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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`———————
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`———————
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`
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`CISCO SYSTEMS, INC. AND QUANTUM CORPORATION,
`Petitioners,
`
`v.
`
`CROSSROADS SYSTEMS, INC.,
`Patent Owner
`
`———————
`
`
`
`PETITION FOR INTER PARTES REVIEW
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`OF
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`U.S. PATENT NO. 7,934,041
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`TABLE OF CONTENTS
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`I. Mandatory Notices ............................................................................................. 1
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`A. Real Party-in-Interest ................................................................................ 1
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`B. Related Matters ......................................................................................... 1
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`C. Lead and Back-up Counsel and Service Information .............................. 2
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`II. Grounds for Standing ......................................................................................... 2
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`III. Relief Requested ................................................................................................ 2
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`IV. The Reasons for the Requested Relief ............................................................... 3
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`A. Summary of Reasons ................................................................................ 3
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`B. The ’041 Patent ......................................................................................... 4
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`1. Overview .......................................................................................... 4
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`2.
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`Prosecution History .......................................................................... 8
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`C.
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`Identification of Challenges ..................................................................... 9
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`1. Challenged Claims ........................................................................... 9
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`2.
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`Statutory Grounds for Challenges .................................................... 9
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`3. Claim Construction ........................................................................ 10
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`i.
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`ii.
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`“native low level block protocol” ........................................... 11
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`“remote” .................................................................................. 12
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`4.
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`Identification of How the Claims Are Unpatentable ..................... 13
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`i.
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`Challenge #1: Claims 1-14, 16-33, 35-50 and 53 are obvious
`over the CRD Manual in view of the HP Journal ................... 13
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`ii. Challenge #2: Claims 15, 34, 51, 52 are obvious over the CRD
`Manual in view of the HP Journal and in further view of the
`Fibre Channel Standard .......................................................... 56
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`V. Conclusion ....................................................................................................... 60
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`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
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`I. Mandatory Notices
`A. Real Party-in-Interest
`The real parties-in-interest are Cisco Systems, Inc. and Quantum
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`Corporation (“Petitioners”).
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`B. Related Matters
`Petition for Inter Partes Review, IPR2014-01177, filed July 18, 2014;
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`Crossroads Systems, Inc. v. Quantum Corporation, 1-14-cv-00150, TXWD, filed
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`February 18, 2014; Crossroads Systems, Inc. v. NetApp, Inc., 1-14-cv-00149,
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`TXWD, filed February 18, 2014; Crossroads Systems, Inc. v. Cisco Systems, Inc.,
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`1-14-cv-00148, TXWD, filed February 18, 2014; Crossroads Systems, Inc. v.
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`Huawei Technologies Co. Ltd. et al, 1-13-cv-01025, TXWD, filed November 26,
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`2013; Crossroads Systems, Inc. v. Oracle Corporation, 1-13-cv-00895, TXWD,
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`filed October 7, 2013. Also, (i) case nos. IPR2014-01197 (filed July 23, 2014) and
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`IPR2014-01226 (filed July 31, 2014) have been filed against U.S. Patent No.
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`6,425,035, which is related to the ’041 patent; and (ii) case nos. IPR2014-01207
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`(filed July 25, 2014) and IPR2014-01209 (filed July 25, 2014) have been filed
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`against U.S. Patent No. 7,051,147, which is related to the ‘041 patent.
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`Additionally, this petition refers to a claim construction order from Crossroads
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`Systems, Inc. v. 3PAR, Inc., et. al., no. 1-10-cv-00652 (W.D. Tex. 2010), which is
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`one of the district court litigations involving U.S. Patent No. 6,425,035, which is
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`related to the ’041 patent.
