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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`Oracle Corporation,
`
`NetApp Inc. and
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`Huawei Technologies Co., Ltd.
`
`Petitioners,
`
`v.
`
`Crossroads Systems, Inc.
`
`Patent Owner.
`
`____________
`
`IPR2014-_________
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`U.S. Patent No. 7,051,147
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`____________
`
`PETITION FOR INTER PARTES REVIEW
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`1 of 67
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`CROSSROADS EXHIBIT
`NetApp Inc. v. Crossroads Systems, Inc.
`IPR2015-00773
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`2122
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`CROSSROADS EXHIBIT
`Oracle Corp. v. Crossroads Systems, Inc.
`IPR2015-008(cid:1009)(cid:1006)
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`2122
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`

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`TABLE OF CONTENTS
`EXHIBIT LIST ........................................................................................................ iv
`I.
`INTRODUCTION ........................................................................................... 1
`II. MANDATORY NOTICES ............................................................................. 2
`A.
`Real Party-In-Interest ................................................................................... 2
`B.
`Related Matters ............................................................................................ 2
`C.
`Lead and Back-Up Counsel ......................................................................... 3
`D.
`Service Information ...................................................................................... 3
`III. PAYMENT OF FEES ..................................................................................... 3
`IV. REQUIREMENTS FOR INTER PARTES REVIEW ...................................... 4
`A. Grounds for Standing ................................................................................... 4
`B.
`Identification of Challenge ........................................................................... 4
`1. The Specific Art and Statutory Ground(s) on Which the Challenge Is
`Based ............................................................................................................ 4
`2. How the Construed Claims Are Unpatentable Under the Statutory
`Grounds Identified in 37 C.F.R. § 42.204(b)(2) and Supporting Evidence
`Relied upon to Support the Challenge ......................................................... 5
`THE ‘147 PATENT ......................................................................................... 6
`V.
`The Preferred Embodiment of the ‘147 Patent ............................................ 6
`A.
`Reexamination of an Ancestor of the ‘147 Patent ....................................... 7
`B.
`VI. BROADEST REASONABLE CONSTRUCTION ...................................... 10
`Claims 1-13 Are Rendered Obvious by CRD-5500 User’s Manual Taken
`A.
`in Combination with CRD-5500 Data Sheet and Smith ............................. 12
`Introduction of the CRD-5500 References ................................................ 12
`1.
`Introduction of the Smith Reference .......................................................... 15
`2.
`3. The Combined System of CRD-5500 User Manual, CRD-5500 Data Sheet
`and Smith .................................................................................................... 16
`4. Correspondence between Claims 1-13 and the Combined System of CRD-
`5500 and Smith ........................................................................................... 19
`Claims 1-4 and 6-13 Are Rendered Obvious by Kikuchi Taken in
`Combination with Bergsten ........................................................................ 29
`Introduction of the Kikuchi Reference ....................................................... 29
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`B.
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`1.
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`C.
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`D.
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`Introduction of the Bergsten Reference ..................................................... 30
`2.
`3. The Combined System of Kikuchi and Bergsten ....................................... 32
`4. Correspondence between Claims 1-4 and 6-13 and the Combined System
`of Kikuchi and Bergsten ............................................................................. 35
`Claim 5 is Rendered Obvious by Kikuchi Taken in Combination with
`Bergsten and Smith .................................................................................... 43
`Claims 1-4 and 6-13 Are Rendered Obvious by Bergsten Taken in
`Combination with Hirai .............................................................................. 44
`Introduction of the Hirai Reference ........................................................... 44
`1.
`2. The Combined System of Bergsten and Hirai ........................................... 46
`3. Correspondence between Claims 1-4 and 6-13 and the Combined System
`of Bergsten and Hirai ................................................................................ 49
`Claim 5 is Rendered Obvious by Bergsten Taken in Combination with
`Hirai and Smith .......................................................................................... 57
`VIII. EXPLANATION OF NON-REDUNDANCY .............................................. 58
`IX. CONCLUSION ............................................................................................. 60
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`E.
