ORACLE EXHIBIT 1009
`
`ORACLE EXHIBIT 1009
`
`PART 1
`
`PART 1
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`
`

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`Case 1:13-cv-00895-SS Document 31 Filed 04/09/14 Page 1 of 8
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
` §
` §
` §
` § CIVIL ACTION NO. 1:14-CV-00895-SS
` §
` §
` §
` §
` §
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` JURY DEMANDED
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`CROSSROADS SYSTEMS, INC.,
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`Plaintiff,
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`v.
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`ORACLE CORPORPORATION,
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`Defendant.
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`CROSSROADS SYSTEMS, INC.’S CONCISE STATEMENT OF INFRINGEMENT
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`Oracle Ex. 1009, pg. 1
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`

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`Case 1:13-cv-00895-SS Document 31 Filed 04/09/14 Page 2 of 8
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`Crossroads Systems, Inc. (“Crossroads”) alleges that Oracle Corporation (“Oracle”)
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`infringes United States Patent No. 6,425,035 (the “’035 Patent”), United States Patent No.
`
`7,934,041 (the “’041 Patent”) and United States Patent No. 7,051,147 (the “’147 Patent”).1
`
`More particularly, Crossroads alleges that Oracle infringes directly and indirectly, either literally
`
`or under the doctrine of equivalents, Claims 1-4 and 7-14 of the ’035 Patent. Crossroads further
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`alleges that Oracle infringes directly and indirectly, either literally or under the doctrine of
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`equivalents, Claims 1-3, 5, 6, 10-12, 14-16, 19, 37-39, 41-42, 46-48, 50-52 of the ’041 Patent.
`
`Crossroads further alleges that Oracle infringes directly and indirectly, either literally or under
`
`the doctrine of equivalents, Claims 1-4, 6-16, 18-19, 21-23, 25-26, 28-30, 32-35 and 37-38 of the
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`’147 Patent.2
`
`Crossroads alleges that Oracle has infringed the ’035 and ’041 Patents by making, using,
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`offering to sell, importing and/or selling its Pillar Axiom systems with FC SAN Slammers, iSCSI
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`SAN Slammers and Combination FC/iSCSI SAN Slammers,3 ZFS Storage Appliances,4 Sun
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`Storage Unified Storage Systems,5 Sun Storage Arrays and Sun StorageTek Arrays with FC or
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`iSCSI interfaces,6 Sun StorageTek NAS Appliances,7 Oracle Servers with Solaris with SCSI
`
`1 The ’035, ’041 and ’147 Patents disclose apparatuses and methods for providing access controls/controlling access
`between hosts and remote storage, allowing access to remote storage using native low level block protocols. The
`’035 Patent and ’041 Patent provide access controls/control access between hosts and “remote” storage, where the
`storage is remote if there is a serial network transport medium connection between host and storage. The ’147
`Patent, on the other hand, requires that the transport mediums between the host and storage be fibre channel
`transport mediums, a particular example of a serial transport medium.
`2 This statement is preliminary as Crossroads has received no discovery from Oracle. Crossroads reserves the right
`to supplement and/or amend its positions herein based upon further information obtained during the discovery
`process, claim construction or further analysis (including adding additional infringing products Crossroads may
`determine that Oracle makes, uses, offers to sell, sells or imports (or has made, used, offered to sell, sold or
`imported), other than those specifically called out below that infringe one or more of the ’035, ’041 and ’147
`Patents).
`3 For example, Pillar Axiom 300 and Pillar Axiom 600.
`4 For example, Sun ZFS Storage 7120 Appliance, Sun ZFS Storage 7320 Appliance, Sun ZFS Storage 7420
`Appliance, ZS3-2 Storage Appliance, ZS3-4 Storage Appliance.
`5 For example, Sun Unified Storage Systems 7110, 7210, 7310, 7410.
`6 For example, Sun StorageTek 6140 Array, Sun StorageTek 6540 Array, Sun StorageTek 2540 Array, Sun Storage
`6180 Array, Sun Storage 2540-M2 Array.
`
`Oracle Ex. 1009, pg. 2
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`

