Case 1:13-cv-00895-SS Document 1 Filed 10/07/13 Page 1 of 11
`
`N THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`FILE
`
`2913 OCT -7 PM 2:52
`
`c/ETE,
`
`CROSSROADS SYSTEMS, INC.,
`
`Plaintiff,
`
`V.
`
`ORACLE CORPORATION,
`
`Defendant.
`
`CIVIL ACTION NO.
`
`JURY DEMANDED
`
`A13CV0895 ss
`
`PLAINTIFF CROSSROADS SYSTEMS, INC.'S
`COMPLAINT FOR PATENT INFRINGEMENT
`
`THE PARTIES
`
`1.
`
`Plaintiff Crossroads Systems, Inc. ("Crossroads") is a corporation incorporated
`
`under the laws of the State of Delaware and has its principal place of business at 11000 North
`
`MoPac Expressway, Austin, Texas 78759.
`
`2.
`
`Upon information and belief, Defendant Oracle Corporation ("Defendant") is a
`
`Delaware corporation with a principal place of business of 500 Oracle Parkway, Redwood City,
`
`CA 94065.
`
`JURISDICTION AND VENUE
`
`3.
`
`This action arises under the laws of the United States, more specifically under 35
`
`U.S.C. § 100, et seq. Subject matter jurisdiction is proper in this Court pursuant to 28 U.S.C. §
`
`1331 and 1338.
`
`4.
`
`Personal jurisdiction and venue are proper in this district under 28 U.S.C. § 1391
`
`and 1400(b). Upon information and belief, Defendant Oracle has established minimum contacts
`
`with this forum such that tle exercise of jurisdiction over Defendant woutd not offend traditional
`
`notions of fair play and sulstantial justice.
`
`1
`
`Oracle Ex. 1034, pg. 1
`
`

`
`Case 1:13-cv-00895-SS Document 1 Filed 10/07/13 Page 2 of 11
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`5.
`
`This Court has personal jurisdiction over Oracle. Upon information and belief,
`
`Oracle regularly conducts business in the State of Texas and in this judicial district and is subject
`
`to the jurisdiction of this Court. Upon information and belief, Oracle has been doing business in
`
`Texas and this judicial district by distributing, marketing, selling and/or offering for sale its
`
`products, including, but not limited to, products that practice the subject matter claimed in the
`
`Patents-In-Suit, and/or regilarly doing or soliciting business and/or engaging in other persistent
`
`courses of conduct in and/dr directed to Texas and this judicial district.
`
`COUNT 1: INFRINGEMENT OF U.S. PATENT NO. 6425,O35
`
`6.
`
`Crossroads incorporates by reference the allegations set forth in the preceding
`
`paragraphs.
`
`7.
`
`On July 23, 2002, United States Patent No. 6,425,035 (the "035 Patent") was
`
`duly and legally issued. A true and correct copy of the '035 Patent is attached hereto as Exhibit
`
`A. Crossroads is the assignee and the owner of all right, title, and interest in and to the '035
`
`Patent. The '035 Patent is entitled to a presumption of validity.
`
`8.
`
`On information and belief, Defendant has directly infringed the '035 Patent. On
`
`information and belief, Defendant continues to directly infringe the '035 Patent.
`
`9.
`
`Specifically, on information and belief, Defendant has directly infringed the '035
`
`Patent by making, using, offering for sale, selling and/or importing into the United States certain
`
`of its products including at least the following: Sun ZFS Storage 7120 Appliance, Sun ZFS
`
`Storage 7320 Appliance, Sun ZFS Storage 7420 Appliance, Oracle Servers with Solaris with
`
`SCSI Target Mode Framework, Pillar Axiom 300 with Fibre Channel SAN Slammer, Pillar
`
`Axiom 300 with iSCSI SAN Slammer, Pillar Axiom 300 with Combination FC1iSCSI SAN
`
`Slammer, Pillar Axiom 600 with Fibre Channel SAN Slammer, Pillar Axiom 600 with iSCSI
`
`2
`
`Oracle Ex. 1034, pg. 2
`
`

