ORACLE EXHIBIT 1024
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`ORACLE EXHIBIT 1024
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`PART 2
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`PART 2
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`ORACLE EXHIBIT 1024
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`PART 2
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`PART 2
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`06I11I2001 Trial, Day 3
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`there's no access to devices three,
`
`four and five.
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`‘Q. Okay. And so if we go back to the colorized version of
`
`exhibit 552, which computer screen shot were we looking at
`
`then?
`
`A. We were looking at the left computer the one shown in
`
`blue.
`
`Q.
`
`Now, should we look at the right one?
`
`A. Yes.
`
`Q. And now I'm showing, again, a screen shot from exhibit
`
`110, your Honor, showing right G 06, windows explore er with
`
`ones three four and five enabled for right system and what is
`
`this showing?
`
`A. This is the windows ex er showing what the right system
`
`can see for storage devices and three external devices labeled
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`blue, purple and orange.
`
`Q.
`
`It's a few pages later and it's also on the graphic
`
`exhibit in you want to look at them.
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`MR. BAHLER: What graphic exhibit?
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`A.
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`The blue, purple and yellow are —- blue, purple and orange
`
`are devices three,
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`four and five.
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`MR . ALCOCK:
`
`Q. Okay. And so now let's go back to exhibit 564. What is
`
`exhibit 564 showing?
`
`A. This is a composite of the three slides we've showed for
`
`access control-‘ The Pathlight.sun director,
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`the_left computer
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 616
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`06/11/2001 Trial, Day 3
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`and the right computer.
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`Q.
`
`A.
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`So what is this showing us,
`
`then?
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`Showing the correspondence between the checkmarks on the
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`Pathlight SAN director and the devices that are available to
`
`the particular computers.
`
`Q.
`
`A.
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`Now, how does this show access controls?
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`It shows that we have allowed access to certain devices to
`
`a particular computer and not to -- and that computer does
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`clot have access to other devices.
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`Q. Okay.
`
`So by operating the management station, you can
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`control
`
`the access of the left and the right computer to the
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`various remote storage devices?
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`A. Yes, that's true.
`
`Q. And in effect, here it shows that those computers can't
`
`even see those storage devices on their computer screen;
`
`is
`
`that right?
`
`A. That's correct.
`
`Q.
`
`A.
`
`How would they get access to them?
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`I was unable to do that.
`
`I tried doing that by running
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`SCSI —- a SCSI commands director to the particular addresses
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`and simply said the device was not recognized.
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`Q. Lastly,
`
`let me show you exhibit 611. What is exhibit 611?
`
`A. This is an excerpt
`
`from the Pathlight from one of the
`
`manuals.
`
`It's gateway,
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`I believe. And it shows the use of
`
`the SAN director and the privileges that one might have in
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`02/22/2002 8556 AM
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`Oracle Ex. 1024, pg. 617
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`06I11I2001 Trial, Day 3
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`terms of using the Pathlight SAN director. There are --
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`Q.
`
`Now, hold on one second. Let's just step back for the a
`
`moment T SAN director is what?
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`MR. BAHLER: Counsel,
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`I don't have 611 in the book.
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`MR. ALCOCK:
`
`I apologize.
`
`It was left out.
`
`You were
`
`given a copy of all the graphics earlier, counsel, every
`
`single one of them.
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`MR. ALCOCK:
`
`‘Q. Continue.
`
`A. Would you repeat the question?
`
`Q. What is exhibit 611 showing?
`
`A.
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`It's showing the —— how one uses the SAN director. And in
`
`particular, it says that there are two different privilege
`
`modes that one might have in using the SAN director. One is a
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`user privilege which simply allows you to look at things that
`
`is —- you could look at the access control and the
`
`administrator mode which allows you to actually change access
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`control.
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`Both of those actually require a pass word for access
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`before you can do anything. Here is a administrator's pass
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`word screen shot here when you log on to the Pathlight SAN
`
`director, it asks you who you are and your pass word.
`
`Q. Okay.
`
`So does the products that you've tested have the
`
`element of the claim including the access control limitation?
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`A. Yes, it does.
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 618
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`06/11/2001 Trial, Day 3
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`Q. Okay.
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`Now, finally we'll move to exhibit 565 and what is
`
`that showing, sir?
`
`A. This is showing the final element of claim 1 in which we
`
`talk about the native low level block protocol, and the text
`
`down there comes from a computer screen where I was actually
`
`operating the devices with SCSI commands addressing a
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`particular device.
`
`Q.