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`Case 1:13-cv-00895-SS Document 31 Filed 04/09/14 Page 3 of 8
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`Target Mode Framework (STMF)8 (the “Accused Devices”) and Solaris with STMF (the
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`“Accused Software Product”). Crossroads further alleges that Oracle has infringed the ’147
`
`Patent by making, using, offering to sell, importing and/or selling its Pillar Axiom systems with
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`FC SAN Slammers and Combination FC/iSCSI SAN Slammers9 and Sun Storage Arrays and
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`Sun StorageTek Arrays with FC interfaces and FC storage10 (the “Accused Fibre-to-Fibre
`
`Devices”).
`
`I.
`
`’035 Patent
`
`With respect to Claim 1 (and the asserted claims depending from Claim 1), the Accused
`
`Devices and systems implementing the Accused Software Products infringe by providing virtual
`
`local storage on remote storage devices to hosts so that the storage appears to the host as locally
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`connected (despite the fact that the storage is indirectly connected to the host through at least one
`
`serial transport medium).11 Claim 1 recites various hardware limitations, such as a buffer, first
`
`controller, second controller and supervisor unit each of which are included in the Accused
`
`Devices and systems implementing the Accused Software Products. The Accused Devices and
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`the Accused Software Products provide a map that creates a path between the host and the
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`storage that includes a representation of the host (e.g., World Wide Name or IQN) and a
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`representation of the storage (e.g., LUN). In this way, the Accused Devices and Accused
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`Software Products allocate subsets of storage to associated host(s) so that a particular subset of
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`storage is accessible by only the associated host(s), thereby providing controls which limit
`
`7 For example, Sun StorageTek 5320 NAS Appliance.
`8 For example, Oracle SPARC and x86 Servers with Solaris with STMF.
`9 For example, Pillar Axiom 300 and Pillar Axiom 600.
`10 For example, Sun StorageTek Sun StorageTek 6140 Array, Sun StorageTek 6540 Array, Sun Storage 6180 Array.
`11 Attached hereto as Exhibits A1-A5 are claims charts showing infringement of the ’035 Patent by exemplary
`Oracle products.
`
`Oracle Ex. 1009, pg. 3
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`

`
`Case 1:13-cv-00895-SS Document 31 Filed 04/09/14 Page 4 of 8
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`host(s) access to the storage.12 The Accused Devices and systems implementing the Accused
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`Software Products receive native low level block protocol commands (e.g., SCSI commands)
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`from the hosts via a serial network transport (e.g., fibre channel, iSCSI transport) to allow hosts
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`to access storage using native low level block protocols (i.e., protocols that do not require the
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`overhead of high level protocols or file systems typically required of network servers (e.g., the
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`SCSI protocol)).13
`
`With respect to Claim 7 (and the asserted claims depending from Claim 7), Oracle
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`provides instructions to users regarding how to operate its Accused Devices and Accused
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`Software Products in a storage network.14 With respect to Claim 11 (and the asserted dependent
`
`claims), the Accused Devices and Accused Software Products perform and are used to perform
`
`the claimed method of providing virtual local storage.15
`
`II.
`
`’041 Patent
`
`With respect to Claim 1 (and the asserted claims depending from Claim 1), the Accused
`
`Devices and systems implementing the Accused Software Products infringe by providing virtual
`
`local storage on remote storage devices to hosts so that the storage appears to the host as locally
`
`12 Oracle describes the ability of Pillar Axiom systems to provide the claimed access controls as “LUN mapping.”
`With respect to the ZFS Storage Appliances, Oracle describes the ability to provide the claimed access controls by
`associating LUNs with initiator groups and states “when a LUN is associated with a specific initiator group, the
`LUN will only be visible to initiators in the group” and “a LUN can only be seen by the initiators in the group or
`groups to which it belongs.” With respect to the Sun Storage Arrays and Sun StorageTek Arrays, Oracle describes
`the ability to provide the claimed access controls by “mapping a host to a volume.” With respect to Sun StorageTek
`NAS Appliances, Oracle describes the ability to provide the claimed access controls by defining “which Internet
`Small Computer Systems (iSCSI) initiators can access a logical unit number (LUN) by creating an iSCSI access
`list.” Oracle describes the ability of the Accused Software Products to provide the claimed access controls as
`“selective mapping” that “enables you to specify the hosts that can access the LUN.” Regardless of how it is
`phrased, each of the Accused Devices and Accused Software Products include the capability of mapping storage to
`hosts and only allowing host(s) to access storage this is mapped to such host(s).
`13 Oracle provides instructions to operate systems using the Accused Software Products as the claimed storage router
`and the Accused Software Products have no alternative function other than to operate in a storage router as claimed
`in Claim 1 of the ’035 Patent.
`14 The Accused Devices and Accused Software products have no alternative function other than to operate in a
`storage network as claimed in Claim 7 of the ’035 Patent.
`15 Oracle provides instructions to perform the method of providing virtual local storage as claimed using its Accused
`Devices and Accused Software Products. The Accused Devices and Accused Software Products have no alternative
`function other than to operate in accordance with the method as claimed in Claim 11 of the ’035 Patent.
`
`Oracle Ex. 1009, pg. 4
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`

