CCisco Systems et. al.,
`Petitioners
`v.
`Crossroads Systems
`Patent Owner
`IPR2014-01226, -01463, -01544
`
`
` CROSSROADS EXHIBIT 2049
` Cisco Systems et al v Crossroads Systems, Inc.
` IPR2014-01226, -01463, -01544
`
`1
`
`1 of 101
`
`
`Petitioners
`v.
`Crossroads Systems
`Patent Owner
`IPR2014-01226, -01463, -01544
`
`
` CROSSROADS EXHIBIT 2049
` Cisco Systems et al v Crossroads Systems, Inc.
` IPR2014-01226, -01463, -01544
`
`1
`
`1 of 101
`
`
`
`OOverview of Presentation
`
`•
`
`The invention includes mapping and access controls between particular
`hosts and storage space
`• Petitioners’ combination uses the Host LUN Mapping of the CRD As-Is, with
`no capability to map to hosts
`o The CRD and its Host LUN Mapping are only capable of allocating storage to
`channels
`o Adding Fibre Channel does not change any of these capabilities
`
`•
`
`In their Reply, Petitioners state that one of skill in the art would add new
`capabilities to the Host LUN Mapping to map to hosts
`o New combination - not a basis upon which trial was instituted
`o No evidentiary support - Hospodor says no changes for combination
`o Petitioners’ position in reply is based on an erroneous foundation
`
`• Petitioners assert in their Reply that one host per channel is a per-host
`system rather than a channel based system – the evidence shows otherwise
`o New combination – not a basis upon which trial was instituted
`
`2
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`2 of 101
`
`
`
`TThe Invention Includes Mapping and
`Access Controls Between Particular
`Hosts and Storage Space
`
`3
`
`3 of 101
`
`
`
`PPatent Owner Invented the Claimed Access Controls
`WWhich Use a Host to Storage Map
`
`The invention requires the capability to map different storage to
`different hosts on the same transport medium (i.e., a common
`communications link):
`
`cited in 1226 POR at 8 4
`
`4 of 101
`
`
`
`PPetitioners’ Combination Uses the
`CRD’s Host LUN Mapping As-Is, with
`No Capability to Map to Hosts
`
`5
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`5 of 101
`
`
`
`PPetitioners’ Original Combination
`
`Petitioners’ Original Combination replaced the multiple SCSI I/O host modules in the CRD-
`5500 with a single Fibre Channel I/O host module, so that all hosts would be on a single
`
`transport medium: sport medium:
`
`1226 Pet. at 23
`
`
`
`
`
`1226 Pet. at 261226 Pet
`
`
`
`1226 Pet. at 40-411226
`
`cited in 1226 POR 33-35,44-45
`
`6
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`6 of 101
`
`
`
`Petitioners’ Original Combination from Petition
`
`1226 Pet. at 29, 41, 50; Ex. 2027 (Levy Decl.) ¶ 89
`
`cited in 1226 POR at 35
`
`7
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`7 of 101
`
`
`
`PPetitioners Relied on the CRD-5500’s “Host LUN Mapping” in
`Unchanged Form to Meet the Map Limitation
`
`. . . .
`
`. 1226 Pet at
`
`1226 Pet. at 31
`
`Q. What specific changes did you describe in your declaration that you would
`make to the firmware?
`. . .
`A. I didn’t make any specific changes within the firmware. I merely noted that
`as part of the integration process, the firmware could be easily updated and
`could be pushed out to the CRD-5500 once implemented.
