`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`———————
`
`PETITION FOR INTER PARTES REVIEW
`OF
`U.S. PATENT NO. 6,425,035
`
`
`
`
`
`
`
`
`
`ORACLE CORPORATION and
`DOT HILL SYSTEMS CORPORATION
`Petitioners,
`
`v.
`
`CROSSROADS SYSTEMS, INC.,
`Patent Owner
`———————
`
`
`
`TABLE OF CONTENTS
`
`I. This Petition Presents the Same Grounds Which Were Instituted in IPR2014-
`01226 ........................................................................................................................................... 1
`II. Mandatory Notices ............................................................................................................. 1
`A. Real Party-in-Interest ..................................................................................................... 1
`B. Related Matters ............................................................................................................... 1
`C. Lead and Back-up Counsel and Service Information ............................................... 2
`III. Grounds for Standing .................................................................................................... 3
`IV. Relief Requested ............................................................................................................. 3
`V. The Reasons for the Requested Relief ............................................................................ 3
`A. Summary of Reasons ...................................................................................................... 3
`B. The ‘035 Patent ............................................................................................................... 5
`1. Overview ...................................................................................................................... 5
`2. Prosecution History .................................................................................................... 9
`C. Identification of Challenges ........................................................................................ 10
`1. Challenged Claims ..................................................................................................... 10
`2. Statutory Grounds for Challenges .......................................................................... 10
`3. Claim Construction ................................................................................................... 11
`i. “to map between devices connected to the first transport medium and the
`storage devices” ............................................................................................................ 12
`ii. “native low level block protocol” ....................................................................... 14
`iii. “remote” ................................................................................................................. 15
`4. Identification of How the Claims Are Unpatentable .......................................... 16
`i. Challenge #1: Claims 1-5 and 7-14 are obvious over the CRD-5500 Manual
`in view of the HP Journal ............................................................................................ 16
`(a) Summary of the CRD-5500 Manual 16 .......................................................... 16
`(b)
`Summary of the HP Journal ......................................................................... 21
`(c) Reasons to Combine the CRD-5500 Manual and the HP Journal ......... 22
`
`
`
`(d) Detailed Analysis ............................................................................................ 26
`(d) Detailed Analysis .......................................................................................... ..26
`ii. Challenge #2: Claim 6 is obvious over the CRD-5500 Manual in view of
`ii. Challenge #2: Claim 6 is obvious over the CRD—5500 Manual in View of
`the HP Journal and in further view of the QLogic Data Sheet ............................. 54
`the HP Journal and in further View of the QLogic Data Sheet ........................... ..54
`(a) Brief Summary of the QLogic Data Sheet ..................................................... 54
`(a) Brief Summary of the QLogic Data Sheet ................................................... ..54
`(b) Reasons to Combine the CRD-5500 Manual, the HP Journal, and the
`(b)
`Reasons to Combine the CRD—5500 Manual, the HP Journal, and the
`QLogic Data Sheet .................................................................................................... 54
`QLogic Data Sheet.................................................................................................. ..54
`(c) Detailed Analysis ............................................................................................ 55
`(c)
`Detailed Analysis .......................................................................................... ..55
`VI. Conclusion ..................................................................................................................... 57
`CERTIFICATE OF SERVICE ........................................................................................ 59
`
`CERTIFICATE OF SERVICE ...................................................................................... ..59
`
`VI.
`
`Conclusion ................................................................................................................... ..57
`
`
`
`
`
`
`I.
`
`This Petition Presents the Same Grounds Which Were Instituted in
`IPR2014-01226
`
`The instant inter partes review petition presents challenges which are identical to
`
`
`
`those on which trial was instituted in IPR2014-01226. Paper No. 9. The petition in the
`
`instant case copies verbatim the challenges set forth in the petition in IPR2014-01226
`
`(Paper No. 3) and relies upon the same evidence, including the same expert
`
`declaration. This petition is accompanied by a motion for joinder.
`
`II. Mandatory Notices
`
`A.
`
`Real Party-in-Interest
`
`The real parties-in-interests are Oracle Corporation and Dot Hill Systems
`
`Corporation.
`
`B. Related Matters
`
`As of the filing date of this petition, U.S. Patent No. 6,425,035 (“the ‘035
`
`Patent”) is subject to inter partes review in case nos. IPR2014-01197, filed July 23,
`
`2014, IPR2015-00777, filed February 19, 2015, and IPR2014-01226, filed July 31,
`
`2014.
