Petition for Inter Partes Review of U.S. Patent No. 7,051,147
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`CISCO SYSTEMS, INC. AND QUANTUM CORPORATION,
`Petitioners,
`
`v.
`
`CROSSROADS SYSTEMS, INC.,
`Patent Owner
`
`———————
`
`PETITION FOR INTER PARTES REVIEW
`
`OF
`
`U.S. PATENT NO. 7,051,147
`
`

`
`TABLE OF CONTENTS
`
`I. Mandatory Notices......................................................................................... 1
`A. Real Party-in-Interest............................................................................. 1
`B. Related Matters...................................................................................... 1
`C. Lead and Back-up Counsel and Service Information.............................. 2
`II. Grounds for Standing..................................................................................... 2
`III. Relief Requested............................................................................................ 2
`IV. The Reasons for the Requested Relief............................................................ 3
`A.
`Summary of Reasons ............................................................................. 3
`B. The ’147 Patent...................................................................................... 4
`1. Overview ....................................................................................... 4
`2.
`Prosecution History........................................................................ 8
`Identification of Challenges ................................................................... 8
`1. Challenged Claims......................................................................... 8
`2.
`Statutory Grounds for Challenges .................................................. 9
`3. Claim Construction........................................................................ 9
`i.
`“maps between the device and the remote storage devices” ..10
`ii.
`“native low level block protocol”..........................................12
`iii.
`“remote” ...............................................................................13
`Identification of How the Claims Are Unpatentable..................... 14
`i.
`Challenge: Claims 1-14, 16-33, 35-50 and 53 are obvious over
`the CRD Manual in view of the HP Journal ..........................14
`V. Conclusion....................................................................................................60
`
`C.
`
`4.
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,051,147
`
`I.
`
`Mandatory Notices
`A.
`Real Party-in-Interest
`The real parties-in-interest are Cisco Systems, Inc. and Quantum
`
`Corporation (“Petitioners”).
`
`Related Matters
`B.
`Petitions for Inter Partes Review, IPR2014-01207, filed July 25, 2014, and
`
`IPR2014-01209, filed July 25, 2014; Crossroads Systems, Inc. v. Quantum
`
`Corporation, 1-14-cv-00150, TXWD, filed February 18, 2014; Crossroads
`
`Systems, Inc. v. NetApp, Inc., 1-14-cv-00149, TXWD, filed February 18, 2014;
`
`Crossroads Systems, Inc. v. Cisco Systems, Inc., 1-14-cv-00148, TXWD, filed
`
`February 18, 2014; Crossroads Systems, Inc. v. Huawei Technologies Co. Ltd. et
`
`al, 1-13-cv-01025, TXWD, filed November 26, 2013; Crossroads Systems, Inc. v.
`
`Oracle Corporation, 1-13-cv-00895, TXWD, filed October 7, 2013. Also, (i) case
`
`nos. IPR2014-01197 (filed July 23, 2014) and IPR2014-01226 (filed July 31,
`
`2014) have been filed against U.S. Patent No. 6,425,035, which is related to the
`
`’147 patent; and (ii) case nos. IPR2014-01177 (filed July 18, 2014) and IPR2014-
`
`01463 (filed Sept. 8, 2014) have been filed against U.S. Patent No. 7,934,041,
`
`which is related to the ’147 patent. Additionally, this petition refers to a claim
`
`construction order from Crossroads Systems, Inc. v. 3PAR, Inc., et. al., no. 1-10-
`
`cv-00652 (W.D. Tex. 2010), which is one of the district court litigations involving
`
`U.S. Patent No. 6,425,035, which is related to the ’147 patent.
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`

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`Petition for Inter Partes Review of U.S. Patent No. 7,051,147
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`Lead and Back-up Counsel and Service Information
`C.
