`Trials@uspto.gov
`571-272-7822 Entered: January 29, 2015
`,2015
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`
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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`ORACLE CORPORATION, NETAPP INC., and
`HUAWEI TECHNOLOGIES CO., LTD.,
`Petitioners,
`
`v.
`
`CROSSROADS SYSTEMS, INC.,
`Patent Owner.
`____________
`
`Case IPR2014-01197
`Patent 6,425,035 B2
`____________
`
`Before HYUN J. JUNG, NEIL T. POWELL, and KRISTINA M. KALAN,
`Administrative Patent Judges.
`
`JUNG, Administrative Patent Judge.
`
`
`DECISION
`Institution of Inter Partes Review
`37 C.F.R. § 42.108
`
`
`
`
`
`CROSSROADS EXHIBIT 2101
`NetApp Inc. v. Crossroads Systems, Inc.
`IPR2015-00777
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`1
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`CROSSROADS EXHIBIT
`Oracle Corp. v. Crossroads Systems, Inc.
`IPR2015-008(cid:1009)(cid:1006)
`
`2101
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`IPR2014-01197
`Patent 6,425,035 B2
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`I.
`
`INTRODUCTION
`
`
`
`A. Background
`Oracle Corporation, NetApp Inc., and Huawei Technologies Co., Ltd.
`(“Petitioners”) filed a Petition (Paper 1, “Pet.”), requesting institution of an
`inter partes review of claims 1–14 of U.S. Patent No. 6,425,035 B2
`(Ex. 1001, “the ’035 patent”). Crossroads Systems, Inc. (“Patent Owner”)
`timely filed a Preliminary Response (Paper 12, “Prelim. Resp.”). We have
`jurisdiction under 35 U.S.C. § 314.
`We institute inter partes review because we determine that the
`information presented in the Petition and in the Preliminary Response shows
`that there is a reasonable likelihood that Petitioners would prevail with
`respect to at least one of the claims challenged in the Petition. See 35
`U.S.C. § 314(a). In particular, we institute inter partes review with respect
`to claims 1, 2, 4–6, 11, 12, and 14.
`
`II. DISCUSSION
`
`A. The ’035 Patent
`The ’035 patent relates to a storage router and method for providing
`virtual local storage on remote Small Computer System Interface (“SCSI”)
`storage devices to Fiber Channel (“FC”) devices. Ex. 1001, 1:16–19. SCSI
`is a storage transport medium that provides for “relatively small number of
`devices to be attached over relatively short distances.” Id. at 1:23–26. FC is
`a high speed serial interconnect that provides “capability to attach a large
`number of high speed devices to a common storage transport medium over
`large distances.” Id. at 1:29–32. Computing devices can access local
`storage through native low level, block protocols and can access storage on a
`remote network server through network interconnects. Id. at 1:37–49. To
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`access the storage on the remote network server, the computing device must
`translate its file system protocols into network protocols, and the remote
`network server must translate network protocols to low level requests. Id. at
`1:51–60. A storage router can interconnect the SCSI storage transport
`medium and the FC high speed serial interconnect to provide devices on
`either medium access to devices on the other medium so that no network
`server is involved. Id. at 3:30–40.
`Figure 4 of the ’035 patent is reproduced below:
`
`
`
`Figure 4 is a block diagram of an embodiment of a storage router. Id.
`at 2:59–60, 5:6–7. Storage router 56 can comprise FC controller 80 that
`interfaces with FC 52 and SCSI controller 82 that interfaces with SCSI bus
`54. Buffer 84 connects to FC controller 80 and SCSI controller 82 and
`provides memory work space. Id. at 5:7–9. Supervisor unit 86 connects to
`FC controller 80, SCSI controller 82, and buffer 84. Id. at 5:10–12.
`Supervisor unit 86 controls operation of storage router 56 and handles
`mapping and security access for requests between FC 52 and SCSI bus 54.
`Id. at 5:12–17.