`
`Ex. 2028 (Hospodor Depo.) at 208:15-23
`
`
`
`cited in 1226 POR at 33cited in 1226 POR at 33
`
`8
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`8 of 101
`
`
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`PPetitioners Agree tthat the CRD’s “Host LUN Mapping” Utilizes
`Only Channels to Allocate Storage
`
`1226 Reply at 11,12
`
`9
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`9 of 101
`
`
`
`TThe Invention Maps Hosts to Storage,
`Not Channels to Storage
`
`The claimed invention requires the capability to map different
`storage to different hosts on the same transport medium (i.e., a
`common communications link):
`
`cited in 1226 POR at 8 10
`
`10 of 101
`
`
`
`The CRD-5500 Was Incapable of Providing Different Storage
`AAccess to Different Hosts on a First Transport Medium
`
`The Host LUN Mapping only allocates storage to channels, rendering the CRD-
`5500 incapable of providing different storage access to different hosts on one
`channel:
`
`
`
`
`
`Ex. 2027 (Levy Decl.) ¶ 74E 2027 (L D l ) ¶
`
`cited in 1463 POR at 36
`
`11
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`11 of 101
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`
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`PPetitioners’ Expert Agrees that the CRD Does Not Identify Hosts
`
`When asked, Petitioners’ expert repeatedly said CRD cannot identify hosts:
`
`Ex. 2028 (Hospodor Depo.) at 192:14-19
`
`Ex. 2028 (Hospodor Depo.) at 195:5-8; see also 194:5-9, 17-22
`
`cited in 1226 POR at 17
`
`12
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`12 of 101
`
`
`
`The Claimed Invention Maps Storage to Devices, NOT
`Channels (i.e. First Controller)
`
`Ex. 2027 (Levy Decl.) ¶ 89
`
`‘035 Patent; Claim 1
`
`1226 Pet. at 28-29; 1226 POR at 8-9, 14-23, 35 13
`
`13 of 101
`
`
`
`The Claimed Invention Maps Storage to Devices, NOT
`Channels (i.e. First Controller)
`
`Ex. 2027 (Levy Decl.) ¶ 89
`
`‘035 Patent; Claim 1
`
`1226 Pet. at 28-29; 1226 POR at 8-9, 14-23, 35
`
`14
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`14 of 101
`
`
`
`TThe CRD Will Not Be Able to Distinguish Hosts on a Fibre
`Channel Loop Any Better Than On a SCSI Bus
`
`Ex. 2028 (Hospodor Depo.) at 195:5-8; see also 194:5-9, 17-22
`
`Ex. 2027 (Levy Decl.) ¶ 89
`
`cited in 1226 POR at 17, 35 15
`
`15 of 101
`
`
`
`PPetitioners’ CCombination Uses the Host LUN Mapping
`of the CRD As-Is, with No Capability to Map to Hosts
`
`• The CRD and its Host LUN Mapping are only
`capable of allocating storage to channels
`
`• Adding Fibre Channel does not change any of
`these capabilities
`
`But the claimed mapping requires mapping hosts
`to storage space to allow access control
`
`16
`
`16 of 101
`
`
`
`IIn their Reply, Petitioners State that
`One of Skill in the Art Would Add New
`Capabilities to the Host LUN Mapping
`to Map to Hosts
`
`17
`
`17 of 101
`
`
`
`PPetitioners’ Reply Asserts Creating
`New Data Structures for the Host LUN Mapping
`
`In their Reply, Petitioners assert that data structures would have to be
`created to map hosts to storage space:
`
`1226 Reply at 16
`
`18
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`18 of 101
`
`
`
`IIn their Reply, Petitioners Assert that PPer-Host Mapping was the
`Intent of the CRD-5500 All Along
`
`Petitioners argue in their Reply that the CRD-5500 manual has no
`disclosure of multiple hosts connected to one channel:
`
`1226 Reply at 14, 16, 19
`
`19
`
`19 of 101
`
`
`
`PPetitioners Then Ascribe a Goal to the CRD-5500 of Per-Host
`Mapping, Claiming that Would Lead to the Invention
`
`Petitioners’ in their Reply further conclude that the goal of the
`CRD-5500 is to map storage to particular hosts:
`
`On the foundation of these mistaken
`allegations Petitioners assert that:
`
`
`
`1226 Reply at 15, 1626 Reply at 15, 16
`
`20
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`20 of 101
`
`
`
`PPetitioners in their Reply Rely oon the Knowledge of One of
`OOrdinary Skill in the Art to Create New Data Structures Using a
`HHost Identifier instead of the Channel Number
`
`Petitioners cite Hospodor ¶ 61 to support the following conclusion.
`
`1226 Reply at 19
`
`21
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`21 of 101
`
`
`
`PPetitioners’ Expert Based His Opinion
`on a Mistaken Belief About the CRD-5500
`
`Petitioners’ Expert mistakenly believes that only one host can be
`connected to one channel.