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`EXHIBIT LIST
` 
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`U.S. Patent No. 7,051,147 (“the ‘147 Patent”)
`
`Select Portions of File History of the ‘147 Patent
`
`CRD-5500 SCSI RAID Controller User’s Manual (“CRD-5500 User
`Manual”)
`
`CRD-5500 SCSI RAID Controller Data Sheet (“CRD-5500 Data
`Sheet”)
`
`Smith et al., Tachyon: A Gigabit Fibre Channel Protocol Chip,
`Hewlett-Packard Journal, October 1996 (“Smith”)
`
`U.S. Patent No. 6,219,771 to Kikuchi et al. (“Kikuchi”)
`
`U.S. Patent No. 6,073,209 to Bergsten (“Bergsten”)
`
`JP Patent Application Publication No. Hei 5[1993]-181609 to Hirai
`(“Hirai”)
`
`Infringement contentions in Crossroads Systems, Inc. v. Oracle
`Corporation, W.D. Tex. Case No. 1-13-cv-00895, Crossroads
`Systems, Inc. v. Huawei Technologies Co. Ltd. et al., W.D. Tex.
`Case No. 1-13-cv-01025, and Crossroads Systems, Inc. v. NetApp,
`Inc., W.D. Tex. Case No. 1-14-cv-00149
`
`Declaration of Professor Chase, Professor of Computer Science at
`Duke University
`
`Cheating the I/O Bottleneck: Network Storage with Trapeze/Myrinet
`
`Interposed Request Routing for Scalable Network Storage
`
`Cut-Through Delivery in Trapeze: An Exercise in Low-Latency
`Messaging
`
`Structure and Performance of the Direct Access File System
`
`Implementing Cooperative Prefetching and Caching in a Globally-
`Managed Memory System
`
`
`iv
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`1001
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`1002
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`1003
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`1004
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`1005
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`1006
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`1007
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`1008
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`1009
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`1010
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`1011
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`1012
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`1013
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`1014
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`1015
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`1016
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`1017
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`1018
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`1019
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`
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`1020
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`1021
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`1022
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`1023
`
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`1024
`
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`1025
`
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`1026
`
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`1027
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`1028
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`
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`Network I/O with Trapeze
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`A Cost-Effective, High-Bandwidth Storage Architecture
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`RAID-II: A High-Bandwidth Network File Server
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`Payload Caching: High-Speed Data Forwarding for Network
`Intermediaries
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`Petal: Distributed Virtual Disks
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`File Server Scaling with Network-Attached Secure Disks
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`Failure-Atomic File Access in an Interposed Network Storage System
`
`U.S. Patent No. 6,308,228 to Yocum et al. (“Yocum”)
`
`Select Portions of File History of Reexamination Control No.
`90/007,123 (U.S. Patent No. 5,941,972)
`
`Select Portions of the File History of Reexamination Control No.
`90/007,124 (U.S. Patent No. 6,421,753)
`
`Plaintiff Crossroads Systems, Inc.’s Objections and Responses to
`Defendants’ First Set of Common Interrogatories in Crossroads
`Systems, Inc. v. Oracle Corporation, W.D. Tex. Case No. 1-13-cv-
`00895, Crossroads Systems, Inc. v. Huawei Technologies Co. Ltd. et
`al., W.D. Tex. Case No. 1-13-cv-01025, and Crossroads Systems, Inc.
`v. NetApp, Inc., W.D. Tex. Case No. 1-14-cv-00149
`
`Storagepath Fibre Channel Drive System, SWS/Storagepath,
`available at
`web.archive.org/web/19970114010450/http://www.storagepath.com/
`fibre.htm, archived January 14, 1997
`
`Technology Brief Strategic Direction for Compaq Fibre Channel-
`Attached Storage, Compaq Computer Corporation, October 14, 1997
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`1029
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`1030
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`1031
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`1032
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`1033
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`1034
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`1035
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`1036
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`1037
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`Tantawy (ed.), Fibre Channel (Ch. 5) of High Performance Networks,
`Kluwer Academic Publishers, 1994
`
`Deel et al., Moving Uncompressed Video Faster Than Real Time,
`Society of Motion Picture and Television Engineers, Inc., December
`1996
`
`Emulex LightPulse Fibre Channel PCI Host Adapter, Emulex
`Corporation, available at
`web.archive.org/web/19980213052222/http://www.emulex.com/fc/
`lightpulse2.htm, archived February 13, 1998
`
`Select Portions of File History of Reexamination Control Nos.