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`Case 1:13-cv-00895-SS Document 31 Filed 04/09/14 Page 5 of 8
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`connected (despite the fact that the storage is indirectly connected to the host through at least one
`
`serial transport medium).16 Claim 1 recites various hardware limitations, such as a first
`
`controller and processing device each of which are included in the Accused Devices and systems
`
`implementing the Accused Software Products. The Accused Devices and the Accused Software
`
`Products provide a map that creates a path between the host and the storage that includes a
`
`representation of the host (e.g., World Wide Name or IQN) and a representation of the storage
`
`space (e.g., LUN). In this way, the Accused Devices and Accused Software Products allocate
`
`subsets of storage to associated host(s) so that a particular subset of storage is accessible by only
`
`the associated host(s), thereby providing controls which limit host(s) access to the storage. The
`
`Accused Devices and systems implementing the Accused Software Products receive native low
`
`level block protocol commands (e.g., SCSI commands) from the hosts via their serial transport
`
`(e.g., fibre channel, iSCSI transport) to allow hosts to access storage using native low level block
`
`protocols (i.e., protocols that do not require the overhead of high level protocols or file systems
`
`typically required of network servers (e.g., the SCSI protocol)).17
`
`With respect to Claim 37 (and the asserted dependent claims), the Accused Devices and
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`Accused Software Products perform and are used to perform the claimed method of providing
`
`virtual local storage.18
`
`III.
`
`’147 Patent
`
`16 Attached hereto as Exhibits B1-B5 are claims charts showing infringement of the ’041 Patent by exemplary
`Oracle products.
`17 Oracle provides instructions to operate systems using the Accused Software Products as the claimed storage router
`and the Accused Software Products have no alternative function other than to operate in a storage router as claimed
`in Claim 1 of the ’041 Patent.
`18 Oracle provides instructions to perform the method of providing virtual local storage as claimed using its Accused
`Devices and Accused Software Products. The Accused Devices and Accused Software Products have no alternative
`function other than to operate in accordance with the method as claimed in Claim 37 of the ’041 Patent.
`
`Oracle Ex. 1009, pg. 5
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`