`
`Ex. 2028 (Hospodor Depo.) at 188:20-189:4
`
`cited in 1226 POR at 21
`
`22
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`22 of 101
`
`
`
`PPetitioners and Dr. Hospodor are Wrong: The CCRD-5500 Manual
`Shows Multiple Hosts on One Channel
`
`Petitioners and Dr. Hospodor ignore the configuration where multiple hosts
`are on the same channel:
`
`Ex. 1004 at 6-13
`
`cited in 1226 POR at 21-22 23
`
`23 of 101
`
`
`
`TThe CRD-5500’s Multiple Host Configuration
`(Just like Tachyon)
`
`
`
`Ex. 1004 at 6-13Ex. 1004 at 6-1
`
`Ex. 2027 (Levy Decl.) ¶ 89
`
`Ex. 2028 (Hospodor Depo.) at 188:10-16
`
`
`
`cited in 1226 POR at 21, 35 cite
`
`24
`
`24 of 101
`
`
`
`TThe CRD-5500’s Multiple Host Configuration
`(Just like Tachyon)
`
`Ex. 1004 at 6-13
`
`Ex. 2028 (Hospodor Depo.) at 188:10-16
`
`Ex. 2027 (Levy Decl.) ¶ 89
`
`cited in 1226 POR at 17, 21, 35
`
`25
`
`25 of 101
`
`
`
`BBut Both Experts Agree that the CRD--5500 Cannot Distinguish
`Between Multiple Hosts on One Channel
`
`1463 Ex. 2027 (Levy Decl.) ¶ 74
`
`Ex. 2028 (Hospodor Depo.) at 192:14-19
`
`Ex. 2028 (Hospodor Depo.) at 195:5-8; see also 194:5-9, 17-22
`
`cited in 1226 POR at 17, 36; , 1463 POR at 36
`
`26
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`26 of 101
`
`
`
`AAdding a Tachyon Fibre Channel Interface Does Nothing to
`SSolve the Fundamental Issue that the CRD-5500 Can Not
`Identify Multiple Hosts on a Single Channel
`
`Ex. 1004 at 6-13
`
`Ex. 2028 (Hospodor Depo.) at 188:10-16
`
`Ex. 2027 (Levy Decl.) ¶ 89
`
`cited in 1226 POR at 17, 21-22, 30-31, 35
`
`27
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`27 of 101
`
`
`
`IIn their Reply, Petitioners State that One of Skill in the Art
`WWould Add New Capabilities to the Host LUN Mapping
`to Map to Hosts
`
`• New combination - not a basis upon which was
`trial was instituted
`
`• No evidentiary support – Hospodor says no
`changes for combination
`
`• Petitioners’ position in reply is based on an
`erroneous foundation
`(cid:190)CRD has a multi-host embodiment
`(cid:190)It was not the goal of CRD to have per-host mapping
`(cid:190)Both experts agree CRD cannot distinguish multiple hosts
`on one channel
`
`28
`
`28 of 101
`
`
`
`PPetitioners Assert in their Reply that One
`HHost Per Channel is a Per-Host System
`Rather than a Channel Based System –
`the Evidence Shows Otherwise
`
`29
`
`29 of 101
`
`
`
`FFurther Evidence that Petitioners’’ OOriginal Combination
`FFails is Their Attempt in the Reply to Rely on a
`Single Host Per Channel
`
`The Petition relied on multiple hosts on a single Fibre Channel loop
`Petitioners’ Reply relies on a “one host per channel” configuration:
`Petition
`
`
`
`
`
`
`
`1226 Pet. at 40-411226 Pet1 at 40 44141
`
`
`
`Reply
`
`…
`
`1226 Reply at 14
`
`30
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`30 of 101
`
`
`
`TThe Invention Requires Mapping Hosts to Storage, NOT
`Mapping Channel/Controller to Storage as Petitioners Assert
`
`In reply, Petitioners assert that putting one host on one channel in the CRD
`invalidates the patents. BUT, this ignores that the basic function of the
`patents is to allocate specific storage to specific hosts—NOT to a Channel
`
`31
`
`31 of 101
`
`
`
`The Claimed Invention Maps to Devices, Not a
`Channel (i.e. First Controller)
`
`Ex. 2027 (Levy Decl.) ¶ 89
`
`‘035 Patent; Claim 1
`
`1226 Pet. at 28-29; 1226 POR at 8-9, 14-23 32
`
`32 of 101
`
`
`
`TThe Capability to Map to Hosts is the Basic Function of the
`IInvention Not an Incidental Result
`
`The invention requires the capability to map different storage to
`different hosts on the same transport medium (i.e., a common
`communications link):
`
`cited in 1226 POR at 8 33
`
`33 of 101
`
`
`
`CClaimed Access Controls are Specific to the Host Device
`
`Ex. 2027 (Levy Decl.) ¶ 43
`
`cited in 1226 POR at 11-12
`
`34
`
`34 of 101
`
`
`
`EEven with One Host Per Channel, the Combination Does Not
`SShow Host Device Specific Access Controls
`
`Because the CRD-5500 Assigns Storage to Channels, Moving the Host to
`another Channel Provides Access to Different Storage.