`90/007,125 and 90/007,317 (U.S. Patent No. 6,425,035)
`
`Local Area Networks Newsletter, Vol. 15, No. 2, Information
`Gatekeepers Inc., February 1997
`
`Litigation Complaint in Crossroads Systems, Inc. v. Oracle
`Corporation, W.D. Tex. Case No. 1-13-cv-00895
`
`Litigation Complaint in Crossroads Systems, Inc. v. Huawei
`Technologies Co. Ltd. et al., W.D. Tex. Case No. 1-13-cv-01025
`
`Litigation Complaint in Crossroads Systems, Inc. v. NetApp, Inc.,
`W.D. Tex. Case No. 1-14-cv-00149
`
`Declaration of Monica S. Ullagaddi authenticating Ex. 1004, Ex. 1027
`and Ex. 1031
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`I.
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`INTRODUCTION
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` Petitioners Oracle Corporation, NetApp Inc., and Huawei Technologies Co.,
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`Ltd. (“Petitioners”) respectfully request inter partes review for claims 1-13 of U.S.
`
`Patent No. 7,051,147 (“the ‘147 Patent”, attached as Ex. 1001) in accordance with
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`35 U.S.C. §§ 311–19 and 37 C.F.R. § 42.100 et seq. The ‘147 Patent is directed to
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`a storage router that serves as a bridge between a Fibre Channel and SCSI channel.
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`More specifically, the ‘147 Patent states that “the storage router of the present
`
`invention is a bridge device that connects a Fibre Channel link directly to a SCSI
`
`bus and enables the exchange of SCSI command set information between
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`application clients on SCSI bus devices and the Fibre Channel links.” (Ex. 1001 at
`
`5:46-50) The ‘147 Patent explains that this method is accomplished with native
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`low level block protocols (NLLBP), which enhances system performance because
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`such an approach “does not involve the overhead of high level protocols and file
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`systems required by network servers.” (Id. at 5:13-17) The “storage router [also]
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`applies access controls such that virtual local storage can be established in remote
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`SCSI storage devices for workstations on the Fibre Channel link.” (Id. at 5:49-52)
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`Systems corresponding closely to the claims of the ‘147 Patent were taught
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`by prior art which were not before the Examiner or were not applied in a prior art
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`rejection. The CRD-5500 SCSI RAID Controller by CMD Technology, Inc. was
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`detailed in product manuals and data sheets released more than a year before the
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`earliest priority date. Additionally, several other combinations of prior art
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`predictably yield combined systems in which a storage controller bridges between
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`a Fibre Channel (“FC”) and a SCSI storage disk array and provides access controls
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`and virtual local SCSI storage space for host devices on the FC. For instance, a
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`skilled artisan would have readily combined the teaching of access controls in U.S.
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`Patent No. 6,219,771 to Kikuchi et al. with the virtualized storage controllers
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`taught in U.S. Patent No. 6,073,209 to Bergsten. (See Ex. 1010 at ¶¶ 142-7) The
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`access control techniques taught in JP Patent Application Publication No. Hei
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`5[1993]-181609 to Hirai would likewise have been readily and predictably
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`combined with the Bergsten system. (Id. at ¶¶ 247-51)
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`II. MANDATORY NOTICES
`Pursuant to 37 C.F.R. § 42.8(a)(1), Petitioners provide the following
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`mandatory disclosures.
`
`A. Real Party-In-Interest
`Pursuant to 37 C.F.R. § 42.8(b)(1), Petitioners certify that Oracle
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`Corporation, NetApp Inc., and Huawei Technologies Co., Ltd. are the real parties-
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`in-interest.
`
`B. Related Matters
`Pursuant to 37 C.F.R. § 42.8(b)(2), Petitioners state that the ‘147 Patent is
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`asserted in co-pending litigation matters captioned Crossroads Systems, Inc. v.