`Lead Counsel
`David L. McCombs
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`Phone: (214) 651-5533
`Fax: (214) 200-0853
`david.mccombs.ipr@haynesboone.com
`USPTO Reg. No. 32,271
`
`Back-up Counsel
`Andrew S. Ehmke
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`Scott T. Jarratt
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`Phone: (214) 651-5116
`Fax: (214) 200-0853
`andy.ehmke.ipr@haynesboone.com
`USPTO Reg. No. 50,271
`
`Phone: (972) 739-8663
`Fax: (214) 200-0853
`scott.jarratt.ipr@haynesboone.com
`USPTO Reg. No. 70,297
`
`II. Grounds for Standing
`Petitioners certify that they are not estopped or barred from requesting inter
`
`partes review of the ’147 Patent. Petitioners were each served with a complaint
`
`asserting infringement of the ’147 Patent on February 18, 2014, which is not more
`
`than one year before the filing of this Petition. Neither petitioner has initiated a
`
`civil action challenging the validity of any claim of the ’147 Patent. Petitioners
`
`also certify that the ’147 Patent is eligible for inter partes review.
`
`III. Relief Requested
`Petitioners ask that the Patent Trial and Appeal Board (“the Board”) review
`
`the accompanying prior art and analysis, institute a trial for inter partes review of
`
`claims 1-39 (all claims) of the ’147 Patent, and cancel those claims as invalid.
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`Petition for Inter Partes Review of U.S. Patent No. 7,051,147
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`IV. The Reasons for the Requested Relief
`The full statement of the reasons for the relief requested is as follows:
`
`A.
`
`Summary of Reasons
`In short, the claims of the ’147 Patent simply recite obvious combinations of
`
`network storage components with functionality that was well-known at the time of
`
`the ’147 Patent invention. For example, each of the ’147 Patent’s seven
`
`independent claims generally include limitations directed to (i) mapping
`
`workstations on one side of a storage router to specific storage devices on the other
`
`side of the storage router, and (ii) routing block-level data between the
`
`workstations and the storage devices based on the mapping so that the workstations
`
`may only access the particular storage devices to which they are mapped. The ’147
`
`Patent’s claims require the workstations and storage devices to be connected via
`
`Fibre Channel links. In one embodiment of the ’147 Patent, the block-level data
`
`flowing between the workstations and storage devices conforms to the SCSI
`
`protocol. CQ-1001, 5:46-56; 6:31-56.
`
`These elements were well known in the prior art. For example, in 1996,
`
`CMD Technologies sold a storage router, the CRD-5500 SCSI RAID Controller,
`
`that performed the functions recited in the claims. According to the CRD-5500
`
`user’s manual, the CRD-5500 Controller (i) allows users to map hosts on one side
`
`of the controller to specific storage devices on the other side of the controller and
`
`then (ii) routes SCSI commands from hosts to storage devices based on the map,
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`Petition for Inter Partes Review of U.S. Patent No. 7,051,147
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`while blocking hosts from accessing storage devices to which they were not
`
`mapped. CQ-1004, pp. 1-1, 1-2, 1-11, 4-2, 4-5.
`
`In one configuration, the CRD-5500 Controller routes data between hosts on
`
`a SCSI bus link and storage devices on a SCSI bus link; however, the CRD-5500
`
`Controller was designed to support Fibre Channel links through the use of different
`
`I/O adapter cards. CQ-1004, pp. 1-1, 2-1, 2-4; CQ-1005, p. 1. One of ordinary skill
`
`in the art at the time of the ’147 Patent would have been motivated to modify the
`
`CRD-5500 Controller to use Fibre Channel I/O adapter cards to take advantage of
`
`the benefits of the Fibre Channel protocol. See CQ-1003, ¶¶ 53-62. In that regard,
`
`Fibre Channel was known to alleviate several limitations of SCSI buses (the
`
`default CRD-5500 Configuration). CQ-1006, pp. 5, 94, 99.
`
`Consequently, this petition demonstrates that claims 1-39 merely recite
`
`features that were well known in the prior art and are therefore rendered obvious
`
`over the references presented in this petition.
`
`B.
`
`The ’147 Patent
`1.
