Case 1:13-cv-00800-SS Document 105-1 Filed 02/23/15 Page 1 of 9
`SPECIAL MASTER’S RECOMMENDED CONSTRUCTIONS FOR PATENT NO.’s
`6,425,035, 7,051,147, 7,934, 041 & 7,987,311
`
`
`
`Claim Term
`
`Special Master’s
`Recommendation
`
`
`Defined by the
`remainder of the
`claim and does not
`require further
`construction.
`
`
`Defendants’
`Proposed
`Construction
`
` A
`
` device that routes
`storage requests from
`initiator
`devices/workstations
`on one transport
`medium to target
`storage devices on the
`other transport
`medium and routes
`data between the
`initiator
`devices/workstations
`and target storage
`devices.
`
`Crossroads’
`Proposed
`Construction
`
`Defined by the
`remainder of the
`claim and does not
`require further
`construction.
`
`
`
`Indirectly connected
`through at least one
`serial network
`transport medium.
`
`
`
`Indirectly connected
`through at least one
`serial network
`transport medium.
`
`
`
`Indirectly connected
`through a storage
`router to enable
`network connections
`from [devices/Fibre
`Channel initiator
`devices/workstations]
`to storage devices at a
`distance greater than
`allowed by a
`conventional parallel
`interconnect.
`
`
` CROSSROADS EXHIBIT 2034
` Cisco Systems et al v Crossroads Systems, Inc.
` IPR2014-01544
`
`1
`1 of 9
`
`
`Storage Router
`(Page 1 of attached SM
`CC Chart)
`
`’035 Patent:
`1, 2, 3, 4, 5, 6, 7, 10
`
`’041 Patent:
`1, 2, 3, 4, 5, 6, 7, 8, 9,
`10, 11, 12, 13, 14, 15,
`16, 17, 18, 19, 20, 24,
`25, 26, 30, 32, 35, 37,
`41, 42, 43, 47, 49, 52,
`53
`
`’147 Patent:
`1, 2, 3, 4, 5, 6, 9
`
`’311 Patent:
`1, 2, 3, 4, 5, 6, 7, 8, 9,
`10, 11, 12, 13, 14, 15,
`16, 20, 21, 24, 25, 28
`
`
`Remote
`(Page 26 of attached SM
`CC Chart)
`
`’035 Patent:
`1, 11
`
`’041 Patent:
`1, 2, 3, 4, 7, 12, 13,
`19, 20, 21, 22, 23, 26,
`31, 32, 37, 38, 39, 40,
`43, 48, 49, 53
`
`’147 Patent:
`1, 4, 10, 13, 14, 15,
`17, 18, 19, 21, 28, 34
`
`’311 Patent:
`1, 5, 9, 16, 19, 21, 25
`
`
`

`
`Case 1:13-cv-00800-SS Document 105-1 Filed 02/23/15 Page 2 of 9
`Claim Term
`Crossroads’
`Defendants’
`Special Master’s
`Proposed
`Proposed
`Recommendation
`Construction
`Construction
`
`
`Any storage device,
`An electronic device
`including, for
`that stores data,
`example, a tape drive,
`including for
`CD-ROM drive, an
`example, a tape drive,
`optical drive or a hard
`CD-ROM drive, an
`disk drive.
`optical drive or a hard
`
`disk drive.
`
`
`Any storage device,
`including, for
`example, a tape drive,
`CD-ROM drive, an
`optical drive or a hard
`disk drive.
`
`
`
`Storage Device(s)
`(Page 45 of attached SM
`CC Chart)
`
`’035 Patent:
`1, 4, 7, 9, 10, 11, 12,
`14
`
`’041 Patent:
`1, 2, 3, 4, 7, 12, 13,
`19, 20, 21, 22, 23, 26,
`31, 32, 37, 38, 39, 40,
`43, 48, 49, 53
`
`’147 Patent:
`1, 4, 6, 8, 9, 10, 13,
`14, 15, 17, 18, 19, 21,
`22, 24, 25, 26, 28, 29,
`31, 32, 33, 34, 35, 36,
`37, 38
`
`’311 Patent:
`1, 5, 9, 16, 19, 21, 25
`
`
`Interface between;
`Interface with a
`[first transport
`medium]; and
`interface with [a
`second transport
`medium]
`(Page 47 of attached SM
`CC Chart)
`
`’035 Patent:
`1, 10
`
`’041 Patent:
`1
`
`’147 Patent:
`1, 9, 14, 21
`
`’311 Patent:
`{None}
`
`
`
`
`Does not require
`construction.