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`Oracle Corporation, W.D. Tex. Case No. 1-13-cv-00895 (Ex. 1034), Crossroads
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`Systems, Inc. v. Huawei Technologies Co. Ltd. et al., W.D. Tex. Case No. 1-13-cv-
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`01025 (Ex. 1035), and Crossroads Systems, Inc. v. NetApp, Inc., W.D. Tex. Case
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`No. 1-14-cv-00149 (Ex. 1036). All other related and co-pending litigation matters
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`are set forth in Exhibit 1026.
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`
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`C. Lead and Back-Up Counsel
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`Pursuant to 37 C.F.R. § 42.8(b)(3), Petitioners provide the following
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`designation of counsel: Lead counsel is Greg Gardella (Reg. No. 46,045) and back-
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`up counsel is Scott A. McKeown (Reg. No. 42,866).
`
`Service Information
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`D.
`Pursuant to 37 C.F.R. § 42.8(b)(4), papers concerning this matter should be
`
`served on the following.
`
`Address: Greg Gardella and Scott McKeown
`Oblon Spivak
`1940 Duke Street
`Alexandria, VA 22314
`cpdocketgardella@oblon.com, and
`cpdocketmckeown@oblon.com
`Telephone: (703) 413-3000
`Fax:
`
`(703) 413-2220
`
`Email:
`
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`III. PAYMENT OF FEES
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`The undersigned authorizes the Office to charge to Deposit Account No. 15-
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`0030 the fee required by 37 C.F.R. § 42.15(a) for this Petition for inter partes
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`review. The undersigned further authorizes payment for any additional fees that
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`might be due in connection with this Petition to be charged to the above referenced
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`Deposit Account.
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`IV. REQUIREMENTS FOR INTER PARTES REVIEW
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`As set forth below and pursuant to 37 C.F.R. § 42.104, each requirement for
`
`inter partes review of the ‘147 Patent is satisfied.
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`A. Grounds for Standing
`Pursuant to 37 C.F.R. § 42.104(a), Petitioners hereby certify that the ‘147
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`Patent is available for inter partes review and that the Petitioners are not barred or
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`estopped from requesting inter partes review challenging the claims of the ‘147
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`Patent on the grounds identified herein. The ‘147 Patent has not been subject to a
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`previous estoppel based proceeding of the AIA, and, the complaint served on
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`Crossroads Systems, Inc. referenced above in Section II(B) was served within the
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`last 12 months.
`
`B. Identification of Challenge
`Pursuant to 37 C.F.R. §§ 42.104(b) and (b)(1), Petitioners request inter
`
`partes review of claims 1-13 of the ‘147 Patent, and further requests that the Patent
`
`Trial and Appeal Board (“PTAB”) invalidate the same.
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`1. The Specific Art and Statutory Ground(s) on Which
`the Challenge Is Based
`
`Pursuant to 37 C.F.R. § 42.204(b)(2), inter partes review of the ‘147 Patent
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`
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`is requested in view of the following grounds:
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`(a) Claims 1-13 are rendered obvious under 35 U.S.C. § 103(a) by the
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`combination of The CRD-5500 SCSI RAID Controller User’s Manual (“CRD-5500
`
`User Manual”, Ex. 1003), CRD-5500 SCSI RAID Controller Data Sheet (“CRD-
`
`5500 Data Sheet”, Ex. 1004), and Smith et al., Tachyon: A Gigabit Fibre Channel
`
`Protocol Chip, Hewlett-Packard Journal, October 1996 (“Smith”, Ex. 1005);
`
`(b) Claims 1-4 and 6-13 are rendered obvious under 35 U.S.C. § 103(a)
`
`by U.S. Patent No. 6,219,771 to Kikuchi et al. (“Kikuchi”, Ex. 1006) in view of
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`U.S. Patent No. 6,073,209 to Bergsten (“Bergsten”, Ex. 1007);
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`(c) Claim 5 is rendered obvious under 35 U.S.C. § 103(a) by the
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`combination of Kikuchi, Bergsten and Smith;
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`
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`(d) Claims 1-4 and 6-13 are rendered obvious under 35 U.S.C. § 103(a)
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`by Bergsten in view of JP Patent Application Publication No. Hei 5[1993]-181609
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`to Hirai (“Hirai”, Ex. 1008); and
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`
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`(e) Claim 5 is rendered obvious under 35 U.S.C. § 103(a) by the
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`combination of Bergsten, Hirai and Smith.