`Overview
`The ’147 Patent has seven independent claims (claims 1, 6, 10, 14, 21, 28,
`
`and 34) and a total of 39 claims. The ’147 Patent generally describes a “storage
`
`router” that routes storage requests between workstations and storage devices. CQ-
`
`1001, Abstract. Figure 3 of the ’147 Patent illustrates one embodiment of the
`
`storage network in which the storage router operates:
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`Storage Router
`
`SCSI Bus
`
`Workstations
`
`Fibre Channel
`link
`
`CQ-1001, Fig. 3 (annotated);
`CQ-1003, p. 12
`
`Storage devices
`
`As shown in Fig. 3, workstations on a Fiber Channel link (i.e., a transport
`
`medium) are connected to one side of the storage router (the “host side”), and
`
`storage devices on the SCSI bus communication link are connected to the other
`
`side of the storage router (the “disk side”). CQ-1001, 4:10-19. The ’147 Patent
`
`describes the storage router as “a bridge device that connects a Fiber Channel link
`
`directly to a SCSI bus.” Id. at 5:46-50. The ’147 Patent notes, however, that the
`
`“storage router has various modes of operation,” including a mode in which the
`
`storage router routes data between a Fibre Channel-attached host and a Fibre
`
`Channel-attached storage device. Id. at 6:31-43.
`
`According to the ’147 Patent, a “SCSI command” is an example of a native
`
`low level block protocol command and the storage router enables the exchange of
`
`SCSI commands and data between the workstations and the storage devices. Id. at
`
`5:61-63; 4:15-19. Additionally, the ’147 Patent states that Fiber Channel-based
`
`workstations on one side of the storage router may communicate with SCSI-based
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`storage devices on the other side of the storage router by encapsulating SCSI
`
`commands into Fiber Channel Protocol (FCP) requests. Id. at 6:44-56. As
`
`discussed below in more detail, encapsulating SCSI commands inside a Fibre
`
`Channel request was a feature of the Fibre Channel standard, and was well known
`
`in the art at the time of the ’147 invention. See CQ-1006, pp. 94-95.
`
`The ’147 Patent states that the storage router uses “mapping tables” to
`
`allocate subsets of storage space (e.g., partitions) on the storage devices to
`
`particular workstations. CQ-1001, 4:26-35. For example, referring to Fig. 3,
`
`“[s]torage device 62 can be configured to provide partitioned subsets 66, 68, 70
`
`and 72, where each partition is allocated to one of the workstations 58.” Id. at 4:32-
`
`35. Also, the ’147 Patent states that the storage router provides “virtual local
`
`storage” such that a mapped partition is “considered by the workstation 58 to be its
`
`local storage”—i.e., the mapped partition “has the appearance and characteristics
`
`of local storage.” Id. at 4:20-26, 4:56-66. As discussed below in more detail, it was
`
`well known in the art at the time of the ’147 invention to map workstations on one
`
`side of a storage router to partitions on the other side of the storage router, and to
`
`make the partitions appear as local disks. See CQ-1004, pp. 1-2, 3-6, 4-5.
`
`According to the ’147 Patent, the storage router uses the mapping
`
`functionality to facilitate both routing and access control. CQ-1001, 5:37-39. With
`
`respect to routing, the ’147 Patent states that the map between the initiators and the
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`specific subsets of storage allows the storage router to determine “what partition is
`
`being addressed by a particular request,” thus enabling it to “distribute[] requests
`
`and data” to storage devices Id. at 9:11-14, 4:2-5. For access control, the ’147
`
`Patent states that the storage router prevents a workstation from accessing a subset
`
`of storage not allocated to it in the map. Id. at 9:5-17. For example, in Fig. 3,
`
`“subsets 66, 68, 70 and 72 can only be accessed by the associated workstation 58.”
`
`Id. at 4:35-37. As discussed below in more detail, the concept of using a map to
`
`facilitate routing and access control of storage devices was well known in the art at
`
`the time of the ’147 Patent invention. See CQ-1004, pp. 1-2, 4-5.