`
`So the bottom is another one of those screen shots from
`
`your computer?
`
`A. Yes, it is.
`
`Ql
`
`A.
`
`And what does that show?
`
`It shows that I have addressed this device with a
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`particular bus,
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`target and LUN which is the SCSI addressing
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`mechanism that I was actually was able to find that device and
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`I actually execute commands against it.
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`Q. Okay.
`
`Now,
`
`let me take us back to exhibit 559.
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`A word
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`that we didn't talk about is virtual local storage.
`
`Is that
`
`an element_of this claim and some of the other claims?
`
`A. Yes, it is.
`
`Q.
`
`And do these devices have that?
`
`A. Yes,
`
`they do.
`
`Q.
`
`A.
`
`Can you explain?
`
`Virtual local storage is what you get —- is defined as --
`
`I've got blank.
`
`I'm sorry. Storage that has the appearance
`
`and characteristics of local storage.
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`It's what you get when
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 619
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`06/11/2001 Trial, Day 3
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`you combine mapping, virtual -— native low level block
`
`protocol and access control.
`
`Q. Okay. Let me put before you an exhibit,
`
`a number of which
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`I'll give you a in a second and can you explain what that is?
`
`A. This is a summary of claim 1.
`
`Q.
`
`A.
`
`It's exhibit 572 for the record, your Honor.
`
`A summary of claim 1,
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`a summary of the graphics that you‘
`
`saw as we went
`
`through the claimed elements so that you can
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`see that each one of these looks exactly as you saw on the
`
`graphics.
`
`Q. Okay.
`
`Now I'm going to put before you claim 7.
`
`‘There
`
`were three independent claims in the patent, sir?
`
`A. Yes, that's right.
`
`Q.
`
`And is this the next independent claim?
`
`A. This is the next one.
`
`Q.
`
`And how does is this different from the other claim that
`
`we just looked at?
`
`A.
`
`The first claim that we looked at was the claim that
`
`described the storage router. This one starts off describing
`
`a storage network, Pathlight product.
`
`It's not a network,
`
`it's a router.
`
`Q. Okay. But does it go in a network?
`
`A Q
`
`A
`
`Yes, it does.
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`. Does it have any use other than being in a network?
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`Nothing substantial.
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 620
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`06/11/2001 Trial, Day 3
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`Q. Okay. And so does the products have all the elements of
`
`claim 7?
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`A. Yes, it does.
`
`Q. Okay.
`
`I've put before you exhibit 575. Does that help
`
`you explain this quickly?
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`A. Yes, it does. But we have a storage network which has
`
`such characteristics which show a photograph of the device of
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`the Pathlight SAN gateway.
`
`The block diagram, again. We have
`
`a fiber channel transport medium emphasized in red here. We
`
`have the SCSI bus transport medium emphasized in blue. We
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`have Fibre Channel transport medium is just the light pipe.
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`The SCSI bus transform medium is the SCSI came.
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`Work stations,
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`shows work stations and there are
`
`references all through the documentation to work stations.
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`Plurality of SCSI storage devices connected to the SCSI bus,
`
`connected to the fiber channel.
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`So it has all the elements of
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`claim 7.
`
`It has all the elements of claim 7, and the storage
`
`router itself is in the middle of this network, and it has
`
`exactly the same characteristics that are described in claim
`
`1.
`
`Q.
`
`Can you check those off?
`
`A. Yes. Mapping, access controls, native low level block
`
`protocol.
`
`Q. Okay.
`
`Now, claim 11 is the last independent claim.
`
`What's the basic difference between that and the other claims?
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 621
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`06/11/2001 Trial, Day 3
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`A.
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`The other claims claim specific hardware. This claims a
`
`method of doing something which looks remarkably familiar to
`
`you by now.
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`Q. And just quickly showing you exhibit 578. Does it heat
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`the elements of the method claim 11?
`
`A. Yes, it does. We have, again, we have a means describe --
`
`that's described by looking at the product itself and at the
`
`block diagram. We have a means of connecting to the Fibre
`
`Channel, means of connect together the SCSI bus.
`
`Q.
`
`A.
`
`Can you check the boxes for us?
`
`Uh—huh. We have another graphic on the rest of that?
`
`Q. Exhibit 579?
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`A. Yes, means of maintaining a configuration. We've got
`
`through that. Access controls, means of allowing access in
`
`accordance with configuration using native low level block
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`protocol.
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`So we've covered all those things before.
`
`Q.