`Claims 1, 7, and 11 are the independent claims challenged by this
`petition, and claim 1 is reproduced below:
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`1. A storage router for providing virtual local storage on
`remote storage devices to devices, comprising:
`
`a buffer providing memory work space for the storage
`router;
`
`a first controller operable to connect to and interface with
`a first transport medium;
`
`a second controller operable to connect to and interface
`with a second transport medium; and
`
`a supervisor unit coupled to the first controller, the
`second controller and the buffer, the supervisor unit operable to
`map between devices connected to the first transport medium
`and the storage devices, to implement access controls for
`storage space on the storage devices and to process data in the
`buffer to interface between the first controller and the second
`controller to allow access from devices connected to the first
`transport medium to the storage devices using native low level,
`block protocols.
`
`Id. at 9:13–31.
`
`B. Related Proceedings
`
`The ’035 patent is the subject of multiple district court proceedings.
`Pet. 2–3; Exs. 1026, 1034, 1035, 1036; Paper 10, 2.
`
`The ’035 patent is also involved in Case IPR2014-01226 and belongs
`to a family of patents that are the subject of multiple inter partes review
`petitions, including IPR2014-01177, IPR2014-01207, IPR2014-01209,
`IPR2014-01233, and IPR2014-01463.
`
`C. Challenges
`Petitioners challenge the claims as follows, all on the basis of
`obviousness:
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`References
`
`CRD-5500 User Manual1,
`CRD-5500 Data Sheet2, and
`Smith3
`Kikuchi4 and Bergsten5
`
`Kikuchi, Bergsten, and
`Smith
`Bergsten and Hirai
`
`Claims
`Challenged
`1–14
`
`1–4 and 7–14
`
`5 and 6
`
`1–4 and 7–14
`
`Bergsten, Hirai, and Smith
`
`5 and 6
`
`
`D. Claim Construction
`In an inter partes review, claim terms in an unexpired patent are
`interpreted according to their broadest reasonable construction in light of the
`specification of the patent in which they appear. 37 C.F.R. § 42.100(b);
`Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756, 48,766 (Aug. 14,
`2012). We determine that no express claim construction is required for the
`purposes of this decision.
`
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`
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`1 CMD Technology, Inc., CRD-5500 SCSI RAID Controller User’s Manual,
`(1996) (Ex. 1003).
`2 CRD-5500 RAID Disk Array Controller, (Dec. 4, 1996),
`http://web.archive.org/web/19961226091552/http:/www.cmd.com/brochure/
`crd5500.htm (last visited July 23, 2014) (Ex. 1004).
`3 Judith A. Smith and Meryem Primmer, Tachyon: A Gigabit Fibre Channel
`Protocol Chip, Hewlett-Packard J., 1–17 (1996) (Ex. 1005).
`4 U.S. Pat. No. 6,219,771 B1, iss. Apr. 17, 2001 (Ex. 1006).
`5 U.S. Pat. No. 6,073,209, iss. June 6, 2000 (Ex. 1007).
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`E. Obviousness of Claims 1–14 over CRD-5500 User Manual, CRD-
`
`5500 Data Sheet, and Smith
`Petitioners argue that the CRD-5500 controller described in the CRD-
`5500 User Manual and CRD-5500 Data Sheet discloses all the limitations of
`claim 1 except for:
`a supervisor unit coupled to the first controller, the
`second controller, and the buffer, the supervisor unit operable to
`map between devices connected to the first transport medium
`and the storage devices, to implement access controls for
`storage space on the storage devices and to process data in the
`buffer to interface between the first controller and the second
`controller to allow access from devices connected to the first
`transport medium to the storage devices using native low level,
`block protocol.
`
`Pet. 18–20 (citing Ex. 1003, 1–1, 1–4, 4–5; Ex. 1005 Fig.8; Ex. 1010 ¶¶ 36,
`44–47). Petitioners assert that the combination of CRD-5500 User Manual,
`CRD-5500 Data Sheet, and Smith meet the limitations of the recited
`“supervisor unit.” Pet. 20–22 (citing Ex. 1010 ¶¶ 31, 48–52). Petitioners
`also refer to Patent Owner’s assertions in litigation. Id. at 19, 20, 22 (citing
`Ex. 1009, p. 9; Ex. 1010 ¶¶ 45–52). For independent claims 7 and 11,
`Petitioners rely on their arguments for claim 1. Pet. 26 (citing Ex. 1010 ¶¶
`46, 60–66), 28 (citing Ex. 1010 ¶¶ 78–83).