`
`Case 1:13-cv-00895-SS Document 1 Filed 10/07/13 Page 3 of 11
`
`SAN Slammer, Pillar Axiom 600 with Combination FC/iSCSI SAN Slammer, and Oracle Sun
`
`Storage 2540-M2 Array.
`
`10.
`
`Further, on information and belief, Defendant has been and now is indirectly
`
`infringing by way of inducing infringement of the '035 Patent with knowledge of the '035 Patent
`
`by making, offering for sale, selling, importing into the United States, marketing, supporting,
`
`providing product instruction and/or advertising certain of its products, including the Sun ZFS
`
`Storage 7120 Appliance, Sun ZFS Storage 7320 Appliance, Sun ZFS Storage 7420 Appliance,
`
`Oracle Servers with Solaris with SCSI Target Mode Framework, Oracle Solaris with SCSI
`
`Target Mode Framework, Pillar Axiom 300 with Fibre Channel SAN Slammer, Pillar Axiom
`
`300 with iSCSI SAN Slammer, Pillar Axiom 300 with Combination FC/iSCSI SAN Slammer,
`
`Pillar Axiom 600 with Fibre Channel SAN Slammer, Pillar Axiom 600 with iSCSI SAN
`
`Slammer, Pillar Axiom 600 with Combination FC/iSCSI SAN Slammer, and Oracle Sun Storage
`
`2540-M2 Array, and Defendant knew that its actions were inducing end users to infringe the
`
`'035 Patent.
`
`11.
`
`Further, on information and belief, Defendant has been and now is indirectly
`
`infringing by way of contributing to the infringement by end users of the '035 Patent by selling,
`
`offering to sell and/or importing into the United States components, including the Sun ZFS
`
`Storage 7120 Appliance, Sun ZFS Storage 7320 Appliance, Sun ZFS Storage 7420 Appliance,
`
`Oracle Servers with Solaris with SCSI Target Mode Framework, Oracle Solaris with SCSI
`
`Target Mode Framework, Pillar Axiom 300 with Fibre Channel SAN Slammer, Pillar Axiom
`
`300 with iSCSI SAN Slammer, Pillar Axiom 300 with Combination FC/iSCSI SAN Slammer,
`
`Pillar Axiom 600 with Fibre Channel SAN Slammer, Pillar Axiom 600 with iSCSI SAN
`
`Slammer, Pillar Axiom 600 with Combination FC/iSCSI SAN Slammer, and Oracle Sun Storage
`
`3
`
`Oracle Ex. 1034, pg. 3
`
`

`
`Case 1:13-cv-00895-SS Document 1 Filed 10/07/13 Page 4 of 11
`
`2540-M2 Array, knowing the components to be especially made or especially adapted for use in
`
`the infringement of the '035 Patent. Such components are not a staple article or commodity of
`
`commerce suitable for substantial non-infringing uses.
`
`12.
`
`Defendant has been on constructive and/or actual notice of the '035 Patent since
`
`at least as early as November 2009, and Defendant has not ceased its infringing activities. The
`
`infringement of the '035 Patent by Defendant has been and continues to be willful and deliberate.
`
`13.
`
`Crossroads has been irreparably harmed by Defendant's acts of infringement of
`
`the '035 Patent, and will continue to be harmed unless and until Defendant's acts of infringement
`
`are enjoined and restrained by order of this Court.
`
`14.
`
`As a result of the acts of infringement of the '035 Patent by Defendant,
`
`Crossroads has suffered and will continue to suffer damages in an amount to be proven at trial.
`
`COUNT 2: INFRINGEMENT OF U.S. PATENT NO. 7,934,041
`
`15.
`
`Crossroads incorporates by reference the allegations set forth in the preceding
`
`paragraphs.
`
`16.
`
`On April 26, 2011, United States Patent No. 7,934,041 (the "041 Patent") was
`
`duly and legally issued. A true and correct copy of the '041 Patent is attached hereto as Exhibit
`
`B. Crossroads is the assignee and the owner of all right, title, and interest in and to the '041
`
`Patent. The '041 Patent is entitled to a presumption of validity.
`
`17.
`
`On information and belief, Defendant has directly infringed the '041 Patent. On
`
`information and belief, Defendant continues to directly infringe the '041 Patent.
`
`18.
`
`Specifically, on information and belief, Defendant has directly infringed the '041
`
`Patent by making, using, offering for sale, selling and/or importing into the United States certain
`
`of its products including at least the following: Sun ZFS Storage 7120 Appliance, Sun ZFS
`
`Oracle Ex. 1034, pg. 4
`
`