`
`
`
`Directly connect with
`/ directly connect
`between
`
`
`Does not require
`construction.
`
`
`2
`
`2 of 9
`
`

`
`Case 1:13-cv-00800-SS Document 105-1 Filed 02/23/15 Page 3 of 9
`Claim Term
`Crossroads’
`Defendants’
`Special Master’s
`Proposed
`Proposed
`Recommendation
`Construction
`Construction
`
`The phrase “transport
`medium” has the plain
`and ordinary meaning
`as understood by a
`person of skill in the
`art. The “second
`[Fibre Channel]
`transport medium” is
`physically separate
`from the “first [Fibre
`Channel] transport
`medium.”
`
`
`The phrase “transport
`medium” has the plain
`and ordinary meaning
`as understood by a
`person of skill in the
`art. The “second
`[Fibre Channel]
`transport medium” is
`physically separate
`from the “first [Fibre
`Channel] transport
`medium.”
`
`‘
`The phrase “transport
`medium” has the plain
`and ordinary meaning
`as understood by a
`person of skill in the
`art. The “second
`[Fibre Channel]
`transport medium” is
`physically separate
`from the “first [Fibre
`Channel] transport
`medium.”
`
`
`The phrase “transport
`medium” has the plain
`and ordinary meaning
`as understood by a
`person of skill in the
`art. The “second
`[Fibre Channel]
`transport medium” is
`physically separate
`from the “first [Fibre
`Channel] transport
`medium.”
`
` A
`
` second
`communications link
`that is physically
`separate from the first
`transport medium.
`
`
`3
`
` A
`
` first
`communications link.
`
`
`First Transport
`Medium / First
`[Fibre Channel]
`Transport Medium
`(Page 68 of attached SM
`CC Chart)
`
`’035 Patent:
`1, 2, 5, 7, 10, 11, 12,
`13
`
`’041 Patent:
`1, 2, 4, 6, 7, 10, 11,
`13, 14, 16, 19, 20, 21,
`23, 25, 26, 29, 30, 32,
`33, 35, 36, 37, 38, 40,
`42, 43, 46, 47, 49, 50,
`52, 53
`
`’147 Patent:
`1, 6, 9, 10, 14, 18, 21,
`28, 34
`
`’311 Patent:
`1, 5, 7, 8, 9, 10, 12,
`15, 16, 19, 21, 23, 24,
`25, 26, 28
`
`Second Transport
`Medium / Second
`[Fibre Channel]
`Transport Medium
`(Page 71 of attached SM
`CC Chart)
`
`’035 Patent:
`1, 6, 7, 10, 11
`
`’041 Patent:
`19, 20, 36, 53
`
`’147 Patent:
`1, 6, 9, 10, 14,
`21, 28, 34
`
`’311 Patent:
`1
`
`
`3 of 9
`
`

`
`Case 1:13-cv-00800-SS Document 105-1 Filed 02/23/15 Page 4 of 9
`Claim Term
`Crossroads’
`Defendants’
`Special Master’s
`Proposed
`Proposed
`Recommendation
`Construction
`Construction
`
` A
`
` processing device
`that controls operation
`of the storage router,
`including handling
`mapping and access
`controls.
`
`
`
` A
`
` device comprising
`at least: (1) a
`microprocessor,
`incorporating
`independent data and
`program memory
`spaces; and (2)
`associated logic
`required to implement
`a standalone
`processing system and
`programmed to
`process data in a
`buffer in order to map
`between devices and
`which implements
`access controls.
`
`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.
`
`
` A
`
` device comprising
`at least: (1) a
`microprocessor,
`incorporating
`independent data and
`program memory
`spaces; and (2)
`associated logic
`required to implement
`a standalone
`processing system and
`programmed to
`process data in a
`buffer in order to map
`between devices and
`which implements
`access controls.
