`5." Below is a screen capture I took on October 28, 2014 from the USPTO's
`
`Patent Application Information Retrieval System (PAIR) evidencing the
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`reference in the file wrapper of Reexamination Control No. 90/007,125. Ex.
`
`2011 is a true and correct copy of the document submitted (without citation
`
`markings).
`
`1
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`(cid:20)(cid:3)(cid:82)(cid:73)(cid:3)(cid:25)
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` CROSSROADS EXHIBIT 2010
`Cisco Systems et al v Crossroads Systems, Inc.
` IPR2014-01544
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`
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`CRD-5500
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`RAID DISK AAAAY COMROLLER
`
`One~ again, CMD has raised the standard by which all other RAID controllers will be compared!
`CMO's CR0-5500 SCSI to SCSI RAID controller Is the industry's best solution for building high
`performance, high availability SCSI disk array subsystems. CMD's years of experience as an industry
`leader in high performance, advanced technology RAID controllers and SCSI host adapters for Unix,
`midrange, and PC systems has given CMD unmatched insight in designing a second-generation
`rliel, ~•r~u rnntrnllar cnl11tinn th:at :1llnwc;. OFMc;. VARc; ~nrf c;vc;tpmintPO~tn~ tn huild thP. best RAID
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`3.
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`During prosecution of Patent Application No. 10/658,163 which ultimately
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`issued as U.S. Patent No. 7,051,147, SIPLG submitted an information
`
`disclosure statement dated April 5, 2004. One of the disclosed references
`
`submitted to the Office was Cite No. C7, "CRD-5500, RAID DISK ARRAY
`
`CONTROLLER Product Insert, pp. 1-5." Below is a screen capture I took
`
`from PAIR on October 28, 2014 showing the reference in the file wrapper
`
`for Patent Application No. 10/658,163. Ex. 2011 is a true and correct copy
`
`of the document submitted (without citation markings).
`
`2
`
`(cid:21)(cid:3)(cid:82)(cid:73)(cid:3)(cid:25)
`
`
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`~ [TI Page No. 2
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`Non Patent Literature
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`
`Once again, CMD has raised lhe standard by which all olher RAID controllers will be compared!
`CM D's CRD·SSOO SCSI to SCSI RAID controller is lhe induslry's best solution for building high
`performance, high availability SCSI disk array subsystems. CMD's years of experience as an industry
`leader in high performance, advanced technology RAID controllers and SCSI host adapters for Unix,
`midrange, and PC systems has given CMD unmatched insight in designing a second-generation
`disk array controller solution that allows OEMs, VARs, and sys1em integrators to build the best RAID
`subsyslems available today.
`
`4.
`
`During prosecution of patent application No. 12/690,592, which ultimately
`
`issued as U.S. Patent No. 7,934,041, SIPLG submitted an information
`
`disclosure statement dated June 8, 2010. One of the disclosed references
`
`submitted to the Office was Cite No. C8, "CRD-5500, RAID DISK ARRAY
`
`CONTROLLER Product Insert, pp. 1-5". Below is a screen capture I took
`
`from PAIR on October 28, 2014 evidencing the reference in the file wrapper
`
`for patent application No. 12/690,592. The reference is marked C6 because
`
`the document was copied from another file for submission in 12/690,592.
`
`But, in such a case, it was our practice to include a divider indicating the
`
`3
`
`(cid:22)(cid:3)(cid:82)(cid:73)(cid:3)(cid:25)
`
`
`
`submission's number in the current matter (e.g., C8). Ex. 2011 is a true and
`
`correct copy of the document submitted (without citation markings).
`
`@.I https:.I'. 'ppoir.uspto.9ov/pairfview/BrowsePdfS.:vfotlobJ<ctkl:G9PFBWZWPPOPPYS&lan9= DINO
`
`Flllt: 12690592
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`of 5 pages [8 ~
`
`Non Patent Literature
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`~~~~~-:a-:-~~
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`RAID DISK ARRAY CONTROUER
`
`Once again, CMD has raised the standard by which all other RAID controllers will be compared!
`CMD's CRD-5500 SCSI to SCSI RAID controller Is the industry's best solution for building high
`performance, high availability SCSI disk array subsystems. CMD's years of experience as an industry
`leader in high performance, advanced technology RAID controllers and SCSI host adapters for Unix,
`midrange, and PC systems has given CMD unmatched insight in .designing a second-generation
`disk array controller solution that allows OEMs, VARs, and system integrators to build the best RAID
`subsystems available today.
`
`5.
`
`During prosecution of patent application No. 12/910,515, which ultimately
`
`issued as U.S. Patent No. 7,987,311 , SIPLG submitted an information
`
`disclosure statement dated December 15, 2010. One of the disclosed
`
`references submitted to the Office was Cite No. C8, "CRD-5500, RAID
`
`DISK ARRAY CONTROLLER Product Insert, pp. 1-5." Below is a screen
`
`capture I took from PAIR on October 28, 2014 evidencing the reference in
`
`the file wrapper for patent application No. 12/910 ,515. The reference is
`
`marked C6 because the document was copied from another file for
`4
`
`(cid:23)(cid:3)(cid:82)(cid:73)(cid:3)(cid:25)
`
`
`
`submission in 12/910,515. But, in such a case, it was our practice to include
`
`a divider indicating the submission' s number in the current matter (e.g., C8).
`
`Ex. 2011 is a true and correct copy of the document submitted (without
`
`citation markings).
`
`Ale: 12910515
`
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`RAID DIStC AAAAY COlll1ROUE~
`
`Once again, CMD has raised the standard by which all other RAID controllers will be compared!
`CM D's CRD-5500 SCSI to SCSI RAID controller is the industry's best solution for building high
`performance. high availability SCSI disk array subsystems. CMD's years of experience as an Industry
`leader in high performance, advanced technology RAID controllers and SCSI host adapters for Unix,
`midrange, and PC systems has given CMD unmatched insight in .designing a second -generation
`disk array controller solution that allows OEMs, VARs, and system integrators to build the best RAID
`subsystems available today.
`
`I declare under penalty of perjury under the laws of the United States of America
`
`that the foregoing is true and correct.
`
`5
`
`(cid:24)(cid:3)(cid:82)(cid:73)(cid:3)(cid:25)
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`
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`Executed on: October 29, 2014
`
`Janice ~pell
`
`6
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`(cid:25)(cid:3)(cid:82)(cid:73)(cid:3)(cid:25)
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`