`
`Case 1:13-cv-00895-SS Document 31 Filed 04/09/14 Page 6 of 8
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`
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`With respect to Claims 1 and 14 (and the asserted claims depending from Claims 1 and
`
`14), the Accused Fibre-to-Fibre Devices infringe by providing virtual local storage on remote
`
`storage devices to hosts so that the storage appears to the host as locally connected (despite the
`
`fact that the Fibre-to-Fibre Devices communicate with both hosts and storage using fibre channel
`
`transports).19 Each of the Accused Fibre-to-Fibre Devices maintains a configuration that maps
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`between host devices and subsets of storage. The Accused Fibre-to-Fibre Devices allocate
`
`subsets of storage to associated host(s) so that a particular subset of storage is accessible by only
`
`the associated host(s), thereby providing controls which limit host(s) access to the storage. The
`
`Accused Fibre-to-Fibre Devices receive native low level block protocol commands (e.g., SCSI
`
`commands) from the hosts via a serial Fibre Channel transport to allow hosts to access storing
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`using native low level block protocols.
`
`With respect to Claim 6 (and the asserted claims depending from Claim 6), Oracle
`
`provides instructions to users regarding how to operate the Accused Fibre-to-Fibre Devices in a
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`storage network. With respect to Claims 21 and 34 (and the asserted claims depending from
`
`Claims 21 and 34), Oracle provides instructions to users regarding how to operate the Accused
`
`Fibre-to-Fibre Devices in a system. With respect to Claims 10 and 28 (and the asserted claims
`
`depending from Claims 10 and 28), the Accused Fibre-to-Fibre Devices perform the claimed
`
`method and Oracle provides instructions to users regarding how to perform the method as
`
`claimed using the Accused Fibre-to-Fibre Devices.20, 21
`
`19 Attached hereto as Exhibits C1-C2 are claims charts showing infringement of the ’147 Patent by exemplary
`Oracle products.
`20 The Accused Fibre-to-Fibre Devices have no alternative function other than to operate in a storage network as
`claimed in Claim 6 and system as claimed in Claim 21 of the ’147 Patent. The Accused Fibre-to-Fibre Devices have
`no alternative function other than to operate in accordance with the methods as claimed in claims 10 and 28.
`21 Attached hereto as Exhibits D-K are the ’035, ’041 and ’147 Patents and Prosecution Histories. At the request of
`the Court, Crossroads is submitting, by hand delivery, a copy of the prosecution histories on CD-ROM and a
`summary for each prosecution history.
`
`Oracle Ex. 1009, pg. 6
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`

`
`Case 1:13-cv-00895-SS Document 31 Filed 04/09/14 Page 7 of 8
`
` Respectfully submitted,
`
`
`
`
`
`
`
`Dated: April 9, 2014
`
`
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`
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`
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`
`
`By: /s/ Steven R. Sprinkle
` Steven Sprinkle
` Texas Bar No. 00794962
` Elizabeth J. Brown Fore
` Texas Bar No. 24001795
` Sprinkle IP Law Group, PC
` 1301 W. 25th Street, Suite 408
` Austin, Texas 78705
` Tel: 512-637-9220
` Fax: 512-371-9088
` ssprinkle@sprinklelaw.com
` ebrownfore@sprinklelaw.com
`
`
`Susan K. Knoll
`Texas Bar No. 11616900
`Russell T. Wong
`Texas Bar No. 21884235
`James H. Hall
`Texas Bar No. 24041040
`Stephen D. Zinda
`Texas Bar No. 24084147
`WONG, CABELLO, LUTSCH,
`RUTHERFORD & BRUCCULERI, L.L.P.
`20333 SH 249, Suite 600
`Houston, TX 77070
`Tel: 832-446-2400
`Fax: 832-446-2424
`sknoll@counselip.com
`rwong@counselip.com
`jhall@counselip.com
`szinda@counselip.com
`
`ATTORNEYS FOR PLAINTIFF
`CROSSROADS SYSTEMS, INC.
`
`
`
`Oracle Ex. 1009, pg. 7
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`

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`Case 1:13-cv-00895-SS Document 31 Filed 04/09/14 Page 8 of 8
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`CERTIFICATE OF SERVICE
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`I hereby certify that on the 9th day of April, 2014, I electronically filed the foregoing
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`with the Clerk of the Court using the CM/ECF system which will send notification of such filing
`to the following:
`
`Patton C. Lochridge
`McGINNIS, LOCHRIDGE & KILGORE, LLP
`1300 Capitol Center
`919 Congress Avenue
`Austin, TX 78701
`
`Jared Bobrow (Pro Hac Vice)
`Sonal N. Mehta (Pro Hac Vice)
`Jill J. Schmidt (Pro Hac Vice)
`Aaron Y. Huang (Pro Hac Vice)
`WEIL, GOTSHAL & MANGES, LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` /s/ Steven R. Sprinkle
`Steven R. Sprinkle
`
`
`
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`Oracle Ex. 1009, pg. 8
`
`