`
`To create a known
`path for block-
`addressed data and
`commands from a
`particular device on
`one side of the storage
`router to a particular
`remote physical
`storage device on the
`other side of the
`router. A “map”
`contains a
`representation of the
`particular devices on
`each side of the
`storage router, so that
`before a particular
`workstation/device on
`one side of the storage
`router tries to
`communicate with a
`particular remote
`physical storage
`device on the other
`side of the storage
`router, the storage
`router already has
`stored a path from the
`
`
`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.
`
`
`
`Supervisor Unit
`(Page 74 of attached SM
`CC Chart)
`
`’035 Patent:
`1, 2, 10
`
`’041 Patent:
`{None}
`
`’147 Patent:
`1, 2, 9, 14, 15, 17, 19,
`34, 35, 38
`
`’311 Patent:
`{None}
`
`
`Map/Mapping
`(Page 78 of attached SM
`CC Chart)
`
`’035 Patent:
`1, 7, 10, 11
`
`’041 Patent:
`1, 2, 4, 5, 6, 9, 16, 20,
`21, 23, 24, 25, 28, 35,
`37, 38, 40, 41, 42, 45,
`52
`
`’147 Patent:
`1, 6, 9, 10, 14, 15, 16,
`17, 21, 22, 23, 24, 28,
`29, 30, 31, 34, 35, 36
`
`’311 Patent:
`1, 4, 6, 12, 16, 19, 20,
`22, 28
`
`
`
`
`
`4
`
`4 of 9
`
`

`
`Case 1:13-cv-00800-SS Document 105-1 Filed 02/23/15 Page 5 of 9
`Claim Term
`Crossroads’
`Defendants’
`Special Master’s
`Proposed
`Proposed
`Recommendation
`Construction
`Construction
`particular
`workstation/device to
`the particular remote
`physical storage
`device over which the
`storage router will
`route block-addressed
`requests and data
`between the devices.
`
`Provide/providing
`controls that limit a
`[device/Fibre Channel
`initiator
`device/workstation]’s
`access to a specific
`subset of storage
`devices or sections of
`a single storage
`device according to a
`map for the
`[device/Fibre Channel
`initiator
`device/workstation].
`
`
`Provides controls
`which limit a
`[device/Fibre Channel
`initiator
`device/workstation]’s
`access to a specific
`subset of storage
`devices or sections of
`a single storage
`device according to a
`map.
`
`
`
`Provides controls
`which limit a
`[device/Fibre Channel
`initiator
`device/workstation]’s
`access to a specific
`subset of storage
`devices or sections of
`a single storage
`device according to a
`map.
`
`
`
`Implement(ing)
`(s) access controls
`for storage space on
`the (remote) storage
`devices
`(Page 113 of attached SM
`CC Chart)
`
`’035 Patent:
`1, 7, 10, 11
`
`’041 Patent:
`{None}
`
`’147 Patent:
`1, 6, 9, 10, 28
`
`’311 Patent:
`{None}
`
`Access Controls
`(Page 117 of attached SM
`CC Chart)
`
`’035 Patent:
`1, 7, 8, 10, 11
`
`’041 Patent:
`{None}
`
`’147 Patent:
`1, 6, 7, 9 10, 28, 34
`
`’311 Patent:
`{None}
`
`
`
`
`Controls which limit a
`[device/Fibre Channel
`initiator
`device/workstation]’s
`access to a specific
`subset of storage
`devices or sections of
`a single storage
`device according to a
`map.
`
`
`Controls which limit a
`[device/Fibre Channel
`initiator
`device/workstation]’s
`access to a specific
`subset of storage
`devices or sections of
`a single storage
`device according to a
`map for the
`[device/Fibre Channel
`initiator
`device/workstation].
`
`
`Controls which limit a
`[device/Fibre Channel
`initiator
`device/workstation]’s
`access to a specific
`subset of storage
`devices or sections of
`a single storage
`device according to a
`map.
`
`
`
`5
`
`5 of 9
`
`

`
`Case 1:13-cv-00800-SS Document 105-1 Filed 02/23/15 Page 6 of 9
`Claim Term
`Crossroads’
`Defendants’
`Special Master’s
`Proposed
`Proposed
`Recommendation
`Construction
`Construction
`
`
`Permit access using
`To allow native low
`the native low level,
`level block protocol
`block protocol of the
`requests to be routed
`virtual local storage
`from the
`without involving a
`[devices/Fibre
`translation from high
`Channel initiator
`level network
`devices/workstations]
`protocols to a native
`to the remote storage
`low level block
`devices.