`
`To illustrate the general flow of I/O commands in the storage network of the
`
`’147 Patent, Fig. 3 is further annotated below:
`
`(i) workstation B sends
`a SCSI I/O command
`to its “virtual local
`storage”
`
`(ii) storage router uses map to
`determine which partition is
`allocated to workstation B
`
`CQ-1001, Fig. 3 (annotated);
`CQ-1003, p. 15
`
`(iii) partition mapped to workstation
`B receives SCSI I/O command
`
`Because communicating SCSI commands over Fibre Channel, mapping
`
`workstations to storage partitions, and using the mapping for routing and access
`
`control were well known in the art at the time of the ’147 invention, the storage
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`network described by the ’147 Patent is simply a collection of components that
`
`were well known in the art at the time of the ’147 Patent invention. CQ-1003, ¶ 21.
`
`And, as shown below, these well-known components are arranged in a manner that
`
`would have been obvious to one of ordinary skill in the art. Id.
`
`Prosecution History
`2.
`The ’147 Patent issued on May 23, 2006, from U.S. Patent Application No.
`
`10/658,163 (“the ’163 application”) filed on September 9, 2003 by Geoffrey B.
`
`Hoese and Jeffry T. Russell. The ’147 Patent is purportedly a continuation of a
`
`string of patent applications claiming priority to U.S. Patent Application No.
`
`09/001,799, filed on Dec. 31, 1997. During prosecution, the ’163 application was
`
`rejected under 35 U.S.C. § 112, first paragraph, and was also subject to a double
`
`patenting rejection. CQ-1002, pp. 205-213. Patent Owner overcame the § 112
`
`rejection without amending the claims and filed a Terminal Disclaimer disclaiming
`
`any patent term extending beyond the life of 7 U.S. Patents and 7 pending-at-the-
`
`time U.S. Patent Applications. Id. at 325-343, 371-372. The Examiner then issued
`
`a Notice of Allowance without a substantive rejection of the claims. Id. at 404-407.
`
`Based on the above, it appears that during the course of the prosecution of the ’147
`
`Patent, the Patent Office never substantively considered the relevance of the CRD
`
`Manual or the HP Journal.
`
`C.
`
`Identification of Challenges
`1.
`Challenged Claims
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`Petition for Inter Partes Review of U.S. Patent No. 7,051,147
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`Claims 1-39 of the ’147 Patent are challenged in this petition.
`
`Statutory Grounds for Challenges
`2.
`Claims 1-39 are obvious under 35 U.S.C. § 103(a) over the CRD-5500 SCSI
`
`Raid Controller User's Manual (“CRD Manual”) in view of Volume 47, issue 5 of
`
`the Hewlett-Packard Journal (“HP Journal”). The CRD Manual is dated November
`
`21, 1996 and was available for public download from the CMD Technologies
`
`website at least by December 26, 19961, and is thus prior art under 35 U.S.C. §
`
`102(b). The HP Journal was published in October 1996, and the HP Journal Online
`
`website notes that the “HP Journal has been available on the World Wide Web
`
`since early 1994.” See CQ-1012. The HP Journal is thus prior art under 35 U.S.C.
`
`§ 102(b).
`
`Claim Construction
`3.
`This petition presents claim analysis in a manner that is consistent with the
`
`broadest reasonable construction in light of the specification. See 37 C.F.R. §
`
`1 The CRD Manual was archived on December 26, 1996 by the Internet Archive
`
`Wayback Machine and is available at http://web.archive.org/web/19961226085
`
`953/http://www.cmd.com/ftproot/pub/raid/5500/manual/crd5500user.pdf. The PTO
`
`identifies the Wayback Machine “archived date” as the publication date of web-
`
`based documents. See,
`
`http://uspto.gov/patents/resources/methods/aiplafall02paper.jsp.