`
`access to the storage associated with the LUNs to which the host is mapped.
`Axiom Systems control host to storage access because each host will only have
`create a path between a host and the LUNs to which the host is mapped. The Pillar
`computer and LUN (e.g., by WWN or iSCSI name) through LUN mapping to
`storage. The Pillar Axiom Systems further create a correspondence between a host
`The Pillar Axiom Systems assign Logical Unit Numbers (LUNs) to subsets of
`
`Axiom Systems allow host access to storage (in accordance with the map) using
`commands) transported over Fibre Channel or an iSCSI transport. The Pillar
`The Pillar Axiom Systems receive SCSI commands (native low level block storage
`
`
`
`
`
`FC/ iSCSI SAN Slammer).
`transport medium (Pillar Axiom iSCSI SAN Slammer, Pillar Axiom Combination
`Slammer, Pillar Axiom Combination FC/iSCSI SAN Slammer) or an iSCSI
`and interface with a Fibre Channel transport medium (Pillar Axiom FC SAN
`The Pillar Axiom Systems have a host side controller that is operable to connect to
`
`
`
`interface with a Fibre Channel transport medium.
`The Pillar Axiom Systems contain a second controller operable to connect to and
`
`
`
`The Pillar Axiom Systems contain a processor coupled as claimed.
`
`storage appears to the hosts to be local.
`serial network transport medium, making the storage remote from the hosts. The
`other devices. The Pillar Axiom Systems allow hosts to connect to storage via a
`are storage routers that provide virtual local storage on remote storage devices to
`Slammer or Combination FC/iSCSI SAN Slammer (the “Pillar Axiom Systems”)
`The Pillar Axiom 300 and Pillar Axiom 600 with FC SAN Slammer, iSCSI SAN
`Pillar Axiom 300, Pillar Axiom 600
`
`The Pillar Axiom Systems include cache memory.
`
`
`
`second controller to allow access from devices
`buffer to interface between the first controller and the
`[the supervisor unit operable:] to process data in the
`
`on the storage devices; and
`devices to implement access controls for storage space
`connected to the first transport medium and the storage
`the supervisor unit operable to map between devices
`second controller and the buffer,
`a supervisor unit coupled to the first controller, the
`
`with a second transport medium; and
`a second controller operable to connect to and interface
`
`with a first transport medium;
`a first controller operable to connect to and interface
`
`router;
`a buffer providing memory work space for the storage
`
`
`
`remote storage devices to devices comprising:
`1. A storage router for providing virtual local storage on
`Claim Limitation
`
`U.S. Patent No. 6,425,035 Claims Chart – Pillar Axiom 300, Pillar Axiom 600
`
`EXHIBIT A1
`
`
`
`Case 1:13-cv-00895-SS Document 31-1 Filed 04/09/14 Page 1 of 5
`
`
`
`Oracle Ex. 1009, pg. 9
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`

`
`Mapping is conducted as recited above for Claim 1.
`
`claimed.
`The Pillar Axiom Systems are storage routers that provide virtual local storage as
`
`medium.
`The Pillar Axiom Systems connect to storage devices via a second transport
`
`
`
`network.
`Axiom Systems have no other function than to operate in the claimed storage
`Oracle provides instructions to operate a storage network as claimed and the Pillar
`
`
`
`The hosts in the storage network can be workstations.
`
`
`
`See Claim 1.
`
`
`
`See Claim 1.
`
`The storage connected to the Pillar Axiom Systems can be hard disk drives.
`
`mapped to a LUN.
`storage associated with a LUN is accessible by only the host(s) that have been
`mapping one or more LUNs to one or more hosts. In this manner, each subset of
`The Pillar Axiom Systems maintain an allocation of subsets of storage to hosts by
`
`The hosts connected to the Pillar Axiom Systems can be workstations.
`
`
`
`
`
`devices to the workstations and operable
`router providing virtual local storage on the storage
`medium and the second transport medium, the storage
`storage router interfacing between the first transport
`
`devices;
`to map between the workstations and the storage
`
`
`
`transport medium;
`a plurality of storage devices connected to the second
`
`transport medium;
`a plurality of workstations connected to the first
`
`
`
`a second transport medium;
`
`a first transport medium;
`
`workstations.
`connected to the first transport medium comprise
`3. The storage router of claim 2, wherein the devices
`device connected to the first transport medium.
`wherein each subset is only accessible by the associated
`associated devices connected to the first transport medium,
`unit maintains an allocation of subsets of storage space to
`2. The storage router of claim 1, wherein the supervisor
`
`devices comprise hard disk drives.
`4. The storage router of claim 2, wherein the storage
`
`7. A storage network, comprising:
`
`
`
`
`
`protocols or file systems.
`these SCSI storage commands which do not include the overhead of high level
`
`devices using native low level, block protocols.
`connected to the first transport medium to storage
`
`Case 1:13-cv-00895-SS Document 31-1 Filed 04/09/14 Page 2 of 5
`
`Oracle Ex. 1009, pg. 10
`
`