`
`cited in 1226 POR at 37-38 35
`
`35 of 101
`
`
`
`TThe Combination Does Not Allocate Storage to Particular Hosts
`AAccording to a Map, Access to Storage is Determined by
`Physical Cabling
`
`Ex. 2027 (Levy Decl.) ¶ 94
`
`cited in 1226 POR at 38
`
`36
`
`36 of 101
`
`
`
`PPetitioners’ One Host Per Channel Combination
`DDoes Not Meet the Claimed Map
`Which Requires Mapping Hosts to Storage Space
`
`• New combination - not a basis upon which trial was
`instituted
`
`• Having only one host on one channel does not
`change a channel allocation system like CRD into the
`per-host mapping system of the claimed invention
`
`37
`
`37 of 101
`
`
`
`•
`
`PPetitioners Have Failed to Prove Unpatentability
`oon any Asserted Ground
`The invention includes mapping and access controls between particular
`hosts and storage space
`• Petitioners’ combination uses the Host LUN Mapping of the CRD As-Is, with
`no capability to map to hosts
`o The CRD and its Host LUN Mapping are only capable of allocating storage to
`channels
`o Adding Fibre Channel does not change any of these capabilities
`
`•
`
`In their Reply, Petitioners state that one of skill in the art would add new
`capabilities to the Host LUN Mapping to map to hosts
`o New combination - not a basis upon which trial was instituted
`o No evidentiary support - Hospodor says no changes for combination
`o Petitioners’ position in reply is based on an erroneous foundation
`
`• Petitioners assert in their Reply that one host per channel is a per-host
`system rather than a channel based system – the evidence shows otherwise
`o New combination – not a basis upon which trial was instituted
`
`38
`
`38 of 101
`
`
`
`TThank You
`
`39
`
`39 of 101
`
`
`
`CClaim Terms – Map
`
`40
`
`40 of 101
`
`
`
`“Mapping” Limitations
`
`The claimed “mapping between devices connected to
`the first transport medium and the storage devices”
`requires that the claimed map specifically identify the
`host and its associated storage in order to allocate
`storage to particular hosts.
`
`1226 POR at 11; 1463 POR at 10; 1544 POR at 8
`
`41
`
`41 of 101
`
`
`
`Petitioners Argue Against a Straw Man Claim
`Construction Requiring Permanent Host Identification
`
`Petitioners’ Reply Creates a Straw Man Claim Construction
`Requiring Permanent Host Identification
`
`Patent Owner Never Argues that the Host Identifier Must Be
`Perpetually Associated with a Particular Computer
`
`1226 Reply at 4
`
`42
`
`42 of 101
`
`
`
`Mapping Requires Identification of Particular Hosts, Not
`Perpetual Identification of Hosts
`
`• “One of the ordinary skill in the art. . . would understand from the plain
`language and context of the claims that ‘map[ping]’ requires specifying a
`particular configuration– namely the association between a particular
`workstation and a particular remote storage device)” Ex. 2032 (Pet. Claim
`Construction Brief) at 3
`• It further appears that this mapping prevents an initiator from accessing a
`subset of storage not allocated to it—i.e. subsets of storage “can only be
`accessed by the associated workstation.” Ex. 1003 (Hospodor Decl.) ¶ 31
`cited in 1226 Pet. at 14
`• So the subsets 66, 68, 70, and 72 here can only be accessed by associated
`workstation 58, meaning that they can only be accessed by the workstation
`58 that’s associated with that subset. Ex. 2028 (Hospodor Depo.)