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`42.100(b). Under the broadest reasonable construction, claim terms are given their
`
`ordinary and accustomed 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). Also, because the claim constructions proposed
`
`herein are based on the broadest reasonable construction, they do not necessarily
`
`apply to other proceedings that use different claim construction standards. See
`
`Samsung Electronics Co., Ltd v. Virginia Innovation Sciences, Inc., IPR2013-
`
`00569, Paper 9 at *2, Oct. 30, 2013 (“[B]ecause the Board applies the broadest
`
`reasonable construction standard, the Board’s construction may not be the same as
`
`that adopted by a district court, which may apply a different standard.”).
`
`i.
`
`“maps between the device and the remote storage devices”
`
`This claim term is found in claim 1. Independent claims 6, 10, 14, 21, 28,
`
`and 34 recite similar language. In the previous Crossroads Systems, Inc. v. 3PAR
`
`litigation2 (in connection with related U.S. Patent No. 6,425,035), the District
`
`Court construed “map / mapping” to mean “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
`
`2 Crossroads Systems, Inc. v. 3PAR, Inc., et. al., no. 1-10-cv-00652 (W.D. Tex.
`
`2010).
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`the other side of the storage router, the storage router can connect the devices.”
`
`CQ-1009, p. 12.
`
`The ’147 Patent does not provide an explicit definition of the above term,
`
`but describes that in Fig. 3 “[s]torage router 56 allows the configuration and
`
`modification of the storage allocated to each attached workstation 58 through the
`
`use of mapping tables or other mapping techniques.” CQ-1001, 4:26-29 (emphasis
`
`added). The ’147 Patent also describes that the storage router uses “tables to map,
`
`for each initiator, what storage access is available and what partition is being
`
`addressed by a particular request.” Id. at 9:11-14. Dependent claims 2 and 7 appear
`
`to clarify the mapping in the independent claims. For example, claim 2 recites:
`
`“wherein the configuration maintained by the supervisor unit includes an allocation
`
`of subsets of storage space to associated Fibre Channel devices, wherein each
`
`subset is only accessible by the associated Fibre Channel device.” Id. at 9:48-52.
`
`Thus, consistent with the surrounding language of the claims and the specification,
`
`one of ordinary skill in the art would understand the broadest reasonable
`
`construction of “maps between the device and the remote storage devices” to be
`
`“to allocate storage on the storage devices to devices to facilitate routing and
`
`access controls.” See CQ-1001, 4:26-38, 9:5-17; see also CQ-1003 at ¶¶ 27-31.
`
`Whether the District Court construction or the foregoing construction is
`
`applied, the prior art references relied upon in this petition teach this claim term.
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`See CQ-1003, pp. 54-55, 90, 102-103, 117-118, 139-140, 162, 177-178, 207-208.
`
`ii.
`
`“native low level block protocol”
`This claim term is found in claims 1, 6, 10, 14, 21, 28, and 34. In the 3Par
`
`litigation (in connection with related U.S. Patent No. 6,425,035), the District Court
`
`construed this term to mean “a set of rules or standards that enable computers to
`
`exchange information and do not involve the overhead of high level protocols and
`
`file systems typically required by network servers.” CQ-1009, p. 13.
`
`The ’147 Patent does not provide an explicit definition of “native low level
`
`block protocol,” but contrasts a workstation accessing “a local storage device”
`
`using “native low level, block protocols” with a workstation accessing network-
`
`based storage devices through a “network server” which “implements a file system
`
`and transfers data to workstations 12 only through high level file system
`
`protocols.” CQ-1001, 3:27-36. With reference to Fig. 3, the ’147 Patent states that
`
`subsets 66, 68, 70, and 72 of storage space are “accessed using native low level,
`
`block protocols” and that “storage access involves native low level, block
`
`protocols.” Id. at 4:35-38, 5:13-17. One example in the ’147 Patent of a native low
`
`level block protocol command is a “SCSI command.” Id. at 5:46-50. Thus, based
`
`upon the plain language of the claims and consistent with the specification, one of
`
`ordinary skill in the art would understand the broadest reasonable construction of
`
`“native low level block protocol” to be “a protocol in which storage space is
`
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`accessed at the block level, such as the SCSI protocol.” CQ-1003 at ¶¶ 32-36.