`
`The Pillar Axiom Systems contain a processor coupled as claimed.
`
`into the memory.
`The second controller reads outgoing data from the memory and writes other data
`
`the memory.
`The first controller reads outgoing data from the memory and writes other data into
`
`See Claim 1.
`
`
`
`See Claim 4.
`
`See Claim 2.
`
`Access is allowed as recited above for Claim 1.
`
`Access controls are provided as recited above for Claim 1.
`
`accessible by the associated workstation.
`associated workstations, wherein each subset is only
`controls include an allocation of subsets of storage space to
`8. The storage network of claim 7, wherein the access
`
`storage devices;
`to implement access controls for storage space on the
`
`
`
`
`
`accordance with the mapping and access controls.
`devices using native low level, block protocol in
`to allow access from the workstations to the storage
`
`
`
`
`
`devices comprise hard disk drives.
`9. The storage network of claim 7, wherein the storage
`
`
`
`and to place incoming data into the buffer;
`further operable to pull outgoing data from the buffer
`with the second transport medium, the second controller
`a second controller operable to connect to and interface
`
`operable:
`second controller and the buffer, the supervisor unit
`a supervisor unit coupled to the first controller, the
`
`
`
`
`
`
`
`and to place incoming data into the buffer
`further operable to pull outgoing data from the buffer
`with the first transport medium, the first controller
`a first controller operable to connect to and interface
`
`
`
`router;
`a buffer providing memory work space for the storage
`
`
`
`router comprises:
`10. The storage network of claim 7, wherein the storage
`
`Case 1:13-cv-00895-SS Document 31-1 Filed 04/09/14 Page 3 of 5
`
`Oracle Ex. 1009, pg. 11
`
`

`
`See Claim 3.
`
`See Claim 2.
`
`Allowing access is provided as recited above for Claim 1.
`
`Mapping and providing access controls are provided as recited above for Claim 1.
`
`See Claim 1.
`
`
`
`See Claim 1.
`
`
`
`claimed method.
`Pillar Axiom Systems having no other function than to operate according to the
`Oracle provides instructions to perform the method as claimed, and provides the
`
`Access controls are provided and access allowed as recited above for Claim 1.
`
`Mapping is conducted as recited above for Claim 1.
`
`level, block protocols.
`transport medium to the storage devices using native low
`allowing access from devices connected to the first
`
`access controls for storage space on the storage devices;
`medium and the storage devices and implementing
`mapping between devices connected to the first transport
`
`
`
`
`
`associated device connected to the first transport medium.
`medium, wherein each subset is only accessible by the
`to associated devices connected to the first transport
`storage devices includes allocating subsets of storage space
`devices connected to the first transport medium and the
`12. The method of claim 11, wherein mapping between
`
`to the first transport medium comprise workstations.
`13. The method of claim 12, wherein the devices connected
`
`
`
`
`
`interfacing with a second transport medium;
`
`devices.
`controller to allow access from workstations to storage
`interface between the first controller and the second
`storage devices and to process data in the buffer to
`to implement the access controls for storage space on the
`
`medium and the storage devices,
`to map between devices connected to the first transport
`
`
`
`
`
`comprising:
`devices connected to another transport medium,
`storage devices connected to one transport medium to
`11. A method for providing virtual local storage on remote
`
`interfacing with a first transport medium;
`
`
`
`Case 1:13-cv-00895-SS Document 31-1 Filed 04/09/14 Page 4 of 5
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`Oracle Ex. 1009, pg. 12
`
`