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`2. How the Construed Claims Are Unpatentable Under
`the Statutory Grounds Identified in 37 C.F.R.
`§ 42.204(b)(2) and Supporting Evidence Relied upon to
`Support the Challenge
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`Pursuant to 37 C.F.R. § 42.204(b)(4), an explanation of how claims 1-13 of
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`
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`the ‘147 Patent are unpatentable, including the identification of where each claim
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`element is found in the prior art, is provided in Section VII below. Pursuant to 37
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`C.F.R. § 42.204(b)(5), the exhibit numbers of the supporting evidence relied upon
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`to support the challenges and the relevance of the evidence to the challenges
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`raised, including identifying specific portions that support the challenges, are
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`provided in Section VII.
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`V.
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`THE ‘147 PATENT
`A. The Preferred Embodiment of the ‘147 Patent
`The ‘147 Patent states that “the storage router of the present invention is a
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`bridge device that . . . enables the exchange of SCSI command set information
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`between application clients on SCSI bus devices and the Fibre Channel links.” (Ex.
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`1001 at 5:46-50; see also id. at Figure 3) According to this preferred embodiment,
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`“storage network 50 includes a Fibre Channel high speed serial interconnect 52”
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`(id. at 4:12-15) and a storage router 56 that enables “a large number of
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`workstations 58 to be interconnected on a common storage transport and to access
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`common storage devices 60, 62 and 64 through native low level, block protocols”
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`(id. at 4:15-19).
`
` Storage router 56 also includes “enhanced functionality to implement
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`security controls and routing such that each workstation 58 can have access to a
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`specific subset of the overall data stored in storage devices 60, 62 and 64” which
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`“has the appearance and characteristics of local storage and is referred to . . . as
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`virtual local storage.” (Id. at 4:20-26) Storage router 56 performs access control
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`and routing “such that each workstation 58 has controlled access to only the
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`specified partition of storage device 62 which forms virtual local storage for the
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`workstation 58.” (Id. at 4:41-44)
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`“To accomplish this function, storage router 56 can include routing tables
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`and security controls that define storage allocation for each workstation 58.” (Id. at
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`5:7-9) This provides the advantage that “collective backups and other collective
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`administrative functions” may be performed “more easily.” (Id. at 5:9-13) Further,
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`“[b]ecause storage access involves native low level, block protocols and does not
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`involve the overhead of high level protocols and file systems required by network
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`servers,” this approach does not impede or slow system performance. (Id. at 5:13-
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`17)
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`B. Reexamination of an Ancestor of the ‘147 Patent
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`U.S. Patent No. 6,421,753, an ancestor of the ‘147 Patent shares the same
`
`specification, claims similar subject matter, and was challenged in an ex parte
`
`reexamination in 2004. The Examiner rejected all claims of the ‘753 Patent under
`
`35 U.S.C. §103(a) over combinations including United Kingdom Patent
`
`Application Publication No. UK GB 2297636 (“Spring”) in view of United States
`
`Patent No. 5,634,111 (“Oeda”), and further in view of Cummings, Systems
`
`Architectures Using Fibre Channel, Twelfth IEEE Symposium on Mass Storage
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`Systems, Copyright 1993 IEEE (“Cummings”). (See e.g., Ex. 1025 at pp. 553-64,
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`Reexamm Non-finall Office Acction dated d May 24, 22005 at pp.. 3-14) Pattent Ownerr
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`distinguuished fromm Spring on that basis that Spriing’s Etherrnet-to-SCSSI system d
`does
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`not allow access uusing NLLBBP (id. at ppp. 498-5000, Patent
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`Owner Ressponse datted
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`se” at pp.1er Responsatent OwneJuly 22,, 2005 “Pa
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`9-21):
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`In response to this argument the Examiner issued a Notice of Intent to Issue
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`a Reexam Certificate (“NIRC”) which provided the following reasons for
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`confirmation:
`
`The prior art disclosed by the Patent Owner and cited by the
`Examiner fail to teach or suggest, alone or in combination, all the
`limitations of the independent claims (claims 1 and 4), particularly
`the map/mapping feature which is a one-to-one correspondence, as
`given in a simple table, the map physically resident on a router,
`whereby the router forms the connection between two separate
`entities over different transport mediums, such that neither entity
`determines where data is to be sent, but rather, the router solely
`dictates where the data will be sent; also the “NLLBP” feature
`referring to a fundamental low level protocol defined by a
`specification/standard that is well known to one of ordinary skill in
`the art, where the NLLBP is used at the router for communications
`with both the first and second transport medium. The SCSI
`protocol/standard is considered a NLLBP. TCP/IP, e.g., used in
`Ethernet communications, however, is not considered to be a
`NLLBP. (Id. at p. 14, NIRC at p. 3)
`
`As such, the Examiner agreed that Spring’s Ethernet-to-SCSI system did not
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`satisfy the NLLBP limitation because the Ethernet side of the bridge used TCP/IP.