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`C. Lead and Back-up Counsel and Service Information
`Lead Counsel
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`David L. McCombs
`Phone: (214) 651-5533
`HAYNES AND BOONE, LLP
`Fax: (214) 200-0853
`2323 Victory Ave. Suite 700
`david.mccombs.ipr@haynesboone.com
`Dallas, TX 75219
`USPTO Reg. No. 32,271
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`
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`Back-up Counsel
`Phone: (214) 651-5116
`Andrew S. Ehmke
`Fax: (214) 200-0853
`HAYNES AND BOONE, LLP
`andy.ehmke.ipr@haynesboone.com
`2323 Victory Ave. Suite 700
`USPTO Reg. No. 50,271
`Dallas, TX 75219
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`
`Scott T. Jarratt
`Phone: (972) 739-8663
`HAYNES AND BOONE, LLP
`Fax: (214) 200-0853
`2323 Victory Ave. Suite 700
`scott.jarratt.ipr@haynesboone.com
`Dallas, TX 75219
`USPTO Reg. No. 70,297
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`II. Grounds for Standing
`Petitioners certify that they are not estopped or barred from requesting inter
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`partes review of the ’041 Patent. Petitioners were each served with a complaint
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`asserting infringement of the ’041 Patent on February 18, 2014, which is not more
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`than one year before the filing of this Petition. Neither petitioner has initiated a
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`civil action challenging the validity of any claim of the ’041 Patent. Petitioners
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`also certify that the ’041 Patent is eligible for inter partes review.
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`III. Relief Requested
`Petitioners ask that the Patent Trial and Appeal Board (“the Board”) review
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`the accompanying prior art and analysis, institute a trial for inter partes review of
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`claims 1-53 (all claims) of the ’041 Patent, and cancel those claims as invalid.
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`IV. The Reasons for the Requested Relief
`The full statement of the reasons for the relief requested is as follows:
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`A.
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`Summary of Reasons
`In short, the claims of the ’041 Patent simply recite obvious combinations of
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`network storage components with functionality that was well-known at the time of
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`the ’041 Patent invention. For example, each of the ’041 Patent’s three
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`independent claims generally include limitations directed to (i) mapping
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`workstations on one side of a storage router to specific storage devices on the other
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`side of the storage router, and (ii) routing block-level data between the
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`workstations and the storage devices based on the mapping so that the workstations
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`may only access the particular storage devices to which they are mapped. In one
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`embodiment of the ’041 specification, the storage router is a bridge between
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`workstations on a Fiber Channel link and storage devices on a SCSI bus, and the
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`block-level data flowing between the workstations and storage devices conforms to
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`the SCSI protocol. CQ-1001, 5:34-63; Fig. 3.
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`These elements were well known in the prior art. For example, in 1996,
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`CMD Technologies sold a storage router, the CRD-5500 SCSI RAID Controller,
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`that performed the functions recited in the claims. According to the CRD-5500
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`user’s manual, the CRD-5500 Controller (i) allows users to map hosts on one side
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`of the controller to specific storage devices on the other side of the controller and
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`then (ii) routes SCSI commands from hosts to storage devices based on the map,
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`while blocking hosts from accessing storage devices to which they were not
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`mapped. CQ-1004, pp. 1-1, 1-2, 1-11, 4-2, 4-5.
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`In one configuration, the CRD-5500 Controller routes data between hosts on
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`a SCSI bus link and storage devices on a SCSI bus link; however, the CRD-5500
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`Controller was designed to support serial links through the use of different I/O
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`adapter cards. CQ-1004, pp. 1-1, 2-1, 2-4; CQ-1005, p. 1. One of ordinary skill in
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`the art at the time of the ’041 Patent would have been motivated to modify the
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`CRD-5500 Controller using different I/O adapter cards to take advantage of the
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`benefits of other communications links, such as Fibre Channel. CQ-1003, pp. 31-
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`36. Fiber Channel was known to alleviate the limitations of SCSI buses (the default
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`CRD-5500 configuration). CQ-1006, pp. 5, 94, 99.
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`Consequently, this petition demonstrates that claims 1-53 merely recite
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`features that were well known in the prior art and are therefore rendered obvious
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`over the references presented in this petition.
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`B.