`
`See Claim 4.
`
`comprise hard disk drives.
`14. The method of claim 12, wherein the storage devices
`
`
`
`
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`Case 1:13-cv-00895-SS Document 31-1 Filed 04/09/14 Page 5 of 5
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`Oracle Ex. 1009, pg. 13
`
`

`
`associated with the LUNs to which the host is mapped.
`host to storage access because each host will only have access to the storage
`LUNs to which the host is mapped. The Oracle ZFS Storage Appliances control
`by assigning LUNs to initiator groups to create a path between a host and the
`correspondence between a host computer and LUN (e.g., by WWN or iSCSI name)
`subsets of storage. The Oracle ZFS Storage Appliances further create a
`The Oracle ZFS Storage Appliances assign Logical Unit Numbers (LUNs) to
`
`The Oracle ZFS Storage Appliances allow host access to storage (in accordance
`block storage commands) transported over Fibre Channel or an iSCSI transport.
`The Oracle ZFS Storage Appliances receive SCSI commands (native low level
`
`
`
`
`
`and interface with a second transport medium (e.g., SAS, SATA)
`Oracle ZFS Storage Appliances contain a second controller operable to connect to
`
`transport medium.
`connect to and interface with an iSCSI transport medium or a Fibre Channel
`The Oracle ZFS Storage Appliances have a host side controller that is operable to
`
`
`
`
`
`The Oracle ZFS Storage Appliances contain a processor coupled as claimed.
`
`appears to the hosts to be local.
`network transport medium, making the storage remote from the hosts. The storage
`The Oracle ZFS Storage Appliances allow hosts to connect to storage via a serial
`routers that provide virtual local storage on remote storage devices to other devices.
`Storage ZS3-4 Appliance (the “Oracle ZFS Storage Appliances”) are storage
`Storage 7420 Appliance, Oracle ZFS Storage ZS3-2 Appliance and Oracle ZFS
`The Sun ZFS Storage 7120 Appliance, Sun ZFS Storage 7320 Appliance, Sun ZFS
`ZFS Storage Appliance
`
`The Oracle ZFS Storage Appliances include cache memory.
`
`
`
`second controller to allow access from devices
`buffer to interface between the first controller and the
`[the supervisor unit operable:] to process data in the
`
`on the storage devices; and
`devices to implement access controls for storage space
`connected to the first transport medium and the storage
`the supervisor unit operable to map between devices
`second controller and the buffer,
`a supervisor unit coupled to the first controller, the
`
`with a second transport medium; and
`a second controller operable to connect to and interface
`
`with a first transport medium;
`a first controller operable to connect to and interface
`
`router;
`a buffer providing memory work space for the storage
`
`
`
`remote storage devices to devices comprising:
`1. A storage router for providing virtual local storage on
`Claim Limitation
`
`U.S. Patent No. 6,425,035 Claims Chart – ZFS Storage Appliance
`
`EXHIBIT A2
`
`
`
`Case 1:13-cv-00895-SS Document 31-2 Filed 04/09/14 Page 1 of 5
`
`
`
`Oracle Ex. 1009, pg. 14
`
`

