`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`Oracle Corporation,
`
`Petitioner,
`
`v.
`
`Crossroads Systems, Inc.
`
`Patent Owner.
`
`____________
`
`IPR2015-_________
`
`U.S. Patent No. 7,051,147
`
`____________
`
`
`
`PETITION FOR INTER PARTES REVIEW
`
`
`

`

`TABLE OF CONTENTS
`
`EXHIBIT LIST ........................................................................................................................ iv
`I.
`MANDATORY NOTICES ........................................................................................ 1
`Real Party-In-Interest ................................................................................................ 1
`A.
`Related Matters........................................................................................................... 1
`B.
`Lead and Back-Up Counsel ...................................................................................... 1
`C.
`Service Information ................................................................................................... 1
`D.
`PAYMENT OF FEES ................................................................................................. 2
`II.
`III. REQUIREMENTS FOR INTER PARTES REVIEW ......................................... 2
`A. Grounds for Standing ............................................................................................... 2
`B.
`Identification of Challenge ....................................................................................... 3
`1. The Specific Art and Statutory Ground(s) on Which the Challenge Is Based . 3
`2. How the Construed Claims Are Unpatentable Under the Statutory Grounds
`Identified in 37 C.F.R. § 42.204(b)(2) and Supporting Evidence Relied upon
`to Support the Challenge ......................................................................................... 4
`IV. BROADEST REASONABLE CONSTRUCTION ............................................... 4
`Claims 1-13 Are Rendered Obvious by CRD-5500 User’s Manual Taken in
`A.
`Combination with CRD-5500 Data Sheet and Smith .............................................. 6
`Introduction of the CRD-5500 References ........................................................... 6
`1.
`Introduction of the Smith Reference ....................................................................... 9
`2.
`3. Level of Skill in the Art ........................................................................................... 10
`4. The Combined System of CRD-5500 User Manual, CRD-5500 Data Sheet
`and Smith .................................................................................................................. 10
`5. Correspondence Between Claims 1-14 and the CRD-5500 User Manual, CRD-
`5500 Data Sheet and Smith ....................................................................................... 12
`6. Secondary Indicia of Nonobviousness ................................................................. 28
`B.
`Claims 3, 6-9 and 12 Are Rendered Obvious by Kikuchi Taken in
`Combination with Bergsten ................................................................................... 29
`Introduction of the Kikuchi Reference .................................................................. 29
`1.
`Introduction of the Bergsten Reference .............................................................. 29
`2.
`3. The Combined System of Kikuchi and Bergsten .................................................... 30
`4. Correspondence Between Claims 3, 6-9 and 12 and Kikuchi and Bergsten ....... 33
`
`ii
`
`
`
`
`

`

`C.
`
`Claims 3, 6-9 and 12 Are Rendered Obvious by Bergsten Taken in
`Combination with Hirai .......................................................................................... 43
`Introduction of the Hirai Reference ..................................................................... 43
`1.
`2. The Combined System of Bergsten and Hirai ....................................................... 45
`3. Correspondence Between Claims 3, 6-9 and 12 and Bergsten and Hirai .......... 48
`EXPLANATION OF NON-REDUNDANCY ................................................... 57
`V.
`VI. EARLIER PROCEEDINGS AND 35 U.S.C. §325(D) .......................................... 59
`VII. CONCLUSION .......................................................................................................... 60
`
`
`
`
`
`
`
`iii
`
`