`protocol request.
`
`
`Permit access using
`the native low level,
`block protocol of the
`virtual local storage
`without involving a
`translation from high
`level network
`protocols to a native
`low level block
`protocol request.
`
`
`
`
`
`
`Allow(ing) Access . .
`. Using NLLBP
`(Page 121 of attached SM
`CC Chart)
`
`’035 Patent:
`1, 7, 11
`
`’041 Patent:
`1, 20, 37
`
`’147 Patent:
`1, 6, 10, 28
`
`’311 Patent:
`{None}
`
`Allow(ing) Access . .
`. Using NLLBP
`(Page 147 in SM CC
`Charts)
`
`’035 Patent:
`1, 7, 10, 11
`
`’041 Patent:
`1, 20, 37
`
`’147 Patent:
`1, 6, 10, 28
`
`’311 Patent:
`{None}
`
`Control access from
`the [at least one]
`device . . . to the [at
`least one] remote
`storage device . . .
`using native low
`level, block protocols
`according to a map
`(Page 149 of attached SM
`CC Chart)
`
`’035 Patent:
`{None}
`
`
`
`
`Permit access using
`the native low level,
`block protocol of the
`virtual local storage
`without involving a
`translation from high
`level network
`protocols to a native
`low level block
`protocol request.
`
`
`
`See Defendants’
`proposed construction
`for “allow access …”
`set forth above in
`connection with the
`‘035 Patent.
`
`
`Permit access using
`the native low level,
`block protocol of the
`virtual local storage
`without involving a
`translation from high
`level network
`protocols to a native
`low level block
`protocol request.
`
`
`
`Limit a device’s
`access to a specific
`subset of storage
`devices or sections of
`a single storage
`device according to a
`map using the native
`low level, block
`protocol of the virtual
`local storage without
`involving a translation
`from high level
`network protocols to a
`
`
`Limit a device’s
`access to the storage
`space on the [at least
`one] remote storage
`device according to a
`map for the device by
`limiting the routing of
`native low level,
`block protocol
`requests and data
`from the device to the
`[at least one] remote
`storage device.
`6
`
`
`Limit a device’s
`access to a specific
`subset of storage
`devices or sections of
`a single storage
`device according to a
`map using the native
`low level, block
`protocol of the virtual
`local storage without
`involving a translation
`from high level
`network protocols to a
`
`6 of 9
`
`

`
`Case 1:13-cv-00800-SS Document 105-1 Filed 02/23/15 Page 7 of 9
`Claim Term
`Crossroads’
`Defendants’
`Special Master’s
`Proposed
`Proposed
`Recommendation
`Construction
`Construction
`native low level block
`protocol request.
`
`
`native low level block
`protocol request.
`
`
`
`’041 Patent:
`{None}
`
`’147 Patent:
`14, 21
`
`’311 Patent:
`{None}
`
`LUN
`(Page 166 of attached SM
`CC Chart)
`
`’035 Patent:
`{None}
`
`’041 Patent:
`{None}
`
`’147 Patent:
`15, 16, 17, 22, 23, 24,
`29, 30, 31,36
`
`’311 Patent:
`1, 2, 9, 16, 17, 18, 25
`
`Implement access
`controls according to
`the configuration for
`storage space on the
`storage device using
`native low level
`block protocols
`(Page 167 of attached SM
`CC Chart)
`
`’035 Patent:
`{None}
`
`’041 Patent:
`{None}
`
`’147 Patent:
`34
`
`’311 Patent:
`{None}
`
`
`
`Plain and ordinary
`meaning to one of
`ordinary skill in the
`art. (By agreement
`between Plaintiff and
`Defendants).
`
`
`Plain and ordinary
`meaning to one of
`ordinary skill in the
`art. (By agreement
`between Plaintiff and
`Defendants).
`
`
`Plain and ordinary
`meaning to one of
`ordinary skill in the
`art. (By agreement
`between Plaintiff and
`Defendants).
`
`
`Provide controls that
`limit the host device’s
`access to the storage
`space on the storage
`device according to a
`map for the host
`device by limiting the
`routing of native low
`level, block protocol
`requests and data
`from the host device
`to the storage device.