`Patent Owner responds that the Petition attempts to show how the
`cited references teach a “supervisor unit” “without a single reference to the
`specific portions of the cited art that allegedly show the supervisor unit as
`claimed.” Prelim. Resp. 16 (citing Pet. 21–23).
`We agree with Patent Owner. The Petition states that “[t]he CRD-
`5500 references in combination with Smith . . . meet the limitations of the
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`claimed ‘supervisor unit,’” without any citations to the references
`themselves. Pet. 20. The Petition cites paragraph 48 of the Chase
`Declaration (Ex. 1010) in support of its statement that “[m]ore particularly,
`the CRD-5500 User Manual describes a central processing unit (CPU) that is
`coupled to a host device interface module, a storage interface module, and a
`buffer module.” Id. at 20–21. Petitioners’ further arguments regarding the
`recited “supervisor unit” cite only paragraphs 31 and 48–52 of the Chase
`Declaration. The cited paragraphs of the Chase Declaration refer to portions
`of the CRD-5500 User Manual to argue that it teaches the “supervisor unit.”
`Ex. 1010 ¶ 31 (citing Ex. 1003, pp. 1–1, 2–3, 2–4, 3–3, 3–4, 4–5), ¶ 48
`(citing Ex. 1003 1–3), ¶ 49 (citing Ex. 1003, pp. 1–1, 2–3, 2–4, 3–3, 3–4, 4–
`5), ¶ 50 (citing Ex. 1003 4–5), ¶ 51 (citing Ex. 1003 4–10). Petitioners
`provide no citation to CRD-5500 User Manual, CRD-5500 Data Sheet, or
`Smith in the Petition itself in support of their arguments regarding the
`“supervisor unit.”
`The Petition’s sole reliance on citations to the Chase Declaration in
`lieu of citations to the references themselves amounts to an incorporation by
`reference of arguments made in the Chase Declaration into the Petition,
`thereby circumventing the page limits that apply to petitions. We decline to
`consider the information found only in the Chase Declaration. After
`considering the descriptions of the references, which do not explain how the
`recited “supervisor unit” of claim 1 is taught (Pet. 11–18), and the analysis
`presented in the Petition itself, which does not cite CRD-5500 User Manual,
`CRD-5500 Data Sheet, or Smith (Pet. 20–22), we conclude that Petitioners
`have not shown a reasonable likelihood that they would prevail in
`establishing that claim 1 is unpatentable. Because Petitioners rely on their
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`arguments for claim 1 to establish the unpatentability of independent claims
`7 and 11, Petitioners likewise have not shown a reasonable likelihood that
`they would prevail in showing these claims to be unpatentable. Petitioners’
`arguments regarding dependent claims 2–6, 8–10, and 12–14 do not add to
`Petitioners’ analysis of how CRD-5500 User Manual, CRD-5500 Data
`Sheet, and Smith teach the “supervisor unit” of claim 1. Pet. 22–25, 26–27,
`28.
`
`For these reasons, based on information in the Petition and
`Preliminary Response, we determine that Petitioners have not demonstrated
`a reasonable likelihood that claims 1–14 are unpatentable under 35 U.S.C.
`§ 103(a) over CRD-5500 User Manual, CRD-5500 Data Sheet, and Smith.