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`(Id.) The Examiner also found that Spring’s Ethernet-to-SCSI bridge did not teach
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`a map/mapping feature that is a one-to-one correspondence given in a simple table.
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`(Id.)
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`VI. BROADEST REASONABLE CONSTRUCTION
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`Petitioners base this petition upon the U.S. Patent and Trademark Office’s
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`(“USPTO”) “broadest reasonable interpretation” standard applied in PTAB
`
`proceedings. All claim terms not specifically addressed in this section have been
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`accorded their “broadest reasonable interpretation” in light of the patent
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`specification including their plain and ordinary meaning. Petitioners’ position
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`regarding the scope of the claims under their “broadest reasonable interpretation”
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`is not to be taken as stating any position regarding the appropriate scope to be
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`given the claims in a court or other adjudicative body under the different claim
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`interpretation standards that may apply to such proceedings. In particular,
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`Petitioners note that the standard for claim construction used in district courts
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`differs from the standard applied before the USPTO. Any claim construction
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`offered by Petitioners in this petition is directed to the USPTO standard, and
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`Petitioners do not acquiesce or admit to the constructions reflected herein for any
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`purpose outside of this proceeding.
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` “Native low-level block protocol” is described in the specification as being
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`distinct from higher-level protocols that require translation to NLLBP. (Ex. 1001 at
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`1:21-35, 3:27-38, and 5:13-17) Examples of NLLBPs in the ‘147 Patent include
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`SCSI-2 commands and SCSI-3 Fibre Channel Protocol (“FCP”) commands. (See
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`e.g., id. at 6:44-7:2) The ‘147 Patent distinguishes prior art systems that provided
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`access “through network protocols that the [network] server must translate into low
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`level requests to the storage device.” (Id. at 1:58-61)
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`During the reexamination of the ancestor of the ‘147 Patent, the Patent
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`Owner argued that a NLLBP is “a set of rules or standards that enable computers to
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`exchange information and do not involve the overhead of high level protocols and
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`file systems typically required by network servers,” citing the Markman Order of
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`the U.S. District Court for the Western District of Texas in Crossroads v.
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`Chaparral Network Storage, Inc., Civil Action No. A-00-CA-217-SS and
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`Crossroads Systems (Texas), Inc., v. Pathlight Technology, Inc., Civil Action No.
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`A-00CA-248-JN. (Ex. 1025 at p. 500, Patent Owner Response at p. 21) Consistent
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`with this, the Examiner found that “[t]he SCSI protocol/standard is considered a
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`NLLBP. TCP/IP, e.g., used in Ethernet communications, however, is not
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`considered to be a NLLBP.” (Id. at p. 14, NIRC at p. 3)
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`For the foregoing reasons, the broadest reasonable interpretation of NLLBP
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`includes a protocol, such as SCSI command protocol, that enables the exchange of
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`information without the overhead of high-level protocols and file systems typically
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`required by network servers.
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` VII. GROUNDS OF UNPATENTABILITY
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`The explanations set forth below summarize the grounds of
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`unpatentability. Each reference is introduced in turn and those introductions are
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`followed by an explanation of the combined system or method and the supporting
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`rationale. Thereafter the correspondence between the combined system or method
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`and each claim element is explained. Pinpoint citations are provided to the
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`declaration of Professor Chase (Ex. 1010), which describes in further detail the
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`combined system, supporting rationale, and the correspondence to the claimed
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`subject matter.