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`The ’041 Patent
`1. Overview
`The ’041 Patent has three independent claims (claims 1, 20, and 37) and a
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`total of 53 claims. The ’041 Patent generally describes a “storage router” that
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`routes storage requests between workstations and storage devices. CQ-1001,
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`Abstract. Figure 3 of the ’041 Patent illustrates the architecture of the storage
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`network in which the storage router operates:
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`Storage Router
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`SCSI Bus
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`Workstations
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`Fibre Channel
`link
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`CQ-1001, Fig. 3 (annotated);
`CQ-1003, p. 13
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`Storage devices
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`
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`As shown in Fig. 3, workstations on a Fiber Channel link (i.e., a transport
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`medium) are connected to one side of the storage router (the “host side”), and
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`storage devices on the SCSI bus communication link are connected to the other
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`side of the storage router (the “disk side”). CQ-1001, 4:25-34. The specification
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`describes the storage router as “a bridge device that connects a Fiber Channel link
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`directly to a SCSI bus.” Id. at 5:59-62.
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`According to the specification, a “SCSI command” is an example of a native
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`low level block protocol command and the storage router enables the exchange of
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`SCSI commands and data between the workstations and the storage devices. Id. at
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`5:61-63. Additionally, the specification states that Fiber Channel-based
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`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
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`commands into Fiber Channel Protocol (FCP) requests. Id. at 6:43-55. As
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`discussed below in more detail, encapsulating SCSI commands inside a Fiber
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`Channel request was a feature of the Fibre Channel standard, and was well known
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`in the art at the time of the ’041 invention. See CQ-1006, pp. 94-95.
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`The specification states that the storage router uses “mapping tables” to
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`allocate subsets of storage space (e.g., partitions) on the storage devices to
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`particular workstations. CQ-1001, 4:39-44. For example, referring to Fig. 3,
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`“[s]torage device 62 can be configured to provide partitioned subsets 66, 68, 70
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`and 72, where each partition is allocated to one of the workstations 58.” Id. at 4:47-
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`49. Also, the specification states that the storage router provides “virtual local
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`storage” such that a mapped partition is “considered by the workstation 58 to be its
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`local storage”—i.e., the mapped partition “has the appearance and characteristics
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`of local storage.” Id. at 4:4-14, 4:39-40. As discussed below in more detail, it was
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`well known in the art at the time of the ’041 invention to map workstations on one
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`side of a storage router to partitions on the other side of the storage router, and to
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`make the partitions appear as local disks. See CQ-1004, pp. 1-2, 3-6, 4-5.
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`According to the specification, the storage router uses the mapping
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`functionality to facilitate both routing and access control. CQ-1001, 5:50-54. For
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`routing, the specification states that the map between the initiators and the specific
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`subsets of storage allows the storage router to determine “what partition is being
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`addressed by a particular request,” thus enabling it to “distribute[] requests and
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`data” to storage devices Id. at 9:21-27, 4:18-19. For access control, the
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`specification states that the storage router prevents a workstation from accessing a
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`subset of storage not allocated to it in the map. Id. at 9:15-27. For example, in Fig.
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`3, “subsets 66, 68, 70 and 72 can only be accessed by the associated workstation
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`58.” Id. at 4:50-51. As discussed below in more detail, the concept of using a map
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`to facilitate routing and access control of storage devices was well known in the art
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`at the time of the ’041 Patent invention. See CQ-1004, pp. 1-2, 4-5.
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`To illustrate the general flow of I/O commands in the storage network of the
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`’041 Patent, Fig. 3 is further annotated below:
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`(i) workstation B sends
`a SCSI I/O command
`to its “virtual local
`storage”
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`(ii) storage router uses map to
`determine which partition is
`allocated to workstation B
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`CQ-1001, Fig. 3 (annotated);
`CQ-1003, p. 15
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`(iii) partition mapped to workstation
`B receives SCSI I/O command
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`In addition to the mode of operation shown associated with Fig. 3, the ’041
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`specification notes that the “storage router has various modes of operation,”
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`including a mode in which the storage router routes data between a Fibre Channel
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`host and a Fibre Channel storage device. CQ-1001, 6:43-46.