`at 121:12-26
`
`cited in 1226 POR at 6-7, 9-10
`
`43
`
`43 of 101
`
`
`
`The Claimed Map Must Identify the Particular Host
`
`The specification requires the map to allocate storage to hosts so that it can only
`be accessed by the associated host
`
`1226 POR at 7-8
`
`44
`
`44 of 101
`
`
`
`The Claimed Map Must Identify the Particular Host
`
`If the map does not identify the host it cannot limit access to allocated
`storage to the associated workstation on the first transport medium
`
`Ex. 2027 (Levy Decl.) ¶ 39
`
`cited in 1226 POR at 9
`
`45
`
`45 of 101
`
`
`
`“The Claims Have to Do with What’s in the Map,
`Not How it’s Created”
`
`Ex. 1025 (Levy Depo.) at 155:16-156:2
`
`
`
`FRE 106 (1226 Pet. Reply at 10, 19)FRE 106 (1226 Pet. Reply at 10, 19)
`
`46
`
`46 of 101
`
`
`
`CClaim Terms –
`Access Controls
`
`47
`
`47 of 101
`
`
`
`“Access Control” Limitations
`
`[A]ccess controls . . . refer to controls that limit a host
`computer’s access to a specific subset of storage
`devices or sections of a single storage device according
`to a map. That is, the access controls are device specific
`in that they limit a particular device’s access to specified
`storage according to the map.
`
`1226 POR at 11-12; 1544 POR at 11; see 1463 POR at 10-11
`
`48
`
`48 of 101
`
`
`
`Petitioners Create a Straw Man from
`Patent Owner’s Response
`
`1226 Reply at 8
`Patent Owner then asserts, however,
`that to meet the “access control”
`limitation, the prior art must
`additionally “provid[e] different
`storage access to different hosts.”
`Resp. at 35
`
`1226 POR at 35
`Unlike the claimed storage router, the
`CRD-5500 is incapable of providing
`different storage access to different
`hosts connected to the CRD-5500 by a
`common communications link.
`
`The claimed access controls must only be capable of providing different
`storage access to different hosts.
`
`49
`
`49 of 101
`
`
`
`Petitioners’ Global Data Argument
`Misreads the Specification
`
`1226 Reply at 9
`
`The fact that global data 65 can
`be accessed by all the
`workstations does not mean all
`workstations have access to the
`same storage, which includes
`non-global storage on Storage
`Devices 62 and 64
`1226 POR at 12-13
`‘035 Patent at 4:48-54
`
`50
`
`50 of 101
`
`
`
`Petitioners’ Global Data Argument Ignores the
`Language of the Claims
`
`• Claim 2: “the supervisor unit maintains an allocation of subsets of storage
`space to associated devices connected to the first transport medium,
`wherein each subset is only accessible by the associated device connected
`to the first transport medium.”
`
`• “The plain reading of claim 2 is that the storage router is allocating subsets
`of storage to multiple devices on the first transport medium and then
`providing the capability of access control so that each particular subset may
`only be accessed by the particular host to which it has been allocated, not
`to every host.” Ex. 2027 ¶ 97 (citing ‘035 Patent at 4:22-24) (“[E]ach
`partition is allocated to one of the workstations 58 (workstation A, B, C, and
`D). These subsets 66, 68, 70 and 72 can only be accessed by the workstation
`58”)
`
`cited in 1226 POR at 40-41
`
`51
`
`51 of 101
`
`
`
`The Invention Requires the Capability to Provide
`Different Storage Access to Different Hosts
`
`1226 POR at 36
`
`Ex. 2027 (Levy Decl.) ¶ 91
`
`cited in 1226 POR at 36
`
`52
`
`52 of 101
`
`
`
`CChannel Numbers are Not
`Host Specific Identifiers Such as SCSI ID
`and AL_PA
`
`53
`
`53 of 101
`
`
`
`CChannel Numbers are not Host Identifiers
`
`•
`
`Petitioners Assert that Channel Numbers are Representations of a Particular
`Host, Just Like SCSI ID and AL_PA
`BUT
`• At any given time, AL_PA (for instance) is a unique identifier for one particular
`host on a Fibre Channel loop, and can (unlike channel numbers) be used to