`
`Now, very quickly Dr. Hodges because we are running out of
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`_ our allotted time here, exhibit -- I'm going to ask you very
`
`briefly about the dependent claims. Right now we've covered
`
`three independent claims. What's a dependent claim?
`
`A.
`
`A dependent claim is one that incorporates all of the
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`elements of the independent claim plus something else.
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`Q. Okay. Let's go through claims 2,
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`8 and 14 and I've shown
`
`you exhibit 580. Did they infringe those claims?
`
`A. Yes,'they do.
`
`’Claim 2,
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`8 and l4 are all similar and they.
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 622
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`06/11/2001 Trial, Day 3
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`require that one have only one computer that has access to a
`
`particular device and the access control that I defined in
`
`previously was -- covers that.
`
`Q. Okay.
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`I'm showing you exhibit 581 and I'll ask your
`
`opinion with respect to claims 3 and 13.
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`A. Claims 3 and 13 indicate that the Fibre Channel devices
`
`could have —— could be work stations. Work stations are
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`mentioned in a lot of different places in the manuals and the
`
`web site and various diagrams.
`
`Q. Okay.
`
`Now, exhibit 582 showing claims 4,
`
`9 and 14.
`
`To
`
`they infringe those claims?
`
`A. Yes,
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`the SCSI storage devices,
`
`the hard disk drives,
`
`they
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`show pictures and discussion of that throughout the
`
`documentation.
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`Q. And lastly, claims 5 and 6.
`
`Do they infringe those, sir?
`
`A. Claims 5 and 6, you have a graphic on that?
`
`Q. Exhibit 569 and I'm going to focus you on the bottom two
`
`claims.
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`A. This way I don't leave anything out. Claim 5 describes
`
`the router as in claim 1, but further defines the Fibre
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`Channel controller that has a fiber channel protocol unit,
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`first in, first out cue, direct memory access,
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`technical terms
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`all of which are contained in the Fibre Channel controller
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`found by looking at the data sheets and manuals for the
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`control that is used.
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 623
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`06/11/2001 Trial, Day 3
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`The same thing is true on claim 6.
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`The elements are
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`all there looking at the manuals and data sheets for the SCSI
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`controller that's used in the device.
`
`Q. Okay. Have a seat, sir. while you're doing that,
`
`I'm
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`going to put up a page of exhibit 153.
`
`It's page 109 of
`
`exhibit 153.
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`It's a page from if Pathlight web site.
`
`So far,
`
`Dr. Hodges, have all the tests that you've done,
`
`the screen
`
`shots that we've shown have been used with this VPS software?
`
`A. That's correct.
`
`Q.
`
`Now, earlier you mentioned you tested it with another kind
`
`of software. What was that?
`
`A. That's called channel zoning.
`
`Q. Okay.
`
`And showing exhibit 109 and I'm putting a portion
`
`of it, Pathlight SAN gateway solve these type of problems with
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`two levels of access control.
`
`The first method offered by SAN
`
`gateway is channel access control or zoning.
`
`Is that the
`
`other kind that question haven't talked about yet?
`
`A. Yesf
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`MR. BAHLER: Counselor, you just mentioned 109. Are
`
`you within Plaintiff's Exhibit 153?
`
`MR. ALCOCK: Exhibit 153 point 109 and at the end of
`
`your book are a handful of pages and in it is this included.
`
`MR. BAHLER:
`
`Thank you.
`
`MR. ALCOCK:
`
`Q} Let me take a look at page 110.
`
`Panels Pathlight's
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 624
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`06/11/2001 Trial, Day 3
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`channel access control inhibits devices from knowing that the
`
`storage channel exists, making it inaccessible.
`
`Do you agree
`
`with that statement?
`
`A. Yes.
`
`Q. And what test did you perform the confirm that in fact is
`
`the case?
`
`A.
`
`I reconfigured my test setup so that each of the computers
`
`was on a separate fiber channel port and I reconfigured the
`
`disk drives to have some of them on two different SCSI ports.
`
`Q. Okay. Let me show you exhibit 607. What is exhibit 607?
`
`A. This is a screen shot for the Pathlight SAN director
`
`again, channel zoning control, and the color is added.
`
`Q. And what are you doing here?
`
`A. What I'm doing here is setting up the access control for
`
`the channel zoning.
`
`Q. Okay. Let me show you exhibit 606. What does that show,
`
`sir?
`
`A. This shows a picture of how things are connected. This is
`
`again the Pathlight SAN director.
`
`They have an information
`
`screen that will show you this kind of thing.