`
`Case 1:13-cv-00895-SS Document 1 Filed 10/07/13 Page 5 of 11
`
`Storage 7320 Appliance, Sun ZFS Storage 7420 Appliance, Oracle Servers with Solaris with
`
`SCSI Target Mode Framework, Pillar Axiom 300 with Fibre Channel SAN Slammer, Pillar
`
`Axiom 300 with iSCSI SAN Slammer, Pillar Axiom 300 with Combination FC/iSCSI SAN
`
`Slammer, Pillar Axiom 600 with Fibre Channel SAN Slammer, Pillar Axiom 600 with iSCSI
`
`SAN Slammer, Pillar Axiom 600 with Combination FC/iSCSI SAN Slammer, and Oracle Sun
`
`Storage 2540-M2 Array.
`
`19.
`
`Further, upøn information and belief, Defendant has been and now is indirectly
`
`infringing by way of inducing infringement of the '041 Patent with knowledge of the '041 Patent
`
`by making, offering for sale, selling, importing into the United States, marketing, supporting,
`
`providing product instruction and/or advertising certain of its products, including the Sun ZFS
`
`Storage 7120 Appliance, Skin ZFS Storage 7320 Appliance, Sun ZFS Storage 7420 Appliance,
`
`Oracle Servers with Solaris with SCSI Target Mode Framework, Oracle Solaris with SCSI
`
`Target Mode Framework, Pillar Axiom 300 with Fibre Channel SAN Slammer, Pillar Axiom
`
`300 with iSCSI SAN Slammer, Pillar Axiom 300 with Combination FC/iSCSI SAN Slammer,
`
`Pillar Axiom 600 with Fibre Channel SAN Slammer, Pillar Axiom 600 with iSCSI SAN
`
`Slammer, Pillar Axiom 600 with Combination FC/iSCSI SAN Slammer, and Oracle Sun Storage
`
`2540-M2 Array, and Defendant knew that its actions were inducing end users to infringe the
`
`'041 Patent.
`
`20.
`
`Further, upon information and belief, Defendant has been and now is indirectly
`
`infringing by way of contributing to the infringement by end users of the '041 Patent by selling,
`
`offering to sell and/or importing into the United States components, including the Sun ZFS
`
`Storage 7120 Appliance, Sun ZFS Storage 7320 Appliance, Sun ZFS Storage 7420 Appliance,
`
`Oracle Servers with Solaris with SCSI Target Mode Framework, Oracle Solaris with SCSI
`
`Iii
`
`Oracle Ex. 1034, pg. 5
`
`

`
`Case 1:13-cv-00895-SS Document 1 Filed 10/07/13 Page 6 of 11
`
`Target Mode Framework, Pillar Axiom 300 with Fibre Channel SAN Slammer, Pillar Axiom
`
`300 with iSCSI SAN Slammer, Pillar Axiom 300 with Combination FC/iSCSI SAN Slammer,
`
`Pillar Axiom 600 with Fibre Channel SAN Slammer, Pillar Axiom 600 with iSCSI SAN
`
`Slammer, Pillar Axiom 600 with Combination FC/iSCSI SAN Slammer, and Oracle Sun Storage
`
`2540-M2 Array, knowing the components to be especially made or especially adapted for use in
`
`the infringement of the '041 Patent. Such components are not a staple article or commodity of
`
`commerce suitable for substantial non-infringing uses.
`
`21.
`
`Defendant has been on constructive and/or actual notice of the '041 Patent since
`
`at least as early as May 2011, and Defendant has not ceased its infringing activities. The
`
`infringement of the '041 Patent by Defendant has been and continues to be willful and deliberate.
`
`22.
`
`Crossroads has been irreparably harmed by Defendant's acts of infringement of
`
`the '041 Patent, and will continue to be harmed unless and until Defendant's acts of infringement
`
`are enjoined and restrained by order of this Court.
`
`23.
`
`As a result of the acts of infringement of the '041 Patent by Defendant,
`
`Crossroads has suffered and will continue to suffer damages in an amount to be proven at trial.
`
`COUNT 3: INFRINGEMENT OF U.S. PATENT NO. 7,05L147
`
`24.
`
`Crossroads incorporates by reference the allegations set forth in the preceding
`
`paragraphs.
`
`25.
`
`On May 23, 2006, United States Patent No. 7,051,147 (the "147 Patent") was
`
`duly and legally issued. A true and correct copy of the '147 Patent is attached hereto as Exhibit
`
`C. Crossroads is the assignee and the owner of all right, title, and interest in and to the '147
`
`Patent. The '147 Patent is entitled to a presumption of validity.
`
`Oracle Ex. 1034, pg. 6
`
`