`
`The ‘035 Patent has also been asserted against Oracle Corporation in Crossroads
`
`Systems, Inc. v. Oracle Corp., No. 1-13-cv-00895 (W.D. Tex. 2013) and against Dot Hill
`
`Systems Corporation in Crossroads Systems, Inc. v. Dot Hill Systems Corp., No. 1-13-cv-
`
`00800 (W.D. Tex. 2013) . Additional 3rd party judicial matters involving the ‘035
`
`Patent are: Crossroads Systems v. Quantum Corporation, No. 1-14-cv-00150 (W.D. Tex.);
`
`1
`
`
`
`
`Crossroads Systems, Inc. v. NetApp, Inc., No. 1-14-cv-00149 (W.D. Tex.); Crossroads
`
`
`
`Systems v. Cisco Systems, Inc., No. 1-14-cv-00148 (W.D. Tex.); Crossroads Systems, Inc. v.
`
`Huawei Technologies Co. Ltd. et al., No. 1-13-cv-01025 (W.D. Tex.); Crossroads Systems, Inc.
`
`v. Dell, Inc., No. 1-13-cv-01023 (W.D. Tex.); Crossroads Systems, Inc. v. Tandberg Data
`
`Corp., Inc., No. 1-13-cv-01026 (W.D. Tex.); Crossroads Systems, Inc. v. Addonics
`
`Technologies, Inc., No. 1-12-cv-01090 (W.D. Tex.); Crossroads Systems, Inc. v. Infotrend
`
`Corp., et al., No. 1-12-cv-0104 (W.D. Tex.); Crossroads Systems, Inc. v. 3PAR, Inc., et al.,
`
`No. 1-10-cv-00652 (W.D. Tex.); Crossroads Systems, Inc. v. Postvision, Inc., et al., No. 1-09-
`
`cv-00879 (W.D. Tex.); Symantec Corp v. Crossroads Systems, Inc., No. 1-09-cv-00359
`
`(W.D. Tex.); Symantec Corp v. Crossroads Systems, Inc., No. 4-08-cv-05687 (N.D. Cal.);
`
`Crossroads Systems, Inc. v. DataDirect Networks, Inc., et al., No. 1-08-cv-00861 (W.D. Tex.);
`
`Crossroads Systems, Inc. v. Accusys (U.S.A.), Inc., et al., No. 1-08-cv-00394 (W.D. Tex.);
`
`Equallogic, Inc. v. Crossroads Systems, Inc. et al, No. 1-06-cv-11478 (D. Mass.); Crossroads
`
`Systems (Texas) v. Dot Hill Systems Corp., No. 1-03-cv-00754 (W.D. Tex.).
`
`C.
`
`Lead and Back-up Counsel and Service Information
`
`Pursuant to 37 C.F.R. § 42.8(b)(3)-(4), Petitioners provide the following
`
`designation of counsel:
`
`Greg Gardella (Lead Counsel)
`Oblon LLP
`1940 Duke Street
`Alexandria, VA 22314
`
`Orion Armon (Backup counsel)
`Cooley LLP, ATTN: Patent Group
`1299 Pennsylvania Ave., NW, Suite 700
`Washington, DC 20004
`
`2
`
`
`
`
`cpdocketgardella@oblon.com,
`(703) 413-3000
`
`
`
`
`III. Grounds for Standing
`
`
`
`oarmon@cooley.com
`(720) 566-4119
`
`
`Petitioners certify that they are not estopped or barred from requesting inter
`
`partes review of the ‘035 Patent because this petition is accompanied by a motion for
`
`joinder. The one-year time bar of 35 U.S.C. § 315(b) does not apply to a request for
`
`joinder. 35 U.S.C. § 315(b) (final sentence) (“[t]he time limitation set forth in the
`
`preceding sentence shall not apply to a request for joinder under subsection (c)”); 37
`
`C.F.R. § 42.122(b).
`
`IV. 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-
`
`14 (all claims) of the ‘035 Patent, and cancel those claims as invalid.
`
`V.