`
`You can see
`
`that the —— in the upper section,
`
`the SCSI devices,
`
`there are
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`three devices connected to SCSI channel one and two connected
`
`to SCSI channel
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`two and that the two computers are connected
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`to two different Fibre Channels.
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`‘Q. And what is the right-hand of this thing show ——'I mean
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 625
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`06/11/2001 Trial, Day 3
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`the left-hand side of it show?
`
`A. That's what
`
`I was just talking about.
`
`Q. Oh,
`
`I'm sorry.
`
`So which are connected to which fiber a
`
`channel?
`
`A.
`
`The checkmarks in the previous graphic show that Fibre
`
`Channel one was connected to SCSI channel one and not to SCSI
`
`channel
`
`two.
`
`So you'll see the Fibre Channel one outlined in
`
`red here connected to SCSI channel one should be able to see
`
`only devices one,
`
`three and five which are connected to the
`
`SCSI for that channel.
`
`And the same —— similarly for fiber
`
`channel
`
`two.
`
`Q. Okay.
`
`So let me show you exhibit 608. What is that a
`
`screen shot of?
`
`A.
`
`Screen shot of the windows explore er showing what is
`
`available to the left computer.
`
`The left computer, you'll
`
`recall, was on fiber channel
`
`1 and was allowed access to SCSI
`
`kennel 1 which contained devices one,
`
`three and five,
`
`that is
`
`the red, blue and orange devices.
`
`Q; Okay. And let me show you exhibit 609. What is that
`
`depict?
`
`A. That is the right computer, windows explore er showing
`
`what's accessible to the right computer. Again, it was on --
`
`it was on fiber channel
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`two with access to SCSI channel
`
`two
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`and we see that SCSI channel
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`two had devices two and four,
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`purple and green.
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 626
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`06/11/2001 Trial, Day 3
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`Q.
`
`So is this channel zoning access controls?
`
`A. Yes, it is.
`
`Q. Does it perform the same function as the access controls
`
`in the claims?
`
`A.
`
`‘Yes, it does.
`
`Does it do it in a substantially the same way?
`
`Yes, it does.
`
`Does it achieve the same result?
`
`Yes, it does.
`
`Q. With respect to all the claim elements of all the claims,
`
`do they perform the same function as the claims -— with
`
`respect to all the functions we've talked about with the
`
`devices, are they performing the same function as in the
`
`claims?
`
`A. Yes,
`
`they are.
`
`Q.
`
`And do they do it in substantially the same way?
`
`A. Substantially the same way.
`
`Q. And does it achieve substantially the same result with
`
`respect to every claim element?
`
`A. Yes, it does.
`
`Q. And so do you determine every element of every claim being
`
`present in those devices?
`
`A. Yes,
`
`I did.
`
`Q.
`
`Then I think you better check that last box.
`
`A. which one did I leave off? Oh.
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 627
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`06/11/2001 Trial, Day 3
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`Q.
`
`Pass the witness, your Honor.
`
`CROSS-EXAMINATION
`
`BY MR. BAHLER:
`
`Q. Dr. Hodges, I'd like to talk to you for just a second,
`
`‘first of all, about this concept of access controls.
`
`It's a
`
`word that although you weren't here, Mr. Alcock wrote in big
`
`letters on a board that's right over there. And what is --
`
`does access control require any form of security in your
`
`A. Yes, it does.
`
`Q. Okay. What security's required?
`
`A. Similar to locally attached storage.
`
`Q. Okay. What does the security of -- or the security of
`
`locally attached storage means for example, at least in your
`
`opinion,
`
`that no other hosts can access that storage, right?
`
`A. Not exactly.
`
`Q. What is your idea of security with respect to local
`
`storage?
`
`A.
`
`No unauthorized host can have access to the storage.
`
`The
`
`security should be similar to what you would if you had
`
`something attached the a local compute.
`
`Q.
`
`So in your mind access control does not prohibit access to
`
`-storage devices by hosts that are prohibited from -- or that
`
`are —— that the access control intends to exclude?
`
`MR. ALCOCK: Objection, your Honor. Vague and
`
`ambiguous.
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 628
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`06/11/2001 Trial, Day 3
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`MR. BAHLER:
`
`I'll withdraw it.
`
`Q. There your opinion, access control is not —— does not
`
`prohibit other hosts from getting access?
`
`A.
`
`It does not prohibit unauthorized -- excuse me.
`
`It does
`
`not prohibit authorized hosts from getting access.
`
`Q. But does it prohibit unauthorized hosts from getting
`
`access?
`
`A. Yes.
`
`I
`
`Q. All right. Prohibit --
`
`A.