`distinguish between multiple hosts on the same transport medium (’035
`Patent at 8:9-11)
`Petitioners admit the claimed storage router uses host identifiers like AL_PA
`and SCSI ID:
`
`•
`
`1226 Reply at 5
`
`54
`
`54 of 101
`
`
`
`AA Host Identifier Must Distinguish Between Multiple Hosts on a
`BBus or Loop
`
`Ex. 1025 (Levy Depo.) at 129:18-24
`
`cited in 1226 PO Motion to Exclude at 3-4 (FRE 106)
`
`55
`
`55 of 101
`
`
`
`SSCSI ID and AL_PA Always Identify One and Only One Particular
`HHost
`
`“This configuration can be straightforward, and can consist of providing the device a
`loop-unique ID (AL_PA) in the range of ‘01h’ to ‘Efh.’” ‘035 Pat. 8:9-11
`
`Ex. 1025 (Levy Depo.) at 109:10-24
`
`
`
`1226 Reply at 3-8 (FRE 106)1226 Reply at 3-8 (FRE 106)
`
`56
`
`56 of 101
`
`
`
`SCSI ID and AL_PA Always Identify One and
`Only One Particular Host
`
`
`
`Ex. 1025 (Levy Depo.) at 127:1-20Ex. 1025 (Levy Depo.) at 127:1-20
`
`
`
`cited in 1226 PO Motion to Exclude at 5 (FRE 106)106)
`
`cited in 1463 POR at 36
`
`
`
`(1463) Ex. 2027 (Levy Decl.) ¶ 74(1463) Ex. 2027 (Levy Decl.) ¶ 74
`
`57
`
`57 of 101
`
`
`
`CChannel Numbers Cannot Distinguish
`Between Any Hosts on a Bus or Loop
`
`Channel Numbers Do Not Identify Particular Hosts
`
`Ex. 2027 (Levy Decl.) ¶ 53
`
`cited in 1226 POR at 15
`
`58
`
`58 of 101
`
`
`
`AAny Host Connected to a Channel Gets the Same Access as All
`HHosts Connected to Same Channel
`
`Ex. 2027 (Levy Decl.) ¶ 71
`
`Ex. 2028 (Hospodor Depo.) at 195:5-8; see also 194:5-9, 17-22
`
`
`
`cited in 1226 POR at 17, 21-22cited in 1226 PO
`
`59
`
`59 of 101
`
`
`
`SSCSI ID and AL_PA are
`Different in Kind from Channel Number
`
`• Whether Temporarily or Permanently Assigned,
`SCSI ID and AL_PA Are Used to Distinguish Between
`Hosts on a Bus or Loop
`
`• CRD Channel Numbers Are Not Associated with
`Hosts at All, But Ports, and Do Not Identify any Host
`Cabled to the Port
`
`• Channel Numbers Cannot Be Used to Differentiate
`Between Multiple Hosts on the Same Channel
`
`60
`
`60 of 101
`
`
`
`PPetitioners Conflate Cable Swapping
`with Reassigning Host IDs
`
`2 Types of Physical Reconfigurations
`Cable Swapping
`Reassigning Host IDs
`
`Administrator assigns same SCSI ID to
`different computer:
`For example, when Dr. Levy was
`asked about the consequences of
`reconfiguring Fig. 3 so that
`“Workstation A” is replaced with a
`different workstation assigned the
`same SCSI ID, as discussed above,
`he acknowledged that the
`replacement workstation would
`now be given access to Workstation
`A’s storage…
`1226 Reply at 10
`
`1226 POR at 37-38
`
`61
`
`61 of 101
`
`
`
`TThe Patents Acknowledge that the Basic Functionality of the
`IInvention is Not Dependent on Permanent Host Identification
`
`‘035 Patent
`
`‘035 Patent 7:62-65
`
`‘035 Patent 8:5-11
`
`see 1226 PO Motion to Exclude at 8
`
`62
`
`62 of 101
`
`
`
`TThe Patent Describes How the System Can Be Configured to
`EEnsure Known Addresses are Always Provided for the Map
`
`‘035 Patent 7:5-12
`
`‘035 Patent
`
`See 1226 PO Motion to Exclude at 8 (citing Ex. 1025 (Levy Depo.))
`
`63
`
`63 of 101
`
`
`
`LLevy Confirms the Patent Acknowledges that Changes to Host
`IIDs Might Cause Data Corruption or Loss
`
`Ex. 1025 (Levy Depo.) at 195:4-196:1
`
`
`
`cited in 1226 PO Motion to Exclude at 8 (FRE 106) cited in 1226 PO Motion to Exclud
`
`64
`
`64 of 101
`
`
`
`WWhether Host IDs are “Hard” or “Temporary” the Basic
`Functionality of the Invention is Met
`
`• The Basic Functionality of the Patent is Still Present
`Whether Host IDs are “Hard” or “Temporary”: the Host IDs
`refer to a Particular Host. ‘035 Pat. 8:5-9
`
`• Even if a Power Cycle or Loop Reconfiguration Changes the
`Host ID, it will Still Meet the Basic Functionality of the
`Invention (‘035 Patent, 7:62-65, 8:9-11).