`
`Whether the District Court construction or the foregoing construction is
`
`applied, the prior art references relied upon in this petition teach this claim term.
`
`See CQ-1003, pp. 58, 93-94, 120, 185.
`
`iii.
`
`“remote”
`This term is found in claims 1, 4, 10, 13-15, 17-19, 21, 28, and 34. In the
`
`3Par litigation (in connection with related U.S. Patent No. 6,425,035), the District
`
`Court construed “remote” to mean “indirectly connected through at least one serial
`
`network transport medium.” CQ-1009, p. 12.
`
`The ’147 Patent does not provide an explicit definition of “remote,” but
`
`describes that “the storage space considered by the workstation 58 to be its local
`
`storage is actually a partition (i.e., logical storage definition) of a physically remote
`
`storage device 60, 62 or 64 connected through storage router 56.” CQ-1001, 4:63-
`
`66 (emphasis added). The ’147 Patent also describes that “[t]ypical storage
`
`transport mediums provide for a relatively small number of devices to be attached
`
`over relatively short distances. One such transport medium is a Small Computer
`
`System Interface (SCSI) protocol.” Id. at 1:30-35. Thus, consistent with the
`
`surrounding language of the claims and the specification, one of ordinary skill in
`
`the art would understand the broadest reasonable construction of “remote” to be
`
`“indirectly connected through a storage router to enable connections to storage
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`devices at a distance greater than allowed by a conventional parallel network
`
`interconnect.” CQ-1003 at ¶¶ 37-41.
`
`Whether the District Court construction or the foregoing construction is
`
`applied, the prior art references relied upon in this petition teach this claim term.
`
`See CQ-1003, pp. 40-41, 106-107, 125-126, 153-154, 173.
`
`4.
`
`Identification of How the Claims Are Unpatentable
`i. Challenge: Claims 1-14, 16-33, 35-50 and 53 are obvious over
`the CRD Manual in view of the HP Journal
`(a)
`Summary of the CRD Manual
`The CRD Manual describes the features and operation of the CRD-5500
`
`SCSI RAID Controller. The CRD-5500 Controller routes commands and data
`
`between hosts (i.e., initiators) and storage devices (i.e., targets) coupled to the
`
`controller. CQ-1004, pp. 1-1, 1-4.
`
`Hosts attached to SCSI bus links are connected to the CRD-5500 Controller
`
`(the “host side”) and storage devices attached to SCSI bus links are connected to
`
`the CRD-5500 Controller (the “disk side”). Id. at p. 2-4. The CRD-5500 Controller
`
`enables the exchange of SCSI commands and data between the hosts and the
`
`storage devices. Id. at pp. 1-1, 1-4, 2-1, 2-4. Figure 1-2 in the CRD Manual
`
`illustrates the storage network in which the CRD-5500 Controller operates:
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`Hosts
`
`CRD-5500 Controller
`
`CQ-1004, p. 1-2 (annotated);
`CQ-1003, p. 27
`
`Host SCSI Buses
`
`Storage Device SCSI Buses
`
`Storage devices
`
`The CRD-5500 Controller includes a Monitor Utility in its user-upgradeable
`
`firmware that gives a user “complete control over the configuration and operation
`
`of the controller.” CQ-1004, pp. 4-1, 4-14. The Monitor Utility includes a “Host
`
`LUN Mapping” feature that allows a user to map subsets of storage space on the
`
`storage devices (referred to as “redundancy groups”) to specific hosts. Id. at pp. 1-
`
`2, 1-11, 4-2, 4-5. A “LUN” is a logical unit number used to represent storage
`
`space. CQ-1003, ¶ 44. Specifically, as shown below, the Host LUN Mapping
`
`feature maintains a mapping table for each host, where each mapping table has a
`
`set of virtual LUNs (numbered 0-31) to which the redundancy groups are mapped.