`
`To the degree that it would prohibit it with local
`
`storage.
`
`Q.
`
`I'd like to show you what's on the board as exhibit --
`
`this is Defendant's Exhibit 1. This is figure 3.
`
`Now,
`
`the
`
`thing in the Pathlight or I'm sorry,
`
`the Crossroads patent
`
`that governs access control is this thing called the
`
`management station, correct?
`
`A.
`
`No, sir.
`
`Q.- Well,
`
`the management station is required to —— well,
`
`the
`
`storage router ultimately accomplishes the function of access
`
`control, correct?
`
`A. Yes.
`
`Q. All right. And the settings in the storage router that
`
`accomplish that function are done by the management station,
`
`correct?
`
`A. Yes..
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`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 629
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`06l11I2001 Trial, Day 3
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`Q. All right.
`
`And the work stations don't make those
`
`settings, right?
`
`A. Work stations that do not have management capability or do
`
`not do that.
`
`Q. Right. Well,
`
`take a look at —— column 4 of the patent,
`
`right around line 33fl
`
`Do you see that, sir?
`
`A.
`
`I see what are you referring to?
`
`Q. Well, it talks about the management station 76 and that's
`
`the one that we were just looking at in figure 3, right?
`
`A. Yes.
`
`Q.
`
`It says the management station 76 can be connected
`
`directly to storage router 56 via connection, direct
`
`connection or can interface with the storage router 56 through
`
`either Fibre Channel 52 or SCSI bus 54.
`
`Do you see that?
`
`A.
`
`Can I read the rest of that paragraph, sir?
`
`Sure.‘ Do you have a copy-of the patent?
`
`Yes,
`
`I do. This is which column?
`
`Column 4,
`
`line 33..
`
`Column 4?
`
`Q. Column 4,
`
`line 33.
`
`A.
`
`I'm sorry. My copy is not very good.
`
`I was looking at
`
`line 23. Yes, sir.
`
`Q. All right.
`
`Just after that, it says in the latter case,
`
`and that is when the management station is connected to the,
`
`for example, Fibre Channel bus,
`
`the management-station can be
`
`02/22/2002 8:56 AM
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`Oracle Ex. 1024, pg. 630
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`
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`O6I11I2001 Trial, Day 3
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`a work station.
`
`Do you see that?
`
`A. Yes.
`
`Q. All right. Referring back to figure —— to your 3,
`
`that
`
`means this management station right here on figure 3 doesn't
`
`have to be connected right here, it doesn't have to be
`
`connected right here, but it can be connected directly to the
`
`SCSI bus, right?
`
`A. That's allowed --
`
`Q.' Right there,
`
`right?
`
`A. Yes.
`
`Q.
`
`And in that case; according to that section of column 4,
`
`it could be a work station, right?
`
`Just like all the other
`
`hosts on there,
`
`right?
`
`A. No, sir.
`
`Q.
`
`How is it different?
`
`A. »It's a management station that has special rights.
`
`Q. All right, sir. Could that management station be within
`
`one of the work stations that already exists?
`
`A.
`
`I don't know what that means.
`
`Q. Well, I've got a management station here that according to
`
`the patent can be a work station, right?
`
`A. Yes.
`
`Q. And then, I've got a whole bunch of work stations over
`
`here,
`
`too,
`
`right?
`
`A. Yeah.
`
`02/22/2002 8:56 AM
`
`Oracle Ex. 1024, pg. 631
`
`
`
`06I11I2001 Trial, Day 3
`
`Q. Well wouldn't it make sense rather than have a management
`
`station dedicated to or work station dedicated to the
`
`management station wouldn't it just make sense to put the
`
`management station, combine it with one of those work
`
`stations?
`
`A.
`
`You could do that.
`
`Q. You could actually put it in more than one work station,
`
`right?
`
`A. One could do that.
`
`Q.
`
`A.
`
`Q.
`
`You could put it in all work stations,
`
`right?v
`
`If you wanted to do that.
`
`And in that case, all hosts could get access, right?
`
`A. All hosts could -- would have the capability -- all hosts
`
`would be management stations.
`
`Q. Right.
`
`A.
`
`Q.
`
`You would have the capability of changing access.
`
`In that case -- all right. Now,
`
`if all hosts can get
`
`access to storage at any time, what kind of access control is
`
`it?
`
`A.
`
`It's controlled by the management station which has
`
`special rights.
`
`The management station itself has pass word
`
`protection for the administration so that only the authorized
`
`people can make the changes.
`
`Q. Well, --
`
`A.