`
`Case 1:13-cv-00895-SS Document 1 Filed 10/07/13 Page 7 of 11
`
`26.
`
`On information and belief, Defendant has directly infringed the '147 Patent. On
`
`information and belief, Defendant continues to directly infringe the '147 Patent.
`
`27.
`
`Specifically, on information and belief, Defendant has directly infringed the '147
`
`Patent by making, using, offering for sale, selling and/or importing into the United States certain
`
`of its products including at least the following: Pillar Axiom 300 with Fibre Channel SAN
`
`Slammer, Pillar Axiom 300 with Combination FC/iSCSI SAN Slammer, Pillar Axiom 600 with
`
`Fibre Channel SAN Slammer, and the Pillar Axiom 600 with Combination FC/iSCSJ SAN
`
`Slammer.
`
`28.
`
`Further, on information and belief, Defendant has been and now is indirectly
`
`infringing by way of inducing infringement of the '147 Patent with knowledge of the '147 Patent
`
`by making, offering for sale, selling, importing into the United States, marketing, supporting,
`
`providing product instruction and/or advertising certain of its products, including the Pillar
`
`Axiom 300 with Fibre Channel SAN Slammer, Pillar Axiom 300 with Combination FC/iSCSI
`
`SAN Slammer, Pillar Axiom 600 with Fibre Channel SAN Slammer, and the Pillar Axiom 600
`
`with Combination FC/iSCSI SAN Slammer, and Defendant knew that its actions were inducing
`
`end users to infringe the '147 Patent.
`
`29.
`
`Further, on information and belief, Defendant has been and now is indirectly
`
`infringing by way of contributing to the infringement by end users of the '147 Patent by selling,
`
`offering to sell and/or importing into the United States components, including the Pillar Axiom
`
`300 with Fibre Channel SAN Slammer, Pillar Axiom 300 with Combination FC/iSCSJ SAN
`
`Slammer, Pillar Axiom 600 with Fibre Channel SAN Slammer, and the Pillar Axiom 600 with
`
`Combination FC/iSCSI SAN Slammer, knowing the components to be especially made or
`
`7
`
`Oracle Ex. 1034, pg. 7
`
`

`
`Case 1:13-cv-00895-SS Document 1 Filed 10/07/13 Page 8 of 11
`
`especially adapted for use in the infringement of the '147 Patent. Such components are not a
`
`staple article or commodity of commerce suitable for substantial non-infringing uses.
`
`30.
`
`Defendant has been on constructive and/or actual notice of the '147 Patent since
`
`at least as early as November 2009, and Defendant has not ceased its infringing activities. The
`
`infringement of the '147 Patent by Defendant has been and continues to be willful and deliberate.
`
`31.
`
`Crossroads has been irreparably harmed by Defendant's acts of infringement of
`
`the '147 Patent, and will continue to be harmed unless and until Defendant's acts of infringement
`
`are enjoined and restrained by order of this Court.
`
`32.
`
`As a result of the acts of infringement of the '147 Patent by Defendant,
`
`Crossroads has suffered and will continue to suffer damages in an amount to be proven at trial.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Crossroads requests this Court enter judgment as follows:
`
`A.
`
`B.
`
`C.
`
`That Defendant has infringed the '035 Patent;
`
`That such infringement of the '035 Patent by Defendant has been willful;
`
`That Defendant accounts for and pays to Crossroads all damages caused
`
`by the infringement of the '035 Patent;
`
`D.
`
`That Crossroads receive enhanced damages from Defendant in the form of
`
`treble damages, pursuant to 35 U.S.C. § 284 based on Defendant's willful
`
`infringement of the '035 Patent;
`
`E.
`
`That Crossroads be granted pre-judgment and post-judgment interest on
`
`the damages caused to it by reason of Defendant's infringement of the
`
`'035 Patent, including pre-judgment and post-judgment interest on any
`
`enhanced damages or attorneys' fees award;
`
`[4]
`[4]
`
`Oracle Ex. 1034, pg. 8
`
`

`
`Case 1:13-cv-00895-SS Document 1 Filed 10/07/13 Page 9 of 11
`
`F.
`
`G.
`
`H.
`
`That Defendant has infringed the '041 Patent;
`
`That such infringement of the '041 Patent by Defendant has been willful;
`
`That Defendant accounts for and pays to Crossroads all damages caused
`
`by the infringement of the '041 Patent;
`
`I.
`
`That Crossroads receive enhanced damages from Defendant in the form of
`
`treble damages, pursuant to 35 U.S.C. § 284 based on Defendant's willful
`
`infringement of the '041 Patent;
`
`J.
`
`That Crossroads be granted pre-judgment and post-judgment interest on
`
`the damages caused to it by reason of Defendant's infringement of the
`
`'041 Patent, including pre-judgment and post-judgment interest on any
`
`enhanced damages or attorneys' fees award;
`
`That Defendant has infringed the '147 Patent;
`
`That such infringement of the '147 Patent by Defendant has been willful;
`
`K.
`
`L.
`
`M.
`
`That Defendant accounts for and pays to Crossroads all damages caused
`
`by the infringement of the '147 Patent;
`
`N.
`
`That Crossroads receive enhanced damages from Defendant in the form of
`
`treble damages, pursuant to 35 U.S.C. § 284 based on Defendant's willful
`
`infringement of the '147 Patent;
`
`0.
`
`That Crossroads be granted pre-judgment and post-judgment interest on
`
`the damages caused to it by reason of Defendant's infringement of the
`
`'147 Patent, including pre-judgment and post-judgment interest on any
`
`enhanced damages or attorneys' fees award;
`
`Oracle Ex. 1034, pg. 9
`
`