`

`EXHIBIT LIST
`
`
`1001
`
`U.S. Patent No. 7,051,147 (“the ‘147 Patent”)
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`
`1012
`
`1013
`
`
`
`1014
`
`1015
`
`
`
`
`
`
`
`Select Portions of File History of the ‘147 Patent
`
`CRD-5500 SCSI RAID Controller User’s Manual (“CRD-5500 User
`Manual”)
`
`CRD-5500 SCSI RAID Controller Data Sheet (“CRD-5500 Data
`Sheet”)
`
`Smith et al., Tachyon: A Gigabit Fibre Channel Protocol Chip, Hewlett-
`Packard Journal, October 1996 (“Smith”)
`
`U.S. Patent No. 6,219,771 to Kikuchi et al. (“Kikuchi”)
`
`U.S. Patent No. 6,073,209 to Bergsten (“Bergsten”)
`
`JP Patent Application Publication No. Hei 5[1993]-181609 to Hirai
`(“Hirai”)
`
`Infringement contentions in Crossroads Systems, Inc. v. Oracle Corporation,
`W.D. Tex. Case No. 1-13-cv-00895, Crossroads Systems, Inc. v. Huawei
`Technologies Co. Ltd. et al., W.D. Tex. Case No. 1-13-cv-01025, and
`Crossroads Systems, Inc. v. NetApp, Inc., W.D. Tex. Case No. 1-14-cv-
`00149
`
`Declaration of Professor Chase, Professor of Computer Science at
`Duke University
`
`Cheating the I/O Bottleneck: Network Storage with Trapeze/Myrinet
`
`Interposed Request Routing for Scalable Network Storage
`
`Cut-Through Delivery in Trapeze: An Exercise in Low-Latency
`Messaging
`
`Structure and Performance of the Direct Access File System
`
`Implementing Cooperative Prefetching and Caching in a Globally-
`Managed Memory System
`
`
`
`iv
`
`

`

`1016
`
`1017
`
`1018
`
`1019
`
`
`
`1020
`
`1021
`
`1022
`
`1023
`
`
`1024
`
`
`1025
`
`
`1026
`
`
`1027
`
`
`1028
`
`1029
`
`
`
`
`
`
`Network I/O with Trapeze
`
`A Cost-Effective, High-Bandwidth Storage Architecture
`
`RAID-II: A High-Bandwidth Network File Server
`
`Payload Caching: High-Speed Data Forwarding for Network
`Intermediaries
`
`Petal: Distributed Virtual Disks
`
`File Server Scaling with Network-Attached Secure Disks
`
`Failure-Atomic File Access in an Interposed Network Storage System
`
`U.S. Patent No. 6,308,228 to Yocum et al. (“Yocum”)
`
`Select Portions of File History of Reexamination Control No.
`90/007,123 (U.S. Patent No. 5,941,972)
`
`Select Portions of the File History of Reexamination Control No.
`90/007,124 (U.S. Patent No. 6,421,753)
`
`Plaintiff Crossroads Systems, Inc.’s Objections and Responses to
`Defendants’ First Set of Common Interrogatories in Crossroads Systems,
`Inc. v. Oracle Corporation, W.D. Tex. Case No. 1-13-cv-00895, Crossroads
`Systems, Inc. v. Huawei Technologies Co. Ltd. et al., W.D. Tex. Case No. 1-13-
`cv-01025, and Crossroads Systems, Inc. v. NetApp, Inc., W.D. Tex. Case No.
`1-14-cv-00149
`
`Storagepath Fibre Channel Drive System, SWS/Storagepath, available at
`web.archive.org/web/19970114010450/http://www.storagepath.com/
`fibre.htm, archived January 14, 1997
`
`Technology Brief Strategic Direction for Compaq Fibre Channel-Attached Storage,
`Compaq Computer Corporation, October 14, 1997
`
`Tantawy (ed.), Fibre Channel (Ch. 5) of High Performance Networks, Kluwer
`Academic Publishers, 1994
`
`
`
`v
`
`