`
`ItKs no different from having dedicated management
`
`02/22/2002 8:56 AM
`
`Oracle Ex. 1024, pg. 632
`
`
`
`06/11/2001 Trial, Day 3
`
`station.
`
`Q. Well,
`
`the hypothetical I've posed for you, Dr. Hodges, was
`
`that each and every work station, A, B, C, D and E has
`
`management functions. That means that each one of those work
`
`stations can adjust access control, right?
`
`A. Given the appropriate pass word by the administrator.
`
`Q.
`
`A.
`
`Is that a yes?
`
`The administrator could control access from any work
`
`stations.
`
`Q. Right. Okay.
`
`A.
`
`It does not mean that any work station will willy—nilly
`
`change it.
`
`Q. Well, if any work station can change access control and,
`
`therefore, permit that work station to gain access to the
`
`storage,
`
`then there is,
`
`in fact, no access control?
`
`A.
`
`I'm sorry.
`
`The work stations -- the control software in
`
`the work station can —— is what can change the access control
`
`and one can_choose to -— one can expect to have minimum --
`
`have special rights for an administrator.
`
`So an administrator
`
`can use any work station to change.
`
`Q. Well, I've just given you a hypothetical with the
`
`management function is in all work stations and so they all
`
`have special rights. That's a possibility, right?
`
`A. One could con figure it that way if one desired.
`
`Q. All right.
`
`"And-in that case, any work station can get
`
`02/22/2002 8:56 AM
`
`Oracle Ex. 1024, pg. 633
`
`
`
`06/11/2001 Trial, Day 3
`
`access to any storage at any time, right?
`
`A.
`
`If one chose not to provide the protection that is
`
`inherent in the patent, yes.
`
`Q. Well,
`
`the patent says that the management station can be
`
`connected to the Fibre Channel, right?
`
`A. One could choose not to provide any management —- any
`
`protection at all in one wanted to.
`
`Q. And that would be access control that would be covered by
`
`the patent in your opinion?
`
`A.
`
`The access control is provided by the device. That's if
`
`it's available.
`
`Q.
`
`Is the way that device —— by the device, you mean the
`
`storage router?
`
`A. Access control is provided by the storage router,
`
`the
`
`administration is available as desired by the administrator,
`
`and the function is there.
`
`Q. But —— okay. Let me make sure I have this right.
`
`The
`
`:management station just serves to set the configuration that's
`
`maintained by the router which ultimately accomplishes access
`
`control, right?
`
`A. Yes.
`
`Q.
`
`And there's nothing in the claims directed to the
`
`management station,
`
`is there? You didn't check any boxes
`
`anywhere that said management station, right?
`
`A. That's true.
`
`02/22/2002 8:56 AM
`
`Oracle Ex. 1024, pg. 634
`
`
`
`O6/11I2001 Trial, Day 3
`
`Management station isn't in that claim,
`
`is it?
`
`There's no —- those words are not used in the claim.
`
`Q. What is used in the claim is —— this is claim 1.
`
`A
`
`Yes.
`
`Q.
`
`It says to maintain a configuration for SCSI storage
`
`diseases connected to the SCSI bus transport medium, right?
`
`A. Yes.
`
`Q.
`
`So it's the maintenance of that configuration,
`
`that's
`
`what's required, right?
`
`A. That's what is required.
`
`Q.
`
`And that has nothing to do with how those -- that
`
`configuration is set by the management station, right?
`
`A. That's not addressed in the claim. And the function --
`
`what is addressed by the claims is the function that's
`
`provided by the router.
`Q. And,
`in fact,
`the claims don't say anything about how that
`
`configuration is set,
`
`right?
`
`A.f They do not.
`
`Q. Could be set by the SCSI reserve command, right?
`
`No.
`
`Why not?
`
`The SCSI reserve command being implemented according to
`
`SCSI specification is not sufficient access control.
`
`Why not?
`
`Because it does not provide the kind of access control
`
`02/22/2002 8:56 AM
`
`Oracle Ex. 1024, pg. 635
`
`
`
`06/11/2001 Trial, Day 3
`
`that is available for local storage.
`
`You do not have virtual
`
`local storage from that.
`
`Q. We'll get to that in just a second.
`
`I'm talking about
`
`access control right now, all right?
`
`A. Access control is illuminated by the virtual local
`
`storage.
`
`It tells you what kind of access control is
`
`required.
`
`Q. Well, actually virtual local storage in claim 1 appears up
`
`here at the top,
`
`right? Providing virtual local storage,
`
`right? And access controls's down here, right? Those are the
`
`same in your opinion?