`
`Case 1:13-cv-00895-SS Document 1 Filed 10/07/13 Page 10 of 11
`
`P.
`
`That Defendant pay Crossroads all of Crossroads' reasonable attorneys'
`
`Q.
`
`R.
`
`fees and expenses;
`
`That costs be awarded to Crossroads;
`
`That Defendant, its agents, employees, representatives, successors and
`
`assigns, and those acting in privity or in concert with it, be preliminary
`
`and permanently enjoined from further infringement of the '035 Patent;
`
`S.
`
`That Defendant, its agents, employees, representatives, successors and
`
`assigns, and those acting in privity or in concert with it, be preliminary
`
`and permanently enjoined from further infringement of the '041 Patent;
`
`T.
`
`That Defendant, its agents, employees, representatives, successors and
`
`assigns, and those acting in privity or in concert with it, be preliminary
`
`and permanently enjoined from further infringement of the '147 Patent;
`
`U.
`
`V.
`
`That this is an exceptional case under 35 U.S.C. § 285; and
`
`That Crossroads be granted such other and further relief as the Court may
`
`deem just and proper under the circumstances.
`
`DEMAND FOR JURY TRIAL
`
`Crossroads hereby demands a trial by jury on all issues.
`
`10
`
`Oracle Ex. 1034, pg. 10
`
`

`
`Case 1:13-cv-00895-SS Document 1 Filed 10/07/13 Page 11 of 11
`
`Dated: October 7, 2013
`
`Respectfully submitted,
`
`By:____________
`
`Steven prrnkle
`Texas Bar No. 00794962
`Elizabeth J. Brown Fore
`Texas Bar No. 24001795
`Sprinkle IP Law Group, PC
`1301 W. 25th Street, Siiiite 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 R. Wong
`Texas Bar No. 21884235
`James H. Hall
`Texas Bar No. 24041040
`WONG, CABELLO, LUTSCH,
`RUTHERFORD & BRUCCULERI, L.L.P.
`20333 SH 249, Suite 600
`Houston, TX 77070
`Tel: 832-446-2400
`Fax: 832-446-2424
`skno11@counse1ip.con-
`rwongcounselip.con
`jha11counse1ip.com
`
`ATTORNEYS FOR PLAINTIFF
`CROSSROADS SYSTEMS, INC.
`
`11
`
`Oracle Ex. 1034, pg. 11
`
`

`
`Case 1:13-cv-00895-SS Document 1-1 Filed 10/07/13 Page 1 of 15
`
`EXHIBIT A
`
`Oracle Ex. 1034, pg. 12
`
`