`
`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 ‘035 Patent simply recite obvious combinations of
`
`network storage components with functionality that was well-known at the time of
`
`the ‘035 Patent invention. For example, each of the ‘035 Patent’s three independent
`
`3
`
`
`
`
`
`
`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. In one embodiment of the ‘035 specification, the
`
`storage router is a bridge between workstations on a Fiber Channel link and storage
`
`devices on a SCSI bus, and the block-level data flowing between the workstations and
`
`storage devices conforms to the SCSI protocol. Ex. 1001, 5:34-36; Fig. 3.
`
`These elements were well known in the prior art. For example, in 1996, CMD
`
`Technologies sold a storage router called the CRD-5500 SCSI RAID Controller that
`
`performed the same functions as recited in the claims. According to the User’s
`
`Manual, the CRD-5500 RAID 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 and
`
`blocks hosts from accessing storage devices to which they were not mapped. Ex.
`
`1004, pp. 1-1, 1-2, 1-11, 4-2, 4-5.
`
`In a default configuration, the CRD-5500 RAID controller routes data between
`
`two SCSI buses; however, the controller has a modular design that accepts different
`
`types of I/O adapter cards and was specifically designed to support serial
`
`communication links. Ex. 1004, pp. 1-1, 2-1, 2-4; Ex. 1005, p. 1. One of ordinary skill
`
`in the art at the time of the ‘035 Patent invention would have been motivated to
`
`4
`
`
`
`
`modify the CRD-5500 RAID controller so it communicated with hosts via a Fibre
`
`Channel link rather than a SCSI bus, so as to take advantage of the known benefits of
`
`Fibre Channel and alleviate the known limitations of SCSI buses. Ex. 1006, pp. 5, 94,
`
`
`
`99.
`
`Consequently, this petition demonstrates that claims 1-14 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 ‘035 Patent
`
`1.
`
`Overview
`
`The ‘035 Patent has three independent claims (claims 1, 7, and 11) and a total
`
`of 14 claims. The ‘035 Patent generally relates to network-based storage and describes
`
`a “storage router” that routes storage requests between workstations and storage
`
`devices. Ex. 1001, Abstract. Figure 3 of the ‘035 Patent, annotated below, illustrates
`
`the architecture of the storage network in which the storage router operates:
`
`5
`
`
`
`
`
`
`
`
`
`As shown in Fig. 3, workstations on a Fibre Channel link (i.e., a transport
`
`medium) are connected to one side of the storage router, and storage devices on the
`
`SCSI bus communication link are connected to the other side of the storage router.
`
`Ex. 1001, 3:67-4:6. The specification describes the storage router as “a bridge device
`
`that connects a Fiber Channel link directly to a SCSI bus,” id. at 5:34-36, to give
`
`workstations access to “significantly remote” storage devices. Id. at 5:27-33.
`
`The storage router enables the exchange of SCSI commands and data between
`
`the workstations and the storage devices. Ex. 1001, 5:34-38. According to the
`
`specification, a “SCSI command” is an example of a native low level block protocol
`
`command. Id. at 5:34-38. Additionally, the specification states that Fibre Channel-
`
`based workstations on one side of the storage router may communicate with SCSI-
`
`6
`
`
`
`
`based storage devices on the other side of the storage router by encapsulating SCSI
`
`commands into Fibre Channel Protocol (FCP) requests. Id. at 6:32-44. Encapsulating
`
`low level commands such as SCSI commands inside of a Fibre Channel request was a
`
`feature of the Fibre Channel standard, and was well known in the art at the time of
`
`
`
`the ‘035 invention. Ex. 1006, pp. 94-95.
`
`The specification further states that the storage router uses “mapping tables” to
`
`allocate subsets of storage space (i.e., partitions) on the storage devices to particular
`
`workstations. Ex. 1001, 4:13-25. For example, with reference 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 4:19-22. Further, the
`
`specification states that the storage router provides “virtual local storage” such that a
`
`partition mapped to a workstation 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 4:7-13, 4:44-54. As discussed below in more detail, it was well known
`
`in the art at the time of the ‘035 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 Ex. 1004, p. 1-2, 3-6, 4-5.