`
`A. They're not
`
`the same, no, sir.
`
`Q. Well,
`
`so in your opinion,
`
`a device that's configured like
`
`that shown in figure 3 that uses the SCSI reserve command to
`
`set that configuration,
`
`that performs access control in your"
`
`opinion, right?
`
`A. No, sir.
`
`Q. Okay. Why not?
`
`A.
`
`It does not meet the requirements for virtual local
`
`storage.
`
`Q. No, no, no.
`
`It doesn't meet the requirements for access
`
`control?
`
`A. No, sir.
`
`Q.
`
`So they're the same,
`
`the requirements are the same or are
`
`they different, Dr. Hodges?
`
`02/22/2002 8:56 AM
`
`Oracle Ex. 1024, pg. 636
`
`
`
`O6I11I2001 Trial, Day 3
`
`A. Which requirement?
`
`Q. Requirement for virtual local storage on the one hand and
`
`access control on the other hand?
`
`A. Virtual local storage describes what is expected of the
`
`storage device and illuminates what kinds ever access control
`
`is require.
`
`Q. All right. One of the reasons is because any host
`
`connected to the storage router when the configuration has
`
`been set up using this reserve command, any of those hosts can
`
`change access at any time, right?
`
`A. That's true.
`
`Q. Dr. Hodges,
`
`I just posed for you a hypothetical a second
`
`ago where all of the work stations have management capability,
`
`all of them can set access, and you said that that was access
`
`controls still?
`
`A.
`
`The access control function in previous case was present
`
`in the router. That's what the patent is about, what is
`
`present in the router.
`
`Q. Right. Reserve and release do not provide within the
`
`router the capability for doing the same kind of access
`
`control. Reserve and release. Well, let's forget about
`
`release, let's talk about reserve,
`
`reserve makes settings in
`
`that router, correct?
`
`A.
`
`Its could.
`
`Q.
`
`It changes modifiable set information the router, within
`
`02/22/2002 8:56 AM
`
`Oracle Ex. 1024, pg. 637
`
`
`
`0611112001 Trial, Day 3
`
`the router, right?
`
`A.
`
`Its could.
`
`Q.
`
`It could, it does,
`
`that's the way its works, right?
`
`MR. ALCOCK: Objection, your Honor. Beyond the scope
`
`of redirect. Reserve release is part of their invalidity
`
`case.
`
`THE COURT:
`
`The objection's overruled.
`
`MR. BAHLER: Thank you, your Honor.
`(BY MR. BAHLER)
`Do you need the question again, sir?
`
`Q.
`
`A.
`
`I'm not aware there was a question.
`
`Please repeat it.
`
`Q. Let me withdraw it in case there is one. Dr. Hodges,
`
`the
`
`claim requires this maintaining a configuration as we said,
`
`right?
`
`A. Yes.
`
`Q. Doesn't require it be set by anything, and indeed, a SCSI
`
`reserve command will make -— will change that configuration in
`
`a storage router, correct? Can be used that way, right?
`
`A.
`
`It could.
`
`Q. Could. And when it makes that change,
`
`requests by
`
`subsequent -- by other work stations will be prohibited from
`
`accessing storage that is reserved, right?
`
`A. No, sir.
`
`Q. Well,
`
`is one of the reasons because those other work
`
`stations can issue a reset?
`
`A. According to the SCSI command, according to the SCSI
`
`02/22/2002 8:56 AM
`
`Oracle Ex. 1024, pg. 638
`
`
`
`06I11I20D1 Trial, Day 3
`
`standard, any of those work stations could revoke the reserve
`
`at any time. Therefore,
`
`the capability for prohibiting access
`
`does not exist within the router if you use SCSI reserve.
`
`Q.
`
`If the capability exists to override,
`
`then there is no
`
`access control.
`
`Is that what you just said?
`
`A.
`
`If the capability -- if the access control inherently has
`
`the capability to be overridden by any work station without
`
`any further authority,
`
`that is not access control.
`
`Q. All right.
`
`So if any work station can override the access
`
`controls,
`
`then there is no access control?
`
`A. That's not what
`
`I said.
`
`Q. All right.
`
`I couldn't understand completely and I
`
`apologize. Maybe I'm thick this morning.
`
`MR. ALCOCK: Your Honor, move to strike. That's not
`
`Vappropriate.
`
`THE COURT: Counsel, let's just calm down.
`
`Q.
`
`(BY MR. BAHLER) Could you explain that again, please?