`
`Case 1:13-cv-00895-SS Document 1-1 Filed 10/07/13 Page 2 of 15
`
`(12) United States Patent
`Hoese et al.
`
`11111 11111111 III 11111 11111 11111 11111 11111 11111 11111 11111 111111 liii 11111111
`US006425035B2
`
`(10) Patent No.:
`(45) Date of Patent:
`
`US 6,425,035 B2
`*Jtjl. 23, 2002
`
`(54) STORAGE ROUTER AND M*THOD FOR
`PROVIDING VIRTUAL LOCAL STORAGE
`
`(75)
`
`Inventors: Geoffrey B. Hoese, Austin; Jeifry T.
`Russell, Cibolo, both of TX (US)
`
`(73) Assignee: Crossroads Systems, Inc., Austin, TX
`(US)
`
`(4') Notice:
`
`Subject to aiiy disc1airier, the term of this
`patent is extended or adjusted under 35
`U.S.C. 154(b) by 0 dys.
`
`This patent is subject to a terminal dis-
`claimer.
`
`(21) AppI. No.: 09/965,335
`Sep. 27, 2001
`
`(22) Filed:
`
`Related US. ApplIcation Data
`
`(63) Continuation of application No. 09/354,682, filed on Jul. 15,
`1999, which is a continuation of apptiction No. 091001,799,
`filed on Dec. 31, 1997, now Pat. No. 5,941,972.
`(51) hit. CL7 ................................................ GO6F 13/00
`(52) U.S. CI ............................ 710/129; 710/128; 710/8;
`710/36; 710/105
`(58) FIeld of Search ............................... 710/1-5, 8-13,
`710/36-38, 105, 100-101, 126-131; 711/100,
`112, 113; 714/42
`
`(56)
`
`References Cited
`U.S. PATErr DOCUMENTS
`5,748,924 A * 5/1998 Llorens et at .............. 710/129
`5,768,623 A 6/1998 Judd at a! ..................... 710/37
`5,809,328 A 9/1998 Nogates et al ................. 710/5
`5,812,754 A 4' 9/1998 Liii et al ........................ 71.4/6
`5,835,496 A * 11/1998 Ycung et at ................ 370/514
`5,848,251 A 12/1998 Lomelino eta! ............ 710/129
`
`5,935,260 A * 8/1999 Ofer ............
`714/42
`5,941,972 A * 8/1999 Hoese at at ................. 710/129
`5,959,994 A * 9/1999 Bo5gs Ct a! ................ 370/399
`6,041,381 A * 3/2000 Hoese ........................ 710/129
`6,055,603 A '
`4/2000 01cr et a! ................... 711/113
`6,065,087 A " 5/2000 Keaveny et at ............. 710/129
`6075,863 A * 6(2000 Krishnan at aL ............. 380/49
`6,098,149 A 4'
`8/2000 01cr et al ................... 711/112
`6,118,766 A * 9/2000 Akera ......................... 310/249
`6,148,004 A * 11/2000 Nelson et at ............... 370/463
`2/2001 Berman ...................... 370/351
`6,185,203 BI.
`6,209,023 BI 4' 3/2001 Dimitroff et at ............ 709/211
`6,230,218 131 4' 5/2001 Caspers et a! ................ 710/20
`1/2002 Arroyo at at ............... 709/230
`6,341,315 131
`1/2002 Hubis et al ................. 709/229
`6,343,324 Bi 4'
`
`* cited by examiner
`
`Primary ExaminerChristopher B. Shin
`(74) Attorney, Agent, or FirmGray Cary Ware &
`Fnedrich LLP
`
`(57)
`
`ABSTRACT
`A storage router (56) and storage network (50) provide
`virtual local storage on remote SCSI storage devices (60, 62,
`64) to Fiber Channel devices. A plurality of F'iber Channe!
`devices, such as workstations (58), are connected to a Fiber
`Channel transport medium (52), and a plurality of SCSI
`storage devices (60, 62, 64) arc connected to a SCSI bus
`transport medium (54). The storage routet (56) interfaces
`between the Fibre Channel transport medians (52) and the
`SCSI bus transport medium (54). The storage router (56)
`maps between the workstations (58) and the SCSI storage
`devices (60, 62, 64) and implements access controls for
`stnrage space on the SCSI storage devices (60, 62, 64). The
`storage muter (56) then allows access from the workstations
`(58) to the SCSI Storage devices (60, 62, 4) using native
`low level, bln& protocol in accn dance with the mapping
`and the access controls.
`
`14 ClaIms, 2 DrawIng Sheets
`
`58
`
`58
`
`58
`
`WORKSTATION WORKSTATION WORKSTATION
`A
`B
`C
`
`STORAGE DEVICE
`PLOBAI.
`DATA
`
`I
`
`STORAGE
`ROUTER
`
`scsi
`BUS
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`CIIANNEL
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`WORKSTATION I WORKSTATION L I MANAGEMENT
`1 STATION
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`p.
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`l--"----.----'-1 1
`STOR.ACE DEVICE
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`I
`
`STORAGE DEVICE
`
`WORKSTATION
`A STORAGE
`
`WORKSTATION
`U STORAGE
`
`WORKSTATION
`C STORAGE
`
`WORKSTATION
`
`D STORAGE
`
`66
`
`68
`
`70
`
`72
`
`64 -'I [lRKsTATloN
`I F STORAGE
`I
`
`74
`
`Oracle Ex. 1034, pg. 13
`
`

`
`Case 1:13-cv-00895-SS Document 1-1 Filed 10/07/13 Page 3 of 15
`
`U.S. Patent
`
`Jul. 23, 2002
`
`Sheet 1 of 2
`
`US 6,425,035 B2
`
`12
`
`12
`
`12
`()
`
`10
`
`WORKSTATION I
`
`I WORKSTAT1O1
`
`TWORKSTATION I
`
`WORKSTAT10] NETWORK SERVER
`
`SCSI BUS
`
`16
`
`12
`
`20
`
`DISK
`
`FIG. I
`
`18
`
`36
`
`38
`
`36
`
`WORKSTATION
`
`rwaRKsTATIoN I
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`(MANAGEMENT [-46
`STATION
`
`STORAGE Jçsi BUS
`ROUTER
`
`42
`
`LJ
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`E}
`
`38
`
`FIG. 2
`
`WORKSTATFOj
`
`30
`
`40
`
`42
`
`FIBRE CHANNEL
`
`[KSTAT10N
`
`1
`
`36
`
`58
`
`58
`
`58
`
`60
`
`I STORAGE DEVICE I
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`
`62
`
`WORKSTATION WORKSTATION
`A
`B
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`IWORKSTATION I
`156
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`
`FIBRE
`CHANNEL
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`1
`
`52 I
`
`I STORAGE
`ROUTER
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`LTA
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`GLOBJ_65
`STORAGE DEVICE
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`scsi
`BUS
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`WORKSTATION
`0
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`1
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`WORKSTATION I [ FiINAGEMENT
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`'1 STATION
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`F'
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`58
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`58
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`76
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`50
`
`FIG.
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`1E DEVICE
`1kATION I
`LE!2E74
`
`64-'
`
`WORKSTATION
`STORAGE
`
`WORKSTATION
`8STORAGE
`
`WORKSTATION
`CSTORAGE
`
`WORKSTATION
`' D STORAGE
`
`-66
`
`-68
`
`-70
`
`-72
`
`Oracle Ex. 1034, pg. 14
`
`