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`Because communicating SCSI commands over Fibre Channel, mapping
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`workstations to storage partitions, and using the mapping for routing and access
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`control were well known in the art at the time of the ’041 invention, the storage
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`network described by the ’041 Patent is simply a collection of components that
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`were well known in the art at the time of the ’041 Patent invention. CQ-1003, ¶ 20-
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`21. And, as shown below, these well-known components are arranged in a manner
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`that would have been obvious to one of ordinary skill in the art. Id.
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`2.
`Prosecution History
`The ’041 Patent issued on April 26, 2011, from U.S. Patent Application No.
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`12/690,592 (“the ’592 application”) filed on Jan. 20, 2010 by Geoffrey B. Hoese
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`and Jeffry T. Russell. The ’041 Patent is purportedly a continuation of a string of
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`patent applications claiming priority to U.S. patent application Ser. No.
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`09/001,799, filed on Dec. 31, 1997.
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`During the prosecution of the ’592 application, Patent Owner, in response to
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`a double patenting rejection over “all of the related Patent/Applications,” filed a
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`Terminal Disclaimer disclaiming any patent term extending beyond the life of 12
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`U.S. Patents and 10 pending-at-the-time U.S. Patent Applications. CQ-1002, pp.
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`1647-48, 1689-99. The Examiner then issued a Notice of Allowance without a
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`substantive rejection of the claims. CQ-1002, 1722-25.
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`Based on the above, it appears that during the course of the prosecution of
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`the ’041 Patent, the Patent Office never substantively considered the relevance of
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`the CRD Manual, the HP Journal, or the Fibre Channel Standard to the claims.
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`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
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`Identification of Challenges
`1.
`Challenged Claims
`Claims 1-53 of the ’041 Patent are challenged in this petition.
`
`2.
`Statutory Grounds for Challenges
`Challenge #1: Claims 1-14, 16-33, 35-50 and 53 are obvious under 35 U.S.C. §
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`103(a) over the CRD-5500 SCSI Raid Controller User's Manual (“CRD Manual”)
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`in view of Volume 47, issue 5 of the Hewlett-Packard Journal (“HP Journal”). The
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`CRD Manual is dated November 21, 1996 and was available for public download
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`from the CMD Technologies website at least by December 26, 19961, and is thus
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`prior art under 35 U.S.C. § 102(b). The HP Journal was published in October 1996,
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`and the HP Journal Online website notes that the “HP Journal has been available
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`1 The CRD Manual was archived on by December 26, 1996 by the Internet Archive
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`Wayback Machine and is available at
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`http://web.archive.org/web/19961226085953/http://www.cmd.com/ftproot/pub/rai
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`d/5500/manual/crd5500user.pdf. “Prior art disclosures on the Internet or on an on-
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`line database are considered to be publicly available as of the date the item was
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`publicly posted.” MPEP § 2128. The PTO identifies the Internet Archive Wayback
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`Machine as a mechanism for determining the publication date of electronic
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`documents such as those from the Internet. See,
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`http://uspto.gov/patents/resources/methods/aiplafall02paper.jsp.
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`on the World Wide Web since early 1994.” See CQ-1011. The HP Journal is thus
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`prior art under 35 U.S.C. § 102(b).
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`Challenge #2: Claims 15, 34, 51 and 52 are obvious under 35 U.S.C. § 103(a) over
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`the CRD Manual and the HP Journal, further view of the Fibre Channel Physical
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`and Signaling Interface (FC-PH) X3.230 (“Fibre Channel Standard”). The Fibre
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`Channel Standard is dated June 1, 1994 and was published by the American
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`National Standards Institute. Thus, it is prior art under 35 U.S.C. § 102(b).
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`3.
`Claim Construction
`This petition presents claim analysis in a manner that is consistent with the
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`broadest reasonable construction in light of the specification. See 37 C.F.R. §
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`42.100(b). Under the broadest reasonable construction, claim terms are given their
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`ordinary and accustomed meaning as would be understood by one of ordinary skill
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`in the art in the context of the entire disclosure. In re Translogic Tech., Inc., 504
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`F.3d 1249, 1257 (Fed. Cir. 2007). Additionally, because the claim constructions
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`proposed herein are based on the broadest reasonable construction, they do not
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`necessarily apply to other proceedings that use different claim construction
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`standards. See Samsung Electronics Co., Ltd v. Virginia Innovation Sciences, Inc.,
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`IPR2013-00569, Paper 9 at *2, Oct. 30, 2013 (“[B]ecause the Board applies the
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`broadest reasonable construction standard, the Board’s construction may not be the
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`same as that adopted by a district court, which may apply a different standard.”).