`
`A. What would you like for me to explain?
`
`Q.
`
`The part about where any -- well, let me just start down
`
`the same track, only differently. These work stations shown
`
`in figure 3 could be configured to issue reserve commands,
`
`right? Any one?
`
`A.
`
`SCSI reserve commands?
`
`Q. Yes, sir.
`
`A. Yes,
`
`they could.
`
`02/22/2002 8:56 AM
`
`Oracle Ex. 1024, pg. 639
`
`
`
`06/11/2001 Trial, Day 3
`
`Q. And if the router were so programmed, work station A could
`
`reserve for itself storage A and storage B and work station B
`
`could reserve storage B, et cetera.
`
`In other words,
`
`this
`
`exact configuration shown in figure 3 could be established
`
`using the SCSI reserve commands, correct?
`
`A.
`
`The configuration as described in the patent would not be
`
`the same.
`
`Q. Well, work station A could issue a reserve command and it
`
`would be stored in the storage router and it would reserve for
`
`work station A, work station A storage on storage device 62,
`
`right?
`
`A. That is not access control.
`
`Q. Well, let's say that no other hosts issue a reset or do
`
`anything unusual, all right?
`
`A.
`
`I'm willing to do that because that's part of the SCSI
`
`standard.
`
`Q. Well, let's say that none of them have done it yet.
`
`A.
`
`If none of them have done it yet,
`
`then nothing has
`
`happened.
`
`Q. All right. Well, let's say none of them have issued a
`
`reset and that setting is sitting there in the storage router,
`
`the setting that was made by work station A, all right?
`
`A. Whatever setting that was.
`
`Q. All right.
`
`Now,
`
`if work station B tries to get access to
`
`the storage of work station A, it will be rejected by that’
`
`02/22/2002 8:56 AM
`
`Oracle Ex. 1024, pg. 640
`
`
`
`06/11/2001. Trial, Day 3
`
`storage router, correct?
`
`A. No, sir.
`
`Q. Why not?
`
`A. This is no different from encountering a locked door that
`
`you have a key to it. Doesn't keep you from getting it, it
`
`only delays you.
`
`Q.
`
`A.
`
`Isn't that the same as a pass word?
`
`The same as pass word?
`
`Q. Yeah, before we talked about the management station
`
`according to the patent could be actually exist on all of
`
`those work stations.
`
`A. Yes, sir.
`
`Q. All those could have management functions, right? That's
`
`what you said before, right?
`
`A.
`
`In this case, everybody has a key.
`
`By definition in the
`
`case of reserve release. There's no capability in the storage
`
`router to prevent any work station regardless of how it's
`
`programmed as long as issues a command according to the SCSI
`
`protocol to prevent another work station from getting to that
`
`storage.
`
`Q. All right.
`
`So in a —— if -— well,
`
`the SCSI reserve every
`
`work station has a key, right,
`
`in your opinion?
`
`A.
`
`By definition.
`
`Q. All right. And in the management, every -- in the
`
`management station, where the management function distributed.
`
`02/22/2002 8:56 AM
`
`Oracle Ex. 1024, pg. 641
`
`
`
`06/11/2001 Trial, Day 3
`
`across all those work stations, everybody would have a pass
`
`word, wouldn't they?
`
`A.
`
`The capability is there in the latter case for the storage
`
`router to create whatever access control is desired by the
`
`person who sets this up.
`
`The capability is just there for
`
`access control with reserve the capability is not there.
`
`Q. All right.
`
`Now,
`
`this management function that's performed
`
`by the —— that you say is performed by the SAN gateway and SAN
`
`router products, Pathlight products, that's done by this SAN
`
`director?
`
`A.
`
`Q.
`
`I'm sorry. Would you repeat that?
`
`The management function that you have concluded exists in
`
`the SAN gateway and SAN router products,
`
`is that done by the
`
`SAN director software?
`
`A. That's one way of doing it.
`
`Q. Are there any other ways of doing it?
`
`A. Yes, one can connect by the service port and use a
`
`different protocol for doing the same functions.
`
`Q. That would still be using the SAN director, right?
`
`A. No, sir.
`
`Q.
`
`How would that be?
`
`A.
`
`It's using hyper terminal that's built into the windows
`
`system.
`
`It does not use the SAN director at all.
`
`Q. All right. And would that be access control?v
`
`A» That gives the same-function.
`
`02/22/2002 8:56 AM
`
`Oracle Ex. 1024, pg. 642
`
`
`
`06/11/2001 Trial, Day 3
`
`Q. Okay.
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