`
`CQ-1004, pp. 1-2, 1-11, 4-2, 4-5. A host accesses the redundancy groups by
`
`referencing its virtual LUNs. Id. For example, in the below Host LUN Mapping
`
`configuration, the host associated with channel 0 may access redundancy group 5
`
`by addressing SCSI commands to LUN 4. CQ-1003, ¶¶ 44-45:
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`Mapping for
`the host
`associated
`with
`channel 0
`
`Redundancy
`groups (storage
`space)
`mapped to the
`host’s LUNs
`CQ-1004, p. 4-5
`(annotated);
`CQ-1003, p. 28
`
`As an aspect of this, each mapped redundancy group “will appear to the host as a
`
`different disk drive.” CQ-1004, p. 3-6.
`
`The CRD-5500 Controller uses the Host LUN Mapping tables to facilitate
`
`routing and access control. Figure 1-2 illustrates the general flow for routing
`
`commands from a host to a redundancy group:
`
`(i) host sends a SCSI I/O command to
`its “LUN 0”
`
`(ii) CRD-5500 uses a map to determine which
`redundancy group is mapped to LUN 0
`
`(iii) redundancy group mapped to LUN
`0 receives SCSI I/O command
`CQ-1004, Figure 1-2 (annotated); CQ-1003, p. 29
`
`Additionally, because a host transmits SCSI commands to its set of virtual
`
`LUNs rather than the physical storage devices, the CRD-5500 Controller can
`
`“make a redundancy group visible to one host but not to another.” CQ-1004, p. 1-
`
`1. For example, the CRD-5500 Controller “may make redundancy group 8
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`available on LUN 4 on host channel 0 and block access to it on host channel 1.” Id.
`
`at p. 4-5. Thus, the CRD-5500 not only routes commands, but can control access.
`
`Further, the CRD-5500 Controller includes numerous slots for I/O adapter
`
`cards through which the controller communicates with hosts and storage devices.
`
`CQ-1004, pp. 1-1, 2-1, 2-4. A key feature of the CRD-5500 Controller is that it
`
`“employs a modular design for maximum flexibility.” Id. at p. 1-1. Specifically,
`
`the controller’s slots accept different types of I/O adapter cards. Id. at pp. 1-1, 2-1,
`
`2-4. Figure 2-1 illustrates the modular nature of the controller:
`
`I/O adapter cards
`connected to SCSI buses
`
`Slots for additional
`I/O adapter cards
`
`CQ-1004, Figure 2-1 (annotated); CQ-1003, p. 30
`
`Notably, the designers of the CRD-5500 Controller intended for the CRD-
`
`5500 to work not only with SCSI bus links but also with other types of
`
`communication links. A data sheet advertising the features of the CRD-5500
`
`Controller states that the controller’s “RAID architecture and ASICs were
`
`designed to support tomorrow's high speed serial interfaces, such as
`
`Fiberchannel (FCAL) and Serial Storage Architecture (SSA).” CQ-1005, p. 1
`
`(emphasis added).
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`Summary of the HP Journal
`(b)
`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.” CQ-1006, p. 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 p. 94. The article provides many
`
`reasons a Fibre Channel communication link is superior to a SCSI bus (e.g., longer
`
`distances and higher bandwidth, smaller connectors). Id. at p. 94. It also notes that
`
`SCSI commands may be “encapsulated and transported within Fibre Channel
`
`frames” to support existing storage hardware. Id. at pp. 94-95.
`
`A second article in the same issue of the HP Journal describes a Fibre
`
`Channel protocol chip made by HP called “Tachyon.” CQ-1006, pp. 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 p. 101.
`
`The article also provides details about how to implement a Fibre Channel I/O
`
`adapter card that uses the Tachyon chip. Id. at p. 111.
`
`Reasons to Combine the CRD Manual and the HP Journal
`(c)
`One of ordinary skill in the art would have been motivated to combine the
`
`teachings of the CRD Manual and the HP Journal to replace the SCSI I/O host
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`modules in the CRD-5500 Controller with a Fibre Channel I/O host module. See
`
`CQ-1003 at ¶¶ 53-62.