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`“native low level block protocol”
`This claim term is found in claims 1, 6, 20, 25, 37 and 42. In the Crossroads
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`Systems, Inc. v. 3PAR litigation2 (in connection with related U.S. Patent No.
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`6,425,035), the District Court construed “native low level block protocol” to mean
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`“a set of rules or standards that enable computers to exchange information and do
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`not involve the overhead of high level protocols and file systems typically required
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`by network servers.” CQ-1010, p. 13.
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`The specification does not provide an explicit definition of “native low level
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`block protocol.” The specification, however, contrasts a workstation accessing “a
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`local storage device” using “native low level, block protocols” with a workstation
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`accessing network-based storage devices through a “network server” which
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`“implements a file system and transfers data to workstations 12 only through high
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`level file system protocols.” CQ-1001, 3:46-50. With reference to Fig. 3, the
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`specification states that subsets 66, 68, 70, and 72 of storage space are “accessed
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`using native low level, block protocols” and that “storage access involves native
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`low level, block protocols.” Id. at 4:47-53. One example in the specification of a
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`native low level block protocol command is a “SCSI command.” Id. at 5:59-63.
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`Thus, based upon the plain language of the claims and consistent with the
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`2 Crossroads Systems, Inc. v. 3PAR, Inc., et. al., no. 1-10-cv-00652 (W.D. Tex.
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`2010).
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`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
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`which storage space is accessed at the block level, such as the SCSI protocol.”
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`CQ-1003 at ¶¶ 27-31.
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`Whether the District Court construction or the foregoing construction is
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`applied, the prior art references relied upon in this petition teach this claim term.
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`See CQ-1003, pp. 55-57, 62-64.
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`ii.
`
` “remote”
`This term is found in claims 1-4, 7, 12, 13, 19-23, 26, 31, 32, 37-40, 43, 48,
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`49 and 53. In the 3Par litigation (in connection with related U.S. Patent No.
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`6,425,035), the District Court construed “remote” to mean “indirectly connected
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`through at least one serial network transport medium.” CQ-1010, p. 12.
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`The specification does not provide an explicit definition of “remote.” The
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`specification does describe that “the storage space considered by the workstation
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`58 to be its local storage is actually a partition (i.e., logical storage definition) of a
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`physically remote storage device 60, 62 or 64 connected through storage router
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`56.” CQ-1001, 5:8-14 (emphasis added). The specification also describes that
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`“[t]ypical storage transport mediums provide for a relatively small number of
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`devices to be attached over relatively short distances. One such transport medium
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`is a Small Computer System Interface (SCSI) protocol.” Id. at 1:51-59.
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`Thus, consistent with the surrounding language of the claims and the
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`specification, one of ordinary skill in the art would understand the broadest
`
`reasonable construction of “remote” to be “indirectly connected through a storage
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`router to enable connections to storage devices at a distance greater than allowed
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`by a conventional parallel network interconnect.” CQ-1003 at ¶¶ 32-36.
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`Whether the District Court construction or the foregoing construction is
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`applied, the prior art references relied upon in this petition teach this claim term.
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`See CQ-1003, pp. 39-40, 57, 90, 104-105.
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`4.
`
`Identification of How the Claims Are Unpatentable
`i. Challenge #1: 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
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`SCSI RAID Controller. The CRD-5500 Controller routes commands and data
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`between hosts (i.e., initiators) and storage devices (i.e., targets) coupled to the
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`controller. CQ-1004, pp. 1-1, 1-4.