`
`F. Obviousness of Claims 1–4 and 7–14 over Kikuchi and Bergsten
`In their analysis of the recited “supervisor unit” of claim 1, Petitioners
`argue that, “[i]n the combined system of Kikuchi and Bergsten, a CPU is
`programmed to enact certain functionalities of the address registration unit,
`address verification unit, address offset information conversion unit, actual
`partition address conversion unit, and command interpretation and execution
`unit, and is coupled to the ‘first controller,’ ‘second controller,’ and the
`‘buffer’ as recited in claim 1.” Pet. 36 (citing Ex. 1010 ¶ 103). Petitioners
`also argue that “the combined system includes an enhanced correlation
`chart” and a “RAM to temporarily buffer commands and data.” Id. at 36–37
`(citing Ex. 1010 ¶¶ 104–107). Petitioners also refer to Patent Owner’s
`assertions in litigation. Id. at 35, 36, 37–38 (citing Ex. 1009, 9; Ex. 1010 ¶¶
`99, 101–107). For independent claims 7 and 11, Petitioners rely on their
`arguments for claim 1. Id. at 39, 41 (citing Ex. 1010 ¶¶ 11–117, 129–134).
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`Patent Owner responds, and we agree, that “the Petition fails to make
`a single citation to the references, once again relying solely on the
`declaration of Dr. Chase to provide the required explanation.” Prelim. Resp.
`17–18 (citing Pet. 36–37). The Petition cites paragraphs 103–107 of the
`Chase Declaration (Ex. 1010). Pet. 36–37. Petitioners provide no citation to
`Kikuchi or Bergsten in the Petition itself in support of their arguments
`regarding the “supervisor unit.”
`As discussed supra, the Petition’s sole reliance on citations to the
`Chase Declaration in lieu of citations to the references themselves amounts
`to an incorporation by reference of arguments made in the Chase Declaration
`into the Petition, thereby circumventing the page limits that apply to
`petitions. We decline to consider the information found only in the Chase
`Declaration.
`After considering the descriptions of the references, which do not
`explain how the “supervisor unit” of claim 1 is taught (Pet. 28–34) and the
`analysis presented in the Petition itself, which only cites Kikuchi for “a
`buffer providing memory work space for the storage router” (Pet. 35), we
`conclude that Petitioners have not shown a reasonable likelihood that they
`would prevail in establishing that claim 1 is unpatentable. Because
`Petitioners rely on their arguments for claim 1 to establish the
`unpatentability of independent claims 7 and 11, Petitioners likewise have not
`shown a reasonable likelihood that they would prevail in showing these
`claims to be unpatentable. Petitioners’ arguments regarding dependent
`claims 2–4, 8–10, and 12–14 do not add to Petitioners’ analysis of how
`Kikuchi and Bergsten teach the “supervisor unit” of claim 1. Pet. 38–39,
`40–41.
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`For these reasons, based on information in the Petition and
`Preliminary Response, we determine that Petitioners have not demonstrated
`a reasonable likelihood that claims 1–4 and 7–14 are unpatentable under 35
`U.S.C. § 103(a) over Kikuchi and Bergsten.
`G. Obviousness of Claims 5 and 6 over Kikuchi, Bergsten, and Smith.
`Petitioners’ arguments regarding dependent claims 5 and 6, which
`depend from claim 1, do not add to Petitioners’ analysis of how Kikuchi and
`Bergsten teach the “supervisor unit” of claim 1. Pet. 42–43 (citing Ex. 1005,
`pp. 5, 7, 9, Figs. 4–6; Ex. 1010 ¶¶ 138–143).
`Accordingly, based on information in the Petition and Preliminary
`Response, we determine that Petitioners have not demonstrated a reasonable
`likelihood that claims 5 and 6 are unpatentable under 35 U.S.C. § 103(a)
`over Kikuchi, Bergsten, and Smith.
`
`H. Obviousness of Claims 1–4 and 7–14 over Bergsten and Hirai
`
`Petitioners argue that Bergsten discloses a storage router having all
`the limitations of claim 1 except for access controls. Pet. 49–52 (citing Ex.
`1007 3:14–19, 4:25–28, 5:65–6:1, 6:24–26, 7:24–31, 8:62–9:8, 10:23–29).
`Petitioners rely on Hirai for disclosing unauthorized commands from a
`particular host device are denied based upon a virtual address. Id. at 51
`(citing Ex. 1008 ¶ 13). In view of the Petition’s citations to the Bergsten and
`Hirai references, Petitioners’ arguments regarding how Bergsten and Hirai
`disclose the limitations of claim 1 are reasonable and supported by the
`record thus far presented.