`
`According to the ‘035 specification, the storage router uses the mapping
`
`functionality to facilitate both routing and access control. Ex. 1001, 5:25-27. With
`
`respect to routing, the specification states that the map between the initiators and the
`
`specific subsets of storage allows the storage router to determine “what partition is
`
`7
`
`
`
`
`being addressed by a particular request,” thus enabling it to “distribute[] requests and
`
`data” to storage devices Id. at 8:67-9:3, 3:56-58. With respect to access control, the
`
`specification states that the storage router prevents a workstation from accessing a
`
`subset of storage not allocated to it in the map. Id. at 8:61-9:6. For example, in Fig. 3,
`
`“subsets 66, 68, 70 and 72 can only be accessed by the associated workstation 58.” Id.
`
`at 4:22-24. 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 ‘035 Patent invention. See Ex. 1004, p. 1-2, 4-5.
`
`To illustrate the general flow of I/O commands in the storage network of the
`
`‘035 Patent, Fig. 3 is further annotated below:
`
`
`
`
`
`8
`
`
`
`
`
`
`
`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 ‘035 invention, the storage
`
`network described by the ‘035 Patent is simply a collection of components that were
`
`well known in the art at the time of the ‘035 Patent invention. Ex. 1003, ¶ 20. 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.
`
`2.
`
`Prosecution History
`
`The ‘035 Patent issued on July 23, 2002, from U.S. Patent Application No.
`
`09/965,335 (“the ‘335 application”) filed on September 27, 2001 by Geoffrey B.
`
`Hoese and Jeffry T. Russell. The ‘035 Patent is purportedly a continuation of U.S.
`
`Patent Application No. 09/354,682, filed on July 15, 1999, which is in turn a
`
`continuation of U.S. Patent No. 5,941,972 filed on December 31, 1997.
`
`During the prosecution of the ‘335 application, the Patent Owner, upon the
`
`request of the Examiner, filed a Terminal Disclaimer disclaiming any patent term
`
`extending beyond the life of the parent ‘972 Patent. Ex. 1002, pp. 59-62. The
`
`Examiner then issued a Notice of Allowance without ever substantively rejecting the
`
`claims. Id. at pp. 63-65.
`
`After the ‘035 Patent issued, two Ex Parte Reexamination proceedings were
`
`initiated against the ‘035 patent (control nos. 90/007,125 and 90/007,317). In the
`
`request for the 90/007,125 reexamination, the requester secondarily cited to the
`
`9
`
`
`
`
`
`
`CRD-5500 SCSI RAID Controller and numerous other similar systems but did not
`
`provide detailed analysis. Ex. 1010, p. 321. In the order granting the 90/007,125
`
`reexamination, the Patent Office refused to substantively consider the “voluminous
`
`citation” of secondary prior art in the request because it placed “the burden on
`
``explanation’ on the examiner.” Id. at pp. 288-292. The Office Actions that followed
`
`similarly did not cite to or address the relevance of the CRD-5500 Manual to the
`
`claims of the ‘035 Patent. Id. at pp. 247-258; 147-161.
`
`C.
`
`Identification of Challenges
`
`1.
`
`Challenged Claims
`
`
`
`Claims 1-14 of the ‘035 Patent are challenged in this petition.
`
`2.
`
`Statutory Grounds for Challenges
`
`Challenge #1: Claims 1-5 and 7-14 are obvious under 35 U.S.C. § 103(a) over
`
`the CRD-5500 SCSI Raid Controller User’s Manual (“CRD-5500 Manual”) in view of
`
`Volume 47, issue 5 of the Hewlett-Packard Journal (“HP Journal”). The CRD-5500
`
`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
`
`
`1 The CRD-5500 Manual was archived on by December 26, 1996 by the Internet
`Archive Wayback Machine and is available at http ://web. archive.
`org/web/19961226085953/http ://www. cmd. com/ftproot/pub/rai
`d/5500/manual/crd5500user.pdf. “Prior art disclosures on the Internet or on an
`online database are considered to be publicly available as of the date the item was
`
`10
`
`
`
`
`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 Ex. Ex. 1011. The HP Journal is thus prior
`
`
`
`art under 35 U.S.C. § 102(b).
`
`Challenge #2: Claim 6 is obvious under 35 U.S.C. § 103(a) over the CRD-
`
`5500 Manual in view of the HP Journal and in further view of the QLogic
`
`FAS216/216U/236/236U Fast Architecture SCSI Processor Data Sheet (“QLogic Data
`
`Sheet”). The QLogic Data Sheet has a copyright date of October 4, 1996, and is prior
`
`art under 35 U.S.C. § 102(b). See Ex. 1003, ¶ 66.