`
`Case 1:13-cv-00895-SS Document 1-1 Filed 10/07/13 Page 4 of 15
`
`co
`
`(B
`(B
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`co
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`I.
`
`FIG. 5
`
`96
`
`98
`
`94
`
`BUS
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`PROCESSI NC
`SUPERVISOR
`IB1JFFERL,3J
`
`56
`
`FIFO
`
`92
`
`FIBRE CHANNEL
`
`INTERFACE
`
`DMA
`
`SCSI CONTROLLER
`
`INTERFACE
`
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`90
`
`OTOCOL
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`FC
`
`52
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`FIBRE CHANNEL CONTROLLER
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`I
`
`SUPERVISOR
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`
`FIG. 4
`
`84 82
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`I
`
`BUFFER
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`I
`
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`56
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`SCSI BUS
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`LLER
`
`BRE CHANNEL
`
`FIBRE CHANNEL
`
`SUPERVISOR
`
`I
`
`86
`
`Oracle Ex. 1034, pg. 15
`
`

`
`Case 1:13-cv-00895-SS Document 1-1 Filed 10/07/13 Page 5 of 15
`
`US 6,425,035 B2
`
`STORAGE ROUTER AND MITHOD FOR
`PROVIDING VIRTUAL LOCAL STOIAGE
`RELATED APPLICATIONS
`This application claims the benefit of the filing date of
`U.S. patent application Ser. No. 091354,682 by inventors
`Geoffrey B. Hoese and leifry T. Russell, entitled "Storage
`Router and Method for Providing Virtual Local Storage"
`filed on Jul. 15, 1999, which is a contimtation of U.S. patent
`application Set. No. 091001,799, filed on Dcc. 31, 1997,
`now U.S. Pat. No. 5,941,972, and herebr incorporates these
`applications by reference in their entireties as if they had
`been fully set forth herein.
`
`10
`
`According to one aspect of the present invention, a
`storage router and storage network provide virtual local
`storage on remote SCSI storage devices to Fiber Channel
`devices. A plurality of Fiber Channel devices, such as
`workstations, are connected to a Fiber Channel transport
`medium, and a plurality of SCSI storage devices are con-
`nected to a SCSI bus transport medium. The storage router
`interfaces between the Fiber Channel transport medium and
`the SCSI bus transport medium. The storage router maps
`between the workstations and the SCSI storage devices and
`implements access controls for storage space on the SCSI
`storage devices. The storage router then allows access from
`the workstations to the SCSI storage devices using native
`low Level, block protocol in accordance with the mapping
`and the access controls.
`According to another aspect of the present invention,
`virtual local storage on remote SCSI storage devices is
`provided to Fiber Channel devices. A Fibre Channel trans-
`port medium and a SCSI bus transport medium are inter-
`faced with. A configuration is maintained for SCSI storage
`20 devices connected to the SCSI bus transport medium. The
`configuration maps between Fiber Channel devices and the
`SCSi storage devices and implements access controls for
`storage space on the SCSI storage devices. Access is then
`allowed from Fiber Channel initiator devices to SCSI stor-
`25 age devices using native low level, block protocol in accor-
`dance with the configuration.
`A technical advantage of the present invention is the
`ability to centralize local storage for networked workstations
`without any cost of speed or overhead. Each workstation
`access its virtual local storage as if it Work locally con-
`nected. Further, the centralized storage devices can be
`located in a significantly remote position even in excess of
`ten kilometers as defined by Fibre Channel standards.
`Another technical advantage of the present invention is
`the ability to centrally control and administer storage space
`for connected users without limiting the speed with which
`the users can access local data. In addition, global access to
`data, backups, virus scanning and redundancy can be more
`easily accomplished by centrally located storage devices.
`A further technical advantage of the present invention is
`40 providing support for SCSI storage devices as Local storage
`for Fiber Channel hosts. In addition, the present invention
`helps to provide extended capabilities for Fiber Channel and
`for management of storage subsystems.
`BRIEF DESCRIPTION OF THE DRAWINGS
`A more complete understanding of the present invention
`and the advantages thereof may be acquired by referring to
`the following description taken in conjunction with the
`accompanying drawings, in which like reference numbers
`indicate like features, and wherein:
`FIG. 1 is a block diagram of a conventmnnal network that