`Petitioners argue that “[a]n artisan skilled in network storage during
`the relevant timeframe would combine the Bergsten and Hirai teachings . . .
`in order to provide additional levels of granularity to the access controls of
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`the Bergsten system based on the mapping-based access controls of Hirai.”
`Id. at 48 (citing Ex. 1010 ¶¶ 147–151). Petitioners’ argument that it would
`have been obvious to combine Bergsten’s storage controller with Hirai’s
`access controls is reasonable and supported by record evidence.
`For claim 3, which recites “wherein the devices connected to the first
`transport medium comprise workstations,” Petitioners cite only paragraph
`162 of the Chase Declaration (Ex. 1010) and provide no citation to Bergsten
`or Hirai. Pet. 53. After considering the descriptions of the references, which
`do not explain how the limitations of claim 3 are taught (Pet. 29–31, 44–45),
`and the analysis presented in the Petition itself, we conclude that Petitioners
`have not established a reasonable likelihood that claim 3 is unpatentable.
`Independent claim 7 recites “a plurality of workstations connected to
`the first transport medium,” and Petitioners argue that it “recites similar
`limitations as in claims 1, 3, and 4, and so the discussion . . . for claims 1, 3,
`and 4 applies with equal force to claim 7.” Pet. 54 (citing Ex. 1010 ¶¶ 164–
`170). Claim 13, which depends indirectly from independent claim 11,
`recites “wherein the devices connected to the first transport medium
`comprise workstations.” Petitioners assert that “[d]ependent claims 8, 9 and
`12-14 correspond to dependent claims 2-4” and that the “discussion . . . for
`claims 2-4 therefore applies with equal force to claims 8, 9, and 12-14.” Pet.
`56 (citing Ex. 1010 ¶¶ 171, 172, 188–190). For the reasons discussed for
`claim 3, Petitioners have not met their burden in establishing a reasonable
`likelihood that independent claim 7, claims 8–10 which depend from claim
`7, and claim 13 are unpatentable.
`We also have considered the arguments and evidence of record thus
`far concerning independent claim 11 and dependent claims 2, 4, 12, and 14
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`and are persuaded of a reasonable likelihood that Petitioners would prevail
`in establishing that these claims would have been obvious over Bergsten and
`Hirai as well.
`Patent Owner responds that Petitioners do not provide “expert
`testimony or other probative evidence regarding the meaning of other terms,
`which must be construed in order to apply the asserted prior art to the
`claims,” and that Petitioners “improperly attempt to construe claim language
`with respect to accused instrumentalities,” and “rely on ‘Patent Owner’s
`assertion in litigation,’” thus, “fail[ing] to meet their obligation to explain
`how the challenged claims are to be construed.” Prelim. Resp. 10–14.
`The argument is unpersuasive because Petitioners state that “[a]ll
`claimed terms not specifically addressed in [the claim construction] section
`have been accorded their ‘broadest reasonable interpretation’ in light of the
`’035 Patent including their plain and ordinary meaning.” Pet. 9. Also, this
`decision does not rely on Petitioners’ arguments regarding Patent Owner’s
`assertions in related litigation because the Petition does not explain how
`those assertions are the broadest reasonable construction in light of the
`specification of the patent in which they appear. 37 C.F.R. § 42.100(b).
`
`Patent Owner argues that Bergsten previously has been presented to
`and considered by the Office and has been rejected by the Office as a basis
`for challenging the claims. Prelim. Resp. 32 (citing Ex. 2012, 61, 69–70).
`The argument is not persuasive because, although Bergsten was cited
`previously during a reexamination of the ’035 patent, Patent Owner does not
`explain how Petitioners’ arguments regarding Bergsten and Hirai were
`considered previously.
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`Patent Owner argues that Petitioners combine Bergsten and Hirai into
`
`a theoretical combined system and then provide a purported correspondence
`between the claims and the theoretical combined system. Prelim. Resp. 49–
`50 (citing Pet. 44–49). However, Petitioners’ arguments explain how
`Bergsten, Hirai, or both teach the limitations of the claims 1, 2, 4, 11, 12,
`and 14, and where a combined system is asserted to teach a particular
`limitation, Petitioners provide a citation to the references. Pet. 49–58. Thus,
`Petitioners have provided a correspondence between the claims and the
`references, and not merely compared the claims to a theoretical combined
`system.