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`Hosts attached to SCSI bus links are connected to the CRD-5500 Controller
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`(the “host side”) and storage devices attached to SCSI bus links are connected to
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`the CRD-5500 Controller (the “disk side”). Id. at p. 2-4. The CRD-5500 Controller
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`enables the exchange of SCSI commands and data between the hosts and the
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`storage devices. Id. at pp. 1-1, 1-4, 2-1, 2-4. Figure 1-2 in the CRD Manual
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`illustrates the storage network in which the CRD-5500 Controller operates:
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`Hosts
`
`CRD-5500 Controller
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`Host SCSI Buses
`
`Storage Device SCSI Buses
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`CQ-1004, p. 1-2
`(annotated);
`CQ-1003, p. 25
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`Storage
`d i
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`The CRD-5500 Controller includes a Monitor Utility in its user-upgradeable
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`firmware that gives a user “complete control over the configuration and operation
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`of the controller.” CQ-1004, pp. 4-1, 4-14. The Monitor Utility includes a “Host
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`LUN Mapping” feature that allows a user to map subsets of storage space on the
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`storage devices (referred to as “redundancy groups”) to specific hosts. Id. at pp. 1-
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`2, 1-11, 4-2, 4-5. A “LUN” is a logical unit number used to represent storage
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`space. CQ-1003, p. 25. Specifically, as shown below, the Host LUN Mapping
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`feature maintains a mapping table for each host, where each mapping table has a
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`set of virtual LUNs (numbered 0-31) to which the redundancy groups are mapped.
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`CQ-1004, pp. 1-2, 1-11, 4-2, 4-5. A host accesses the redundancy groups by
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`referencing its virtual LUNs. Id. For example, in the below Host LUN Mapping
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`configuration, the host associated with channel 0 may access redundancy group 5
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`by addressing SCSI commands to LUN 4. CQ-1003, p. 26:
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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. 26
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`
`
`
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`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
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`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. 27
`
`Additionally, because a host transmits SCSI commands to its set of virtual
`
`LUNs rather than the physical storage devices, the CRD-5500 Controller can
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`“make a redundancy group visible to one host but not to another.” CQ-1004, p. 1-
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`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.
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`at p. 4-5. Thus, the CRD-5500 not only routes commands, but can control access.
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`Further, the CRD-5500 Controller includes numerous slots for I/O adapter
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`cards through which the controller communicates with hosts and storage devices.
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`CQ-1004, pp. 1-1, 2-1, 2-4. A key feature of the CRD-5500 Controller is that it
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`“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, pg. 31
`
`
`
`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 additionally
`
`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 further 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.
`
`Additionally, the article provides details about how to implement a Fibre Channel
`
`I/O adapter card that uses the Tachyon chip. Id. at p. 111.
`
`(c) Reasons to Combine the CRD Manual and the HP Journal
`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 ¶¶ 48-57.
`
`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, the HP Journal 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). Additionally, “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
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`Journal notes that 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, ¶ 51.
`
`The HP Journal additionally teaches one of ordinary skill in the art 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, ¶ 53.
`
`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 the
`
`“host side” of the CRD-5500 Controller with a Fibre Channel I/O host module.
`
`CQ-1003, ¶ 53. In some instances, one of ordinary skill in the art would have also
`
`been motivated to replace the SCSI I/O modules on the “disk side” of the
`
`controller with one or more Fibre Channel I/O modules. Both substitutions 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. A Fibre Channel-based I/O module would have allowed the CRD-5500
`
`Controller to communicate with hosts and/or disks via a Fibre Channel transport
`
`medium rather than via SCSI buses, thereby overcoming many of the known
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`limitations of SCSI buses as described in the HP Journal. Id.
`
`Additionally, the beneficial result of modifying the CRD-5500 Controller to
`
`interface with a Fibre Channel transport medium 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, such as the CRD-5500 Controller. CQ-1006, pp. 94-95; CQ-1003, ¶¶ 54,
`
`55.
`
`Moreover, to the extent any modifications of the CRD Manual would have
`
`been needed in order to accommodate the teachings of the HP Journal, such
`
`modifications would have been within the level of ordinary skill in the art of
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`network storage. CQ-1003, ¶ 56. For example, because the CRD-5500 Controller
`
`was intended to be used with Fibre Channel, i