UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CROSSROADS SYSTEMS, INC.
`Patent Owner
`
`____________
`
`Patent Nos. 6,425,035
`
`
`7,051,147
`
`
`7,934,041
`
`____________
`
`DECLARATION OF BRIAN BIANCHI
`
`1 of 5
`
` CROSSROADS EXHIBIT 2043
` Cisco Systems et al v Crossroads Systems, Inc.
` IPR2014-01544
`
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CROSSROADS SYSTEMS, INC.
`Patent Owner
`
`____________
`
`Patent Nos. 6,425,035
`
`
`7,051,147
`
`
`7,934,041
`
`____________
`
`DECLARATION OF BRIAN BIANCHI
`
`1 of 5
`
` CROSSROADS EXHIBIT 2043
` Cisco Systems et al v Crossroads Systems, Inc.
` IPR2014-01544
`
`
`
`
`
`I, Brian Bianchi, state and declare as follows:
`
`1.
`
`I am an employee of Crossroads Systems, Inc.. I have been employed
`
`with Crossroads since June 1998. I am currently in the position of Chief Operating
`
`Officer. My knowledge of the facts stated here is based on my employment with
`
`Crossroads. To the extent I state or refer to any facts which are not based directly
`
`on my personal knowledge, they are based on my inspection of Crossroads’
`
`records. Those records, including those included or referenced in Exhibits A, B,
`
`and C, were made at or near the time the recorded act, event, condition, or opinion
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`occurred. The records were made by someone with knowledge or from information
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`transmitted by someone with knowledge. These records were kept in the course of
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`Crossroads’ regularly conducted business activity. It was Crossroads’ regular
`
`practice to make these records. I am qualified to testify regarding Crossroads’
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`record keeping practices because I am familiar with them through my employment
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`with Crossroads.
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`2.
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`Attached as Exhibit A to my declaration are tables containing
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`Crossroads’ shipment and sales information for its storage bridge and storage
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`router products. The information in this spreadsheet represents Crossroads’
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`business records for shipment and revenue for these products. I am using the term
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`bridge herein to mean a storage appliance that provides one or more host
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`2 of 5
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`computers virtual local storage on remote storage devices using native, low-level
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`block protocols, but without access controls. I am using the term router herein to
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`mean a storage appliance with the same features as a bridge, but with the additional
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`feature of access controls. By access controls I mean the ability to control (allow or
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`deny) access from a host computer to the same storage available to another host
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`computer.
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`3.
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`Exhibit A includes shipments and sales from fiscal year 1998 through
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`fiscal year 2010. Crossroads began selling bridges in 1998. Crossroads first began
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`selling routers in the fiscal fourth quarter of 1999. For each of Crossroads’
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`products in Exhibit A, I have included a designation of whether the product is a
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`bridge or router. Included are embedded routers/bridges. Embedded simply
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`distinguishes standalone routers and bridges from routers or bridges contained on a
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`separate circuit board, to be included inside another device. The functionality of
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`standalone and embedded routers and bridges is the same.
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`4.
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`I have attached as Exhibit B graphs of the shipment and sales data
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`contained in Exhibit A. Exhibits A and B show that, after the introduction of its
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`router products with access controls, Crossroads’ bridge sales quickly dropped.
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`5.
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`Crossroads’ first routers were simply versions of its bridge products,
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`but with access controls. For example, Crossroads’ 4250 Router was similar to the
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`Crossroads’ 4200 Bridge, but included access controls. In several instances,
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`Crossroads sold bridge and router versions of essentially the same products—that
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`is, virtually identical except for the inclusion of access controls and related
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`features. This is true of the 6000-b bridge and 6000-Router, 6240-b bridge and
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`6240-Router, and 7120-b bridge and 7120-Router. I have included as Exhibit C
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`true and correct copies of multiple Crossroads product brochures which compare
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`and contrast these bridge and router products. For a given product (e.g., the 6240)
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`and the associated bridge and router versions (e.g., the 6240 Router vs. the 6240-b
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`Bridge), a comparison of the product features shows that the primary differences
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`between the two versions are the features related to access controls (the access
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`controls themselves, the user defined maps, and dynamic mapping). See, e.g.,
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`Exhibit C at CRDS 504194 (“Crossroads Storage Routers expand bridge
`
`functionality . . . . Storage resources are securely allocated using Crossroads’
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`patented Access Controls . . . Users can configure, secure and manage up to eight
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`custom device maps. Additionally, dynamic mapping allows immediate changes to
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`custom maps without router reboot.”) and CRDS 504195 (providing Product
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`Matrix showing the primary differences between the analogous bridge and router
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`devices). The mapping features (user defined maps and dynamic mapping) are not
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`necessary when access controls do not exist, because they relate to defining which
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`hosts have access to what storage.
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`6.
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`I also have personal knowledge of the differences between these
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`products. Based on that knowledge and my experience at Crossroads, it is my
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`impression that the increase in router sales over time, and the corresponding
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`decrease in bridge sales, is due primarily to customer preference for a product
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`having access controls.
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`I declare under penalty of perjury under the laws of the United States of America
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`that the foregoing is true and correct.
`
`Executed on: April L0 , 2015
`
`Xngiiw
`
`Brian Bianchi
`
`5of5
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`5 of 5
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