`
`• The Patent Specifically Envisioned and Discussed Both
`Temporary and Hard IDs as Part of the Basic Functionality
`of the Invention. ’035 Pat. 8:5-9, 7:1-13, 7:56-65.
`
`• Channel Numbers Never Refer to a Particular Host.
`
`65
`
`65 of 101
`
`
`
`TThe Claimed Access Controls Use a Host to Storage Map
`
`The invention requires the capability to map different storage to
`different hosts on the same transport medium (i.e., a common
`communications link):
`
`cited in 1226 POR at 8 66
`
`66 of 101
`
`
`
`AAL_PA is Unique to Devices on a Fibre Channel Loop, and Even
`iif Changed Meet the Basic Functionality of the Invention
`
`• Petitioners state that “a SCSI ID does not intrinsically identify any particular
`host” and that because an AL_PA may be associated with “a different host
`after every reconfiguration” it “does not identify any one particular host in
`[an] intrinsic manner.” Reply at 6.
`
`• Merely because SCSI ID and AL_PA do not permanently identify a host does
`not mean they do not always refer to one and only one particular host at a
`time. Motion to Exclude at 3-4, 6-7.
`
`• AL_PA is unique on the Fibre Channel Loop. ‘035 Patent, 8:9-11
`
`• Even if the AL_PA of a device changes it still meets the basic functionality of
`the invention. ‘035 Patent, 7:62-65, 8:5-9.
`
`67
`
`67 of 101
`
`
`
`OOBJECTIVE EVIDENCE
`
`68
`
`68 of 101
`
`
`
`PPatent Owner Presented Evidence of Commercial Success
`
`• Patent Owner’s Evidence Shows Commercial Success is Due to
`the Claimed Features of Access Controls
`
`• Objective evidence of Non-obviousness Need Only Be
`Reasonably Commensurate with the Scope of the Claims
`
`69
`
`69 of 101
`
`
`
`CCrossroads’’ Sales Records Show Routers with Access Controls
`WWere Preferred Over Bridges Without Access Controls
`
`Ex. 2043 (Bianchi Decl.) ¶ 2
`
`cited in 1226 POR at 52-53
`
`70
`
`70 of 101
`
`
`
`CCrossroads’’ Sales Records Show Routers with Access Controls
`WWere Preferred Over Bridges Without Access Controls
`
`Ex. 2044 (Bianchi Decl.) at 3,5
`
`
`
`cited in 1226 POR at 52-53cited in 1226 POR at 52-53
`
`71
`
`71 of 101
`
`
`
`TThe NNexus Requirement Does Not Require Patent Licenses to
`RRecite Claim Limitations
`
`• Petitioners’ Position Would Effectively Require Licenses to Recite
`Particular Claims or Claim Limitations (1226 Reply at 24).