`
`First, the CRD Manual teaches that the modular design of CRD-5500
`
`Controller accepts different types of modules to interface with different transport
`
`media. CQ-1004, pp. 1-1, 2-1. Persons of ordinary skill in the art were informed
`
`that the CRD-5500 Controller was specifically “designed to support tomorrow's
`
`high speed serial interfaces, such as Fiberchannel.” CQ-1005, p. 1.
`
`Second, the HP Journal teaches that “today’s parallel bus architectures are
`
`reaching their limits.” CQ-1006, p. 5. More specifically, the HP Journal teaches
`
`that there are a number of inherent limitations in the SCSI bus architecture that
`
`prevent it from “keeping pace with ever-increasing processor speeds and data rate
`
`requirements.” Id. at p. 99. The HP Journal further teaches that the Fibre Channel
`
`serial transport medium solves these limitations because its “increased bandwidth
`
`provides distance flexibility, increased addressability, and simplified cabling.” Id.
`
`at 99. In particular, it teaches that Fibre Channel “can operate from 2.5 to 250
`
`times faster than existing communications interfaces” and that “[a] single 100-
`
`Mbyte/s Fibre Channel port can replace five 20-Mbyte/s SCSI ports, in terms of
`
`raw through put.” Id. at p. 94 (emphasis added). Also, “Fibre Channel resolves the
`
`‘slots and watts’ problem” because Fibre Channel supports the same I/O services
`
`with fewer number of slots. Id. at 100, 101. Further, the HP Journal notes that
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`Fibre Channel is backwards compatible with SCSI-based hardware because SCSI
`
`commands may be “encapsulated and transported within Fibre Channel frames.”
`
`Id. at pp. 94-95; CQ-1003, ¶ 56. The HP Journal also describes how to implement
`
`a generic Fibre Channel I/O adapter board using the Tachyon chip. CQ-1006, pp.
`
`101-111; Fig. 14. Notably, the Tachyon chip was designed to be “easily adaptable”
`
`to a variety of system types. Id. at p. 101; CQ-1003, ¶ 57.
`
`Given the teachings of the CRD Manual and the HP Journal, one of ordinary
`
`skill in the art would have been motivated to replace the SCSI I/O modules on both
`
`the “host side” and “disk side” of the CRD-5500 Controller with Fibre Channel I/O
`
`modules. CQ-1003, ¶ 58. Such a substitution would have been simple because (i)
`
`the CRD-5500 Controller has a modular design that accepts different types of I/O
`
`modules and (ii) the Tachyon Fibre Channel chip is “easily adaptable” to different
`
`systems. Id. Further, the HP Journal specifically teaches that a Fibre Channel I/O
`
`module was intended to “replace” SCSI I/O modules. Using Fibre Channel-based
`
`I/O modules instead of SCSI-based I/O modules on both the “host side” and “disk
`
`side” of the CRD-5500 Controller would have allowed the CRD-5500 to
`
`communicate with hosts and disks via Fibre Channel links rather than via SCSI
`
`buses, thereby overcoming many of the known limitations of SCSI buses described
`
`in the HP Journal. Id.
`
`Additionally, the beneficial result of modifying the CRD-5500 Controller to
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`interface with a Fibre Channel link would have been predictable because (i) the
`
`CRD-5500 Controller was specifically designed to support Fibre Channel, (ii) the
`
`HP Journal specifically contemplates replacing multiple SCSI ports with a single
`
`Fibre Channel port, and (iii) Fibre Channel frames are intended to encapsulate
`
`SCSI commands to create backwards compatibility with SCSI-based devices. CQ-
`
`1006, pp. 94-95; CQ-1003, ¶¶ 59, 60.
`
`To the extent any modifications would have been needed to the teachings of
`
`the CRD Manual in order to accommodate the teachings of the HP Journal, such
`
`modifications would