`Patent Owner argues that the “purpose of Bergsten is to provide a
`
`system in which all hosts have the same access to all storage.” Prelim.
`Resp. 50–51 (citing Ex. 1007, Abstract, 1:39–42, 3:1–4, 4:7–9, 4:39–41,
`4:66–5:2). Patent Owner, thus, argues that Petitioners cannot show a
`reasonable likelihood of success. Id. at 51. After considering Patent
`Owner’s citations to Bergsten, we find that all hosts having the same access
`to all storage would not necessarily conflict with, for example, some
`portions of all storage being restricted to all hosts.
`For the reasons above, based on information in the Petition and
`Preliminary Response, we determine that Petitioners have demonstrated a
`reasonable likelihood that claims 1, 2, 4, 11, 12, and 14 are unpatentable
`under 35 U.S.C. § 103(a) over Bergsten and Hirai.
`
`I. Obviousness of Claims 5 and 6 over Bergsten, Hirai, and Smith
`After considering the arguments (Pet. 57–58) and evidence of record
`thus far concerning claims 5 and 6, which depend from claim 1, we are
`persuaded of a reasonable likelihood that Petitioners would prevail in
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`establishing that claims 5 and 6 would have been obvious over Bergsten,
`Hirai, and Smith. Patent Owner does not present further arguments
`regarding claims 5 and 6, other than those discussed supra. Patent Owner
`does argue that the information in Smith was considered during the
`reexamination of the ’035 patent, but notes that Smith was not explicitly
`before the Office. Prelim. Resp. 19. The Preliminary Response also does
`not explain how Petitioners’ arguments regarding Bergsten, Hirai, and Smith
`were considered previously during the reexamination of the ’035 patent.
`Thus, based on information in the Petition and Preliminary Response,
`we determine that Petitioners have demonstrated a reasonable likelihood that
`claims 5 and 6 are unpatentable under 35 U.S.C. § 103(a) over Bergsten,
`Hirai, and Smith.
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`III. CONCLUSION
`
`For the foregoing reasons, we determine that Petitioners have
`demonstrated that there is a reasonable likelihood of their proving
`unpatentability of claims 1, 2, 4–6, 11, 12, and 14 of the ’035 patent.
`The Board has not made a final determination on the patentability of
`the challenged claims.
`
`IV. ORDER
`
`Accordingly, it is
`ORDERED that pursuant to 35 U.S.C. § 314(a), an inter partes
`review is hereby instituted as to claims 1, 2, 4–6, 11, 12, and 14 of U.S.
`Patent No. 6,425,035 on the following grounds of unpatentability:
`A. Claims 1, 2, 4, 11, 12, and 14 under 35 U.S.C. § 103(a) for
`obviousness over Bergsten and Hirai; and
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`B. Claims 5 and 6 under 35 U.S.C. § 103(a) for obviousness over
`Bergsten, Hirai, and Smith;
`FURTHER ORDERED that pursuant to 35 U.S.C. § 314(c) and
`37 C.F.R. § 42.4, notice is hereby given of the institution of a trial, the trial
`commencing on the entry date of this decision; and
`FURTHER ORDERED that the trial is limited to the grounds
`identified above, and no other grounds are authorized.
`
`PETITIONERS:
`Greg H. Gardella
`Scott A. McKeown
`OBLON SPIVAK
`cpdocketgardella@oblon.com
`cpdocketmckeown@oblon.com
`
`PATENT OWNER:
`Steven R. Sprinkle
`John L. Adair
`SPRINKLE IP LAW GROUP
`crossroadsipr@sprinklelaw.com
`
`Russell Wong
`James Hall
`WONG, CABELLO, LUTSCH, RUTHERFORD & BRUCCULERI, LLP
`CrossroadsIPR@counselip.com
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