`
`• Crossroads’ Licenses Specify the Patent Family at Issue
`
`• Requiring Licenses to Recite Claims instead of Patent Families
`Ignores the Real World and Would Mean Licenses Can Never Be
`Used as Objective Evidence
`
`• Crossroads’ Licensing Program as a Whole, Including
`Non-Litigation Related Licenses, indicates the Invention
`was Non-Obvious
`
`cited in 1226 POR at 54-55
`
`72
`
`72 of 101
`
`
`
`CClaim 1 U.S. Patent Number 6,425,035 B2
`
`73
`
`73 of 101
`
`
`
`CClaim 2 U.S. Patent Number 6,425,035 B2
`
`74
`
`74 of 101
`
`
`
`CClaim 8 U.S. Patent Number 6,425,035 B2
`
`75
`
`75 of 101
`
`
`
`CClaim 11 U.S. Patent Number 6,425,035 B2
`
`76
`
`76 of 101
`
`
`
`CClaim 12 U.S. Patent Number 6,425,035 B2
`
`77
`
`77 of 101
`
`
`
`CClaim 1 U.S. Patent Number 7,051,147 B2
`
`78
`
`78 of 101
`
`
`
`CClaim 2 U.S. Patent Number 7,051,147 B2
`
`79
`
`79 of 101
`
`
`
`CClaim 7 U.S. Patent Number 7,051,147 B2
`
`80
`
`80 of 101
`
`
`
`CClaim 10 U.S. Patent Number 7,051,147 B2
`
`81
`
`81 of 101
`
`
`
`CClaim 11 U.S. Patent Number 7,051,147 B2
`
`82
`
`82 of 101
`
`
`
`CClaim 14 U.S. Patent Number 7,051,147 B2
`
`83
`
`83 of 101
`
`
`
`CClaim 21 U.S. Patent Number 7,051,147 B2
`
`84
`
`84 of 101
`
`
`
`CClaim 28 U.S. Patent Number 7,051,147 B2
`
`85
`
`85 of 101
`
`
`
`CClaim 34 U.S. Patent Number 7,051,147 B2
`
`86
`
`86 of 101
`
`
`
`CClaim 1 U.S. Patent Number 7,934,041 B2
`
`87
`
`87 of 101
`
`
`
`CClaim 14 U.S. Patent Number 7,934,041 B2
`
`88
`
`88 of 101
`
`
`
`CClaim 15 U.S. Patent Number 7,934,041 B2
`
`89
`
`89 of 101
`
`
`
`CClaim 20 U.S. Patent Number 7,934,041 B2
`
`90
`
`90 of 101
`
`
`
`CClaim 33 U.S. Patent Number 7,934,041 B2
`
`91
`
`91 of 101
`
`
`
`CClaim 34 U.S. Patent Number 7,934,041 B2
`
`92
`
`92 of 101
`
`
`
`CClaim 37 U.S. Patent Number 7,934,041 B2
`
`93
`
`93 of 101
`
`
`
`CClaim 50 U.S. Patent Number 7,934,041 B2
`
`94
`
`94 of 101
`
`
`
`CClaim 51 U.S. Patent Number 7,934,041 B2
`
`95
`
`95 of 101
`
`
`
`HHospodor Declaration
`
`Ex. 1003 (Hospodor Decl.) ¶ 61 (cited in 1226 Reply at 19)
`
`96
`
`96 of 101
`
`
`
`PPetitioners Rely on tthe Knowledge of One of Ordinary Skill in
`tthe Art to Create New Data Structures Using a Host Identifier
`IInstead of the Channel Number
`
`Petitioners attempt to shoe-horn these changes under the umbrella of
`simple modifications which are not explained in the Petition:
`
`
`
`1226 Reply at 166 Reply at 16
`
`97
`
`97 of 101
`
`
`
`DDr. Levy Testified One of Skill in the Art Could Create the
`Claimed Map Only After Reviewing the Specification
`
`Neither the Petition nor the CRD-5500 Manual contain any motivation to create
`new data structures containing host specific IDs, because the CRD-5500’s goal is
`not assigning redundancy groups to a particular host.
`Dr. Levy testified that a POSITA could create the claimed map only after being told
`the function and reading the specification—i.e., only with the benefit of hindsight
`in light of the specification.
`
`Ex. 1025 219:25-220:1
`
`Ex. 1025 94:8-12
`
`98
`
`
`
`1226 Reply at 16 (FRE 106) 1226 Reply at 16 (FRE 106)
`
`98 of 101
`
`
`
`PPetitioners’ Prroposed CCoonstructions aand the CClaims
`RRequire the Capability to Handle Multiple Hosts
`on a Single Transport Medium
`
`The invention requires the capability to map different storage
`to different hosts on the same transport medium (i.e., a
`common communications link):
`Petitioners’ proposed constructions for mapping limitations:
`
`1226 Pet. at 14
`
`1544 Pet. at 11
`
`99
`
`99 of 101
`
`
`
`PPetitioners’ Proposed Constructions and the Claims
`RRequire the Capability to Handle Multiple Hosts
`on a Single Transport Medium
`
`Petitioners proposed no relevant construction in the -1463 Proceeding,
`but the ‘041 Patent Requires Such Capability:
`
`1463 POR at 23
`
`100
`
`100 of 101
`
`
`
`HHost LUN Mapping
`
`Ex. 1004 at 4-5
`
`101
`
`101 of 101
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