`

`1030
`
`
`1031
`
`
`
`
`1032
`
`
`1033
`
`1034
`
`
`1147
`
`
`1036
`
`
`1037
`
`
`
`
`
`
`
`Deel et al., Moving Uncompressed Video Faster Than Real Time, Society of
`Motion Picture and Television Engineers, Inc., December 1996
`
`Emulex LightPulse Fibre Channel PCI Host Adapter, Emulex Corporation,
`available at
`web.archive.org/web/19980213052222/http://www.emulex.com/fc/
`lightpulse2.htm, archived February 13, 1998
`
`Select Portions of File History of Reexamination Control Nos.
`90/007,125 and 90/007,317 (U.S. Patent No. 6,425,147)
`
`Local Area Networks Newsletter, Vol. 15, No. 2, Information
`Gatekeepers Inc., February 1997
`
`Litigation Complaint in Crossroads Systems, Inc. v. Oracle Corporation, W.D.
`Tex. Case No. 1-13-cv-00895
`
`Litigation Complaint in Crossroads Systems, Inc. v. Huawei Technologies Co.
`Ltd. et al., W.D. Tex. Case No. 1-13-cv-01025
`
`Litigation Complaint in Crossroads Systems, Inc. v. NetApp, Inc., W.D. Tex.
`Case No. 1-14-cv-00149
`
`Declaration of Monica S. Ullagaddi authenticating Ex. 1004, Ex. 1027
`and Ex. 1031
`
`
`
`vi
`
`

`

`I. MANDATORY NOTICES
`
`Pursuant to 37 C.F.R. § 42.8(a)(1), Petitioner provides the following mandatory
`
`disclosures.
`
`A. Real Party-In-Interest
`Pursuant to 37 C.F.R. § 42.8(b)(1), Petitioner certifies that Oracle Corporation
`
`is the real party-in-interest.
`
`B. Related Matters
`Pursuant to 37 C.F.R. § 42.8(b)(2), Petitioner states that the ‘147 Patent is
`
`asserted co-pending litigation matter captioned Crossroads Systems, Inc. v. NetApp, Inc.,
`
`W.D.TEx. Case No. 1-14-cv-00149 Ex. 1036 and Crossroads Systems, Inc. v. Oracle
`
`Corporation, 1-13-cv-00895, TXWD, filed October 7, 2013. The ‘147 Patent was also
`
`the subject of IPR2014-01209 and is currently the subject of IPR2014-01207 and
`
`IPR2015-00773. All other related and co-pending litigation matters are set forth in
`
`Exhibit 1026.
`
`
`
`C.
`
`Lead and Back-Up Counsel
`
`Pursuant to 37 C.F.R. § 42.8(b)(3), Petitioner provides the following
`
`designation of counsel: Lead counsel is Greg Gardella (Reg. No. 46,045) and back-up
`
`counsel is Scott A. McKeown (Reg. No. 42,866).
`
`Service Information
`
`D.
`Pursuant to 37 C.F.R. § 42.8(b)(4), papers concerning this matter should be
`
`served on the following.
`
`
`
`
`
`
`1
`
`

`

`Address: Greg Gardella and Scott McKeown
`Oblon LLP
`1940 Duke Street
`Alexandria, VA 22314
`cpdocketgardella@oblon.com, and
`cpdocketmckeown@oblon.com
`Telephone: (703) 413-3000
`Fax:
`
`(703) 413-2220
`
`Email:
`
`PAYMENT OF FEES
`
`The undersigned authorizes the Office to charge to Deposit Account No. 15-
`
`
`II.
`
`0030 the fee required by 37 C.F.R. § 42.15(a) for this Petition for inter partes review.
`
`The undersigned further authorizes payment for any additional fees that might be due
`
`in connection with this Petition to be charged to the above referenced Deposit
`
`Account.
`
`III. REQUIREMENTS FOR INTER PARTES REVIEW
`
`As set forth below and pursuant to 37 C.F.R. § 42.104, each requirement for
`
`inter partes review of the ‘147 Patent is satisfied.
`
`A. Grounds for Standing
`Petitioner certifies that is not estopped or barred from requesting inter partes
`
`review of the ‘147 Patent because this petition is accompanied by a motion for
`
`joinder. The one-year time bar of 35 U.S.C. § 315(b) does not apply to a request for
`
`joinder. 35 U.S.C. § 315(b) (final sentence) (“[t]he time limitation set forth in the
`
`preceding sentence shall not apply to a request for joinder under subsection (c)”); 37
`
`C.F.R. § 42.122(b).
`
`
`
`
`
`
`2
`
`