`provides storage through a network server;
`FIG. 2 is a block diagram of one embodiment of a storage
`network with a storage router that provides global access
`55 and routing;
`FIG. 3 is a block diagram of one embodiment of a storage
`network with a storage router that provides virtual local
`storage;
`is a block diagram of one embodiment of the
`FIG.
`60 storage router of FIG. 3; and
`is a block diagram of one embodiment of data flow
`FIG.
`within the storage router of FIG. 4.
`DETAILED DESCRIPTION OF THE
`INVENTION
`FIG. 1 is a block diagram of a conventional network,
`indicated generally at 10, that provides access to storage
`
`TECHNICAL FIELD OF THE U'IVEN'llON
`This invention relates in general to network storage
`devices, and more particularly to a storage router and
`method for providing virtual local storage on remote SCSI
`storage devices to Fiber Channel devices.
`
`BACKGROUND OF THE INVENTION
`Typical storage transport mediums provide for a relatively
`small number of devices to be attached over relatively short
`distances. One such transport medium is a Small Computer
`System Interface (SCSI) protocol, the structure and opera-
`tion of which is generally well known as is described, for
`example, in the SCSI-i, SCSI-2 and SCSI-3 specifications.
`High speed serial interconnects provide enhanced capability
`to attach a large number of high speed devices to a common
`storage transport medium over large distances. One such
`serial interconnect is Fibre Channel, the structure and opera-
`tion of which is described, for example, in Fiber Channel
`Physical and Signaling Interface (PC-PH), ANSi X3.230
`Fiber Channel Arbitrated Loop (Fe-AL), and ANSI X3.272
`Fiber Channel Private Loop Diiect Attach (FC-PLDA).
`Conventional computing devices, *uch as computer
`workstations, generally access storage locally or through
`network interconnects. Local storage typically consists of a
`disk drive, tape drive, CD-ROM drive or other storage
`device contained within, or locally connected to the work-
`station. The workstation provides a file system structure, that
`includes security controls, with access to the local storage
`device through native low level, block protocols. These
`protocols map directly to the mechanisms used by the
`storage device and consist of data requests without security
`controls. Network interconnects typically provide access for
`a. large number of computing devices to data storage on a
`remote network server. The remote network server provides
`file system structure, access control, and other miscellaneous
`capabilities that include the network interface. Access to
`data through the network server is through network proto-
`cols that the server must translate into low level requests to
`the storage device. A workstation with access to the server
`storage must translate its file system protocols into network
`protocols that are used to communicate with the server.
`Consequeotly, from the perspective of a workstation, or
`other computing device, seeking to access such server data,
`the access is much slower than access to data on a local
`storage device.
`
`SUMMARY OF THE INVENTION
`In accordance with the present invention, a storage router
`and method for providing virtual local storage on remote
`SCSI storage devices to Fiber Channel devices are disclosed
`that provide advantages over conventional network storage
`devices and methods.
`
`65
`
`Oracle Ex. 1034, pg. 16
`
`

`
`Case 1:13-cv-00895-SS Document 1-1 Filed 10/07/13 Page 6 of 15
`
`US 6,425,035 B2
`
`3
`through a network server. As shown, ntwork 10 includes a
`plurality of workstations 12 interconneted with a network
`server 14 via a network transport medurc 16. Each work-
`station 12 can generally comprise a processor, memory,
`input/output devices, storage devices anl a network adapter
`as well as other common computer couponents. Network
`server 14 uses a SCSI bus 18 as a storage transport medium
`to interconnect with a plurality of storage devices 20 (tape
`drives, disk drives, etc.). In the embodiment of FIG. 1,
`network transport medium 16 is an network connection and
`storage devices 20 comprise hard disk dtives, although there
`are numerous alternate transport meliums and storage
`devices.
`In network 10, each workstation 12 h*s access to its local
`Storage device as well as network acces to data on storage
`devices 20. The access to a local storage device is typically
`through native low level, block protocols. On the other hand,
`access by a workstation 12 to storage devices 20 requires the
`participation of network server 14 which implements a file
`system and transfers data to workstatiops 12 oniy through 20
`high level file system protocols. Only