`
`3.
`
`Claim Construction
`
`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.
`
`§ 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). An inventor may define specific terms, but this must be done
`
`“with reasonable clarity, deliberateness, and precision.” In Re Paulsen, 30 F.3d 1475,
`
`
`publicly posted.” MPEP § 2128. The PTO identifies the Internet Archive Wayback
`Machine as a mechanism for determining the publication date of electronic
`documents such as those from the Internet. See,
`http://uspto.gov/patents/resources/methods/aiplafal102paper.jsp.
`
`11
`
`
`
`
`
`
`1480 (Fed. Cir. 1994). Also, “limitations are not to be read into the claims from the
`
`specification.” In re Van Geuns, 988 F.2d 1181, 1184 (Fed. Cir. 1993); see also Xilinx,
`
`Inc. v. Intellectual Ventures I LLC, IPR2013-00112, Paper 51 at *7, June 26, 2014 (citing
`
`to In re Van Geuns and noting that “we must be careful not to read a particular
`
`embodiment appearing in the written description into the claim if the claim language
`
`is broader than the embodiment”).
`
`Additionally, 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
`
`(“Although a district court’s construction may be informative, because 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.
`
`“to map between devices connected to the first
`transport medium and the storage devices”
`
`This claim term is found in claim 1. Claim 7 similarly recites “to map between
`
`the workstations and the storage devices” and claim 11 similarly recites “mapping
`
`between devices connected to the first transport medium and the storage devices.”
`
`12
`
`
`
`
`
`
`
`In the previous Crossroads Systems, Inc. v. 3PAR litigation2, 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 the other side
`
`of the storage router, the storage router can connect the devices.” Ex. 1009, p. 12.
`
`The specification does not provide an explicit definition of these related terms.
`
`The specification describes, however, 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.” Ex. 1001, 4:13-
`
`25 (emphasis added). The specification 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 8:61¬9:6. Dependent claims 2, 8, and
`
`12 appear to clarify the mapping language recited in the independent claims. For
`
`example, claim 2 recites: “wherein 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.” Id. at 9:32-36.
`
`
`2 Crossroads Systems, Inc. v. 3PAR, Inc., et. al., no. 1-10-cv-00652 (W.D. Tex. 2010).
`
`13
`
`
`
`
`
`
`
`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 the above limitations to be “to allocate storage on the storage
`
`devices to devices on the first transport medium to facilitate routing and access controls.” See Ex.
`
`1001, 4:13-25, 8:61-9:6; see also Ex. 1003 at ¶¶ 28-32.
`
`Whether the District Court construction or the foregoing construction is
`
`applied, the prior art references relied upon in this petition teach these claim terms.
`
`See Ex. 1003, pp. 53-54, 86.
`
`“native low level block protocol”
`ii.
`This term is found in claims 1, 7, and 11. In the 3Par litigation, the District
`
`Court construed “native low level block protocol” 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.” Ex. 1009, p. 13.
`
`The specification does not provide an explicit definition of “native low level
`
`block protocol.” The specification, however, 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.” Ex. 1001, 3:14-22. With reference to Fig. 3, the
`
`14
`
`
`
`
`specification 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 4:19-25. One example in the specification of a native low level
`
`block protocol command is a “SCSI command.” Id. at 5:34-38.
`
`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 accessed at the block level, such as the SCSI protocol.” See Ex. 1001, 3:14-22,
`
`4:19-25, 5:1-5, 5:34-38, 6:32-44; see also Ex. 1003 at ¶¶ 33-37.
`
`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
`
`Ex. 1003, pp. 57, 89, 112.
`
`“remote”
`iii.
`This term is found in claims 1 and 11. In the 3Par litigation, the District Court
`
`construed “remote” to mean “indirectly connected through at least one serial network
`
`transport medium.” Ex. 1009, p. 12.
`
`The specification does not provide an explicit definition of “remote.” The
`
`specification describes, however, that in Fig. 3 “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
`
`15
`
`
`
`
`storage router 56.” Ex. 1001, 4:48-54 (emphasis added). The specification 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 1:23-31.
`
`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 devices at a distance greater than allowed by a conventional parallel
`
`network interconnect.” See Ex. 1001, 1:23-31, 2:27-33, 4:48-54; see also Ex. 1003 at ¶¶ 38-
`
`42.