`
`
`Provides controls
`which limit a device’s
`access to a specific
`subset of storage
`devices or sections of
`a single storage
`device according to a
`map using the native
`low level, block
`protocol of the virtual
`local storage without
`involving a translation
`from high level
`network protocols to a
`native low level block
`protocol request.
`
`
`
`Provides controls
`which limit a device’s
`access to a specific
`subset of storage
`devices or sections of
`a single storage
`device according to a
`map using the native
`low level, block
`protocol of the virtual
`local storage without
`involving a translation
`from high level
`network protocols to a
`native low level block
`protocol request.
`
`
`7
`
`7 of 9
`
`

`
`Case 1:13-cv-00800-SS Document 105-1 Filed 02/23/15 Page 8 of 9
`Claim Term
`Crossroads’
`Defendants’
`Special Master’s
`Proposed
`Proposed
`Recommendation
`Construction
`Construction
`
`
`Limit a device’s
`Limit/limiting a
`access to a specific
`device’s access to a
`subset of storage
`specific subset of
`devices or sections of
`storage devices or
`a single storage
`sections of a single
`device according to a
`storage device
`map.
`according to the map
`
`for the device..
`
`
`Limit a device’s
`access to a specific
`subset of storage
`devices or sections of
`a single storage
`device according to a
`map.
`
`
`
`Control/controlling
`access from the
`devices . . . to the
`storage space on the
`remote storage
`devices in
`accordance with the
`map
`(Page 185 of attached SM
`CC Chart)
`
`’035 Patent:
`{None}
`
`’041 Patent:
`1, 20, 37
`
`’147 Patent:
`{None}
`
`’311 Patent:
`1, 16
`
`
`In a manner [that is]
`transparent to [. . .]
`the devices
`(Page 189 of attached SM
`CC Chart)
`
`’035 Patent:
`{None}
`
`’041 Patent:
`10, 16, 29, 35, 46, 52
`
`’147 Patent:
`{None}
`
`’311 Patent:
`7, 12, 23, 28
`
`Processing native
`low level block
`requests directed to
`the identified LUNs
`from the device to
`
`
`
`In a manner so that
`the devices are
`unaware of the actions
`being taken by the
`storage router
`
`
`Plain and ordinary
`meaning as
`understood by a
`person of skill in this
`art.
`
`
`Plain and ordinary
`meaning as
`understood by a
`person of skill in this
`art.
`
`
`Processing requests
`according to a
`NLLBP of the Virtual
`Local Storage directed
`to LUNs associated
`
`
`Processing native low
`level, block protocol
`requests directed to
`the identified LUNs
`from the device to
`8
`
`
`Processing requests
`according to a
`NLLBP of the Virtual
`Local Storage directed
`to LUNs associated
`
`8 of 9
`
`

`
`Case 1:13-cv-00800-SS Document 105-1 Filed 02/23/15 Page 9 of 9
`Claim Term
`Crossroads’
`Defendants’
`Special Master’s
`Proposed
`Proposed
`Recommendation
`Construction
`Construction
`with the device to
`route the native low
`permit access to the
`level, block requests
`storage space
`to the storage space
`associated with the
`associated with the
`LUNs.
`identified LUNs.
`
`
`with the device to
`permit access to the
`storage space
`associated with the
`LUNs.
`
`
`allow access to the
`storage space
`associated with the
`identified LUNs
`(Page 190 of attached SM
`CC Chart)
`
`’035 Patent:
`{None}
`
`’041 Patent:
`{None}
`
`’147 Patent:
`{None}
`
`’311 Patent:
`1, 16
`
`
`For a device
`connected to the first
`transport medium,
`identifying LUNs for
`storage
`space allocated to
`that device in the
`map; presenting to
`that device only the
`identified LUNs as
`available storage
`space; and
`processing native
`low level bock
`requests directed to
`the identified LUNs
`from that device to
`allow access to the
`storage space
`associated with the
`identified LUNs:
`(Page 208 of attached SM
`CC Chart)
`
`
`
`
`No construction
`necessary.
`.
`
`
`
`No construction
`necessary.
`.
`
`
`
`Claim 1 and its
`dependent claims are
`indefinite under IPXL
`Holdings, LLC v.
`Amazon.com, Inc.,
`430 F.3d 1377 (Fed.
`Cir. 2005).
`
`
`
`9
`
`9 of 9