`
`Mapping is conducted as recited above for Claim 1.
`
`storage as claimed.
`The Oracle ZFS Storage Appliances are storage routers that provide virtual local
`
`transport medium.
`The Oracle ZFS Storage Appliances connect to storage devices via a second
`
`
`
`storage network.
`ZFS Storage Appliances have no other function than to operate in the claimed
`Oracle provides instructions to operate a storage network as claimed and the Oracle
`
`
`
`See Claim 1.
`
`The hosts in the storage network can be workstations.
`
`
`
`See Claim 1.
`
`
`
`drives.
`The storage connected to the Oracle ZFS Storage Appliances can be hard disk
`
`been mapped to a LUN.
`subset of storage associated with a LUN is accessible by only the host(s) that have
`hosts by mapping one or more LUNs to one or more hosts. In this manner, each
`The Oracle ZFS Storage Appliances maintain an allocation of subsets of storage to
`
`The hosts connected to the Oracle ZFS Storage Appliances can be workstations.
`
`
`
`overhead of high level protocols or file systems.
`with the map) using these SCSI storage commands which do not include the
`
`devices using native low level, block protocols.
`connected to the first transport medium to storage
`
`Case 1:13-cv-00895-SS Document 31-2 Filed 04/09/14 Page 2 of 5
`
`
`
`devices to the workstations and operable
`router providing virtual local storage on the storage
`medium and the second transport medium, the storage
`storage router interfacing between the first transport
`
`devices;
`to map between the workstations and the storage
`
`
`
`transport medium;
`a plurality of storage devices connected to the second
`
`transport medium;
`a plurality of workstations connected to the first
`
`
`
`a second transport medium;
`
`a first transport medium;
`
`workstations.
`connected to the first transport medium comprise
`3. The storage router of claim 2, wherein the devices
`device connected to the first transport medium.
`wherein each subset is only accessible by the associated
`associated devices connected to the first transport medium,
`unit maintains an allocation of subsets of storage space to
`2. The storage router of claim 1, wherein the supervisor
`
`devices comprise hard disk drives.
`4. The storage router of claim 2, wherein the storage
`
`7. A storage network, comprising:
`
`
`
`
`
`Oracle Ex. 1009, pg. 15
`
`

`
`The Oracle ZFS Storage Appliances contain a processor coupled as claimed.
`
`into the memory.
`The second controller reads outgoing data from the memory and writes other data
`
`the memory.
`The first controller reads outgoing data from the memory and writes other data into
`
`See Claim 1.
`
`
`
`See Claim 4.
`
`See Claim 2.
`
`Access is allowed as recited above for Claim 1.
`
`Access controls are provided as recited above for Claim 1.
`
`accessible by the associated workstation.
`associated workstations, wherein each subset is only
`controls include an allocation of subsets of storage space to
`8. The storage network of claim 7, wherein the access
`
`storage devices;
`to implement access controls for storage space on the
`
`
`
`
`
`accordance with the mapping and access controls.
`devices using native low level, block protocol in
`to allow access from the workstations to the storage
`
`
`
`
`
`devices comprise hard disk drives.
`9. The storage network of claim 7, wherein the storage
`
`
`
`and to place incoming data into the buffer;
`further operable to pull outgoing data from the buffer
`with the second transport medium, the second controller
`a second controller operable to connect to and interface
`
`operable:
`second controller and the buffer, the supervisor unit
`a supervisor unit coupled to the first controller, the
`
`
`
`
`
`
`
`and to place incoming data into the buffer
`further operable to pull outgoing data from the buffer
`with the first transport medium, the first controller
`a first controller operable to connect to and interface
`
`
`
`router;
`a buffer providing memory work space for the storage
`
`
`
`router comprises:
`10. The storage network of claim 7, wherein the storage
`
`Case 1:13-cv-00895-SS Document 31-2 Filed 04/09/14 Page 3 of 5
`
`Oracle Ex. 1009, pg. 16
`
`

`
`See Claim 3.
`
`See Claim 2.
`
`Allowing access is provided as recited above for Claim 1.
`
`Mapping and providing access controls are provided as recited above for Claim 1.
`
`See Claim 1.
`
`
`
`See Claim 1.
`
`
`
`to the claimed method.
`Oracle ZFS Storage Appliances having no other function than to operate according
`Oracle provides instructions to perform the method as claimed, and provides the
`
`Access controls are provided and access allowed as recited above for Claim 1.
`
`Mapping is conducted as recited above for Claim 1.
`
`level, block protocols.
`transport medium to the storage devices using native low
`allowing access from devices connected to the first
`
`access controls for storage space on the storage devices;
`medium and the storage devices and implementing
`mapping between devices connected to the first transport
`
`
`
`
`
`associated device connected to the first transport medium.