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`A. Claims 1-13 Are Rendered Obvious by CRD-5500 User’s Manual
`Taken in Combination with CRD-5500 Data Sheet and Smith
`1. Introduction of the CRD-5500 References
`The CRD-5500 SCSI RAID Controller User’s Manual (“CRD-5500 User
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`Manual”, Ex. 1003) and CRD-5500 SCSI RAID Controller Data Sheet (“CRD-
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`5500 Data Sheet”, Ex. 1004) were published on November 21, 1996 and December
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`26, 1996, respectively, over a year before the earliest priority date of the ‘147
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`Patent (December 31, 1997). Therefore, the CRD-5500 User Manual and CRD-
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`5500 Data Sheet are prior art to the ‘147 Patent under 35 U.S.C. §102(b). The
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`CRD-5500 User Manual was before the Examiner but was not discussed by the
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`Examiner in any office action or referenced in any rejection. The Patent Owner
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`initially presented the CRD-5500 User Manual in the list of references submitted
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`in relation to the ex parte reexamination of ancestor U.S. Patent No. 6,421,753.
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`(See Ex. 1025 at p. 649, List of References Cited by Applicant dated January 24,
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`2005) The CRD-5500 Data Sheet has never been before the Examiner.
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`The CRD-5500 User Manual may be presumed authentic under Fed.R.Evid.
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`901(b)(4) given that it was submitted by the Patent Owner as prior art and is self-
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`authenticating under Fed.R.Evid. 902(7) given that it bears trade inscriptions
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`demonstrating that the document is a publication by CMD Technology, Inc.
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`released on a date certain. The CRD-5500 Data Sheet is authenticated by the
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`declaration of Monica S. Ullagaddi (Ex. 1037).
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`The CRD-5500 User Manual describes a RAID controller which couples
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`one or more host devices to virtual local storage on a RAID storage disk array. (Ex.
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`1003 at 1-1) Devices are connected to the CRD-5500 controller through a number
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`of I/O module slots configured to receive both host device interface modules and
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`storage device interface modules. (Id. at 2-1)
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`Figure 1-1 of the CRD-5500 User Manual illustrates how the controller's
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`RAID set configuration utility can be used to configure virtual or logical storage
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`regions by assigning individual disk drives to RAID sets and partitioning the RAID
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`sets into logical storage regions called redundancy groups. (Id. at 1-2) Each
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`redundancy group may have a particular purpose and, as such, a particular
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`configuration including, in some examples, striped partitions, data mirroring, or a
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`combination thereof. (Id.; see also id. at 1-5 and 1-7)
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`The CRD-5500 controller's “Host LUN [Logical Unit Number] Mapping”
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`feature “makes it possible to map RAID sets” or redundancy groups (a RAID set
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`or portion/partition thereof) “differently to each host.” (Id. at 1-1; see also id. at
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`1-10; see also id. at 4-5) As illustrated in the “Host LUN Mapping” utility
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`disclosed in the CRD-5500 User Manual, a particular host device (identified as
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`“Channel 0”) is allotted access to one or more RAID redundancy groups (e.g.,
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`redundancy groups 0, 1, 5, and 6 through 31). The host device is provided an
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`address for accessing each RAID redundancy group through a “Host LUN”
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`(logical unit number, an addressing mechanism). (See e.g., id. at 4-5; 4-10; and
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`6-10) An administrator can allocate a particular disk as a redundancy group, such
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`that a host LUN maps to a single physical disk or partition thereof. (See, e.g., id.
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`at 2-3, 2-4, 3-3, 3-4) Accordingly, the “Host LUN Mapping” utility of the CRD-
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`5500 controller provides virtual local storage to a host device by presenting
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`access to one or more RAID redundancy groups using LUN-based addressing.
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`(Id. at 4-5) Further, the “Host LUN Mapping” utility allows the CRD-5500
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`controller to restrict a particular host’s access to a given memory region on the
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`RAID array by withholding addresses (i.e., “Host LUNs”) for particular RAID
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`redundancy groups to that host (e.g., redundancy groups 2 through 4 have been
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`excluded from the list of redundancy groups for which Host LUNs have been
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`assigned to the host illustrated). (See id; see also id. at 1-1, “You make the same
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`redundancy group show up on different LUNs to different hosts, or make a
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`redundancy group visible to one host but not to another.”; id. at 1-11, “[T]he
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`CRD-5500 defines each RAID set or partition of a RAID set as a ‘redundancy
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`group.’ These redundancy groups may be mapped to host LUNs, either in a direct
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`one-to-one relationship or in a manner defined by the user.”)