`
`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
`
`Ex. 1003, pp. 40, 102.
`
`4.
`
`Identification of How the Claims Are Unpatentable
`
`i.
`
`Challenge #1: Claims 1-5 and 7-14 are obvious over
`the CRD-5500 Manual in view of the HP Journal
`
`Claims 1-5 and 7-14 are obvious under 35 U.S.C. § 103(a) over the CRD-5500
`
`Manual in view of the HP Journal.
`
`(a)
`
`Summary of the CRD-5500 Manual 16
`
`The CRD-5500 Manual describes the features and operation of the CRD-5500
`
`SCSI RAID Controller. In general, the CRD-5500 RAID controller routes commands
`
`16
`
`
`
`
`
`
`
`
`and data between hosts (i.e., initiators) and storage devices (i.e., targets) coupled to the
`
`controller. Ex. 1004, pp. 1-1, 1-4. Figure 1-2 in the CRD-5500 Manual, annotated
`
`below, illustrates the architecture of the storage network in which the CRD-5500
`
`RAID controller operates:
`
`Specifically, in Figure 1-2, hosts attached to SCSI buses are connected to one
`
`side of the CRD-5500 RAID controller and storage devices attached to SCSI buses
`
`are connected to the other side of the CRD-5500 RAID controller. Id. at p. 2¬4. The
`
`CRD-5500 RAID 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.
`
`The CRD-5500 RAID controller includes a Monitor Utility in its user-
`
`upgradeable firmware that gives a user “complete control over the configuration and
`
`17
`
`
`
`
`
`
`
`
`operation of the controller.” Ex. 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).
`
`The following is a screenshot of the Host LUN Mapping feature of the Monitor
`
`Utility:
`
`As shown above, each host has a set of addressable virtual LUNs (numbered 0-
`
`31) to which these redundancy groups are mapped. Id. A host accesses the
`
`redundancy groups via its virtual LUNs. Id. For example, in the figure above, the host
`
`associated with channel 0 may access redundancy group 5 by addressing SCSI
`
`18
`
`
`
`
`
`
`
`
`commands to LUN 4. Additionally, each mapped redundancy group “will appear to
`
`the host as a different disk drive.” Id. at p. 3-6.
`
`Annotated Figure 1-2 below illustrates the general flow of I/O commands in
`
`the CRD-5500 RAID controller system.
`
`The CRD-5500 RAID controller uses the Host LUN Mapping tables to
`
`facilitate routing and access control. For example, because a host transmits SCSI
`
`commands to its set of virtual LUNs rather than the physical storage devices, the
`
`CRD-5500 RAID controller may “make a redundancy group visible to one host but
`
`not to another.” Ex. 1004, p. 1-1. For example, the CRD-5500 RAID controller “may
`
`make redundancy group 8 available on LUN 4 on host channel 0 and block access to
`
`it on host channel 1.” Id. at p. 4-5.
`
`19
`
`
`
`
`
`
`
`
`
`Further, the CRD-5500 RAID controller includes numerous slots for I/O
`
`adapter cards that connect to SCSI buses on which the hosts and storage devices
`
`communicate. Ex. 1004, pp. 1-1, 2-1, 2-4. A notable feature of the CRD-5500 RAID
`
`controller is that it “employs a modular design for maximum flexibility.” Id. at p. 1-1.
`
`Specifically, the controller’s slots accept many different types of I/O adapter cards
`
`that connect to different types of SCSI buses. Id. at pp. 1-1, 2-1, 2-4. Figure 2-1
`
`illustrates the modular nature of the controller:
`
`Notably, the designers of the CRD-5500 RAID controller intended for the
`
`CRD-5500 to work not only with SCSI buses but also with other types of
`
`communication links. A data sheet advertising the features of the CRD-5500 RAID
`
`controller states that the controller’s “RAID architecture and ASICs were designed
`
`20
`
`
`
`
`to support tomorrow’s high speed serial interfaces, such as Fiberchannel
`
`(FCAL) and Serial Storage Architecture (SSA).” Ex. 1005, p. 1, (emphasis added).
`
`
`
`(b)
`
`Summary of the HP Journal
`
`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.” Ex. 1006, p. 1. 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 har
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