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`The CRD-5500 Data Sheet notes that the modular design of the CRD-5500
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`controller supports interfacing with host and/or storage devices via a high speed
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`serial connection such as a FC transport medium:
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`Unlike other RAID controllers, CMD's advanced ‘Viper’ RAID
`architecture and ASICs were designed to support tomorrow's
`high speed serial interfaces, such as Fiberchannel (FCAL). (Ex.
`1004 at p. 1 (emphasis added))
`2. Introduction of the Smith Reference
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`Smith et al., Tachyon: A Gigabit Fibre Channel Protocol Chip, Hewlett-
`
`
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`Packard Journal, October 1996 (“Smith”) was published in October of 1996,
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`over a year before the earliest priority date of the ‘147 Patent (December 31,
`
`1997). Smith is therefore prior art under 35 U.S.C. §102(b).
`
`
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`Smith describes the off-the-shelf Tachyon controller which is used in the
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`preferred embodiment of the ‘147 Patent. (Ex. 1001 at 6:17) The Tachyon chip is
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`designed to serve as, among other things, a host adapter by de-encapsulating SCSI
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`commands and responses received at the host device for internal processing and by
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`encapsulating the SCSI commands and responses prior to sending over a FC link
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`connected a FC (FCP) device. (Ex. 1005 at p. 4) Indeed,
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`[t]he second major design goal was that Tachyon should support
`SCSI encapsulation over Fibre Channel (known as FCP). From the
`beginning of the project, Tachyon designers created SCSI assists to
`support SCSI initiator transactions. …Early in the design, Tachyon
`only supported SCSI initiator functionality with its SCSI hardware
`assists. It became evident from customer feedback, however, that
`Tachyon must support SCSI target functionality as well, so SCSI
`target functionality was added to Tachyon hardware assists. (Id.)
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`The SCSI target functionality of the Tachyon allows for mass storage support by
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`adapting the FC controller chip for use in a FC target adapter card, such as the
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`host interface modules of the CRD-5500. (Id. at p. 3)
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`3. The Combined System of CRD-5500 User Manual,
`CRD-5500 Data Sheet and Smith
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`It would have been obvious to one of ordinary skill in the art to combine the
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` 
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`CRD-5500 User Manual, the CRD-5500 Data Sheet, and Smith to enhance the
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`communication and storage options of a host device on a FC transport medium,
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`benefit from the “Host LUN Mapping” feature of the CRD-5500 controller, and
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`avail the host computing device of ubiquitous mass storage applications (e.g.,
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`RAID). (Ex. 1010 ¶¶ 39-43) This combination is specifically suggested in the
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`CRD-5500 Data Sheet, which explains that “CMD's advanced ‘Viper’ RAID
`
`architecture and ASICs were designed to support tomorrow's high speed serial
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`interfaces, such as Fiberchannel.” (Ex. 1004 at p. 1) FC’s high bandwidth and
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`capability to extend the distances between hosts and the storage controller each
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`provided a strong motivation to adopt the CRD-5500 Data Sheet’s suggestion to
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`enhance the CRD-5500 controller with FC connectivity for host and/or storage
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`device modules designed with Tachyon chips of Smith. (See generally Ex. 1004 at
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`pp. 1-2)
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`In the combined system, the Tachyon chip is incorporated into FC enabled
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`host device interface modules installed in I/O slots of the CRD-5500 controller.
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`(See e.g., Ex. 1010 at ¶¶ 41-42) Professor Chase explains that the Tachyon chip
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`encapsulates and de-encapsulates SCSI commands transported over FC transport
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`media to enable intercommunication between the SCSI-based processing system of
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`the CRD-5500 and both FC host devices and FC storage devices. (See e.g., id. at
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`¶¶ 36, 38, 41-43; Ex. 1005 at pp. 4, 9, and 10; see also Ex. 1004 at pp. 1-2)