`

`B. Identification of Challenge
`Pursuant to 37 C.F.R. §§ 42.104(b) and (b)(1), Petitioner requests inter partes
`
`review of claims 1-13 of the ‘147 Patent, and further requests that the Patent Trial and
`
`Appeal Board (“PTAB”) invalidate the same.
`
`1. The Specific Art and Statutory Ground(s) on Which the
`Challenge Is Based
`
`Pursuant to 37 C.F.R. § 42.204(b)(2), inter partes review of the ‘147 Patent is
`
`
`
`requested in view of the following grounds:
`
`(a)
`
`Claims 1-13 are rendered obvious under 35 U.S.C. § 103(a) by the
`
`combination of The CRD-5500 SCSI RAID Controller User’s Manual (“CRD-5500 User
`
`Manual”, Ex. 1003), CRD-5500 SCSI RAID Controller Data Sheet (“CRD-5500 Data
`
`Sheet”, Ex. 1004), and Smith et al., Tachyon: A Gigabit Fibre Channel Protocol Chip,
`
`Hewlett-Packard Journal, October 1996 (“Smith”, Ex. 1005);
`
`(b) Claims 3, 6-9 and 12 are rendered obvious under 35 U.S.C. § 103(a) by
`
`U.S. Patent No. 6,219,771 to Kikuchi et al. (“Kikuchi”, Ex. 1006) in view of U.S. Patent
`
`No. 6,073,209 to Bergsten (“Bergsten”, Ex. 1007); and
`
`
`
`(d) Claims 3, 6-9 and 12 are rendered obvious under 35 U.S.C. § 103(a) by
`
`Bergsten in view of JP Patent Application Publication No. Hei 5[1993]-181609 to Hirai
`
`(“Hirai”, Ex. 1008).
`
`
`
`
`
`
`3
`
`

`

`2. How the Construed Claims Are Unpatentable Under the
`Statutory Grounds Identified in 37 C.F.R.
`§ 42.204(b)(2) and Supporting Evidence Relied upon to
`Support the Challenge
`
`Pursuant to 37 C.F.R. § 42.204(b)(4), an explanation of how claims 1-13 of the
`
`
`
`
`‘147 Patent are unpatentable, including the identification of where each claim element
`
`is found in the prior art, is provided in Section VII below. Pursuant to 37 C.F.R. §
`
`42.204(b)(5), the exhibit numbers of the supporting evidence relied upon to support
`
`the challenges and the relevance of the evidence to the challenges raised, including
`
`identifying specific portions that support the challenges, are provided in Section VII.
`
`IV. BROADEST REASONABLE CONSTRUCTION
`
`Petitioner bases this petition upon the U.S. Patent and Trademark Office’s
`
`(“USPTO”) “broadest reasonable interpretation” standard applied in PTAB
`
`proceedings. All claimed terms not specifically addressed in this section have been
`
`accorded their “broadest reasonable interpretation” in light of the ‘147 Patent
`
`including their plain and ordinary meaning. Petitioner’s position regarding the scope
`
`of the claims under their “broadest reasonable interpretation” is not to be taken as
`
`stating any position regarding the appropriate scope to be given the claims in a court
`
`or other adjudicative body under the different claim interpretation standards that may
`
`apply to such proceedings. In particular, Petitioner notes that the standard for claim
`
`construction used in district courts differs from the standard applied before the
`
`USPTO. Any claim construction offered by Petitioner in this petition is directed to
`
`
`
`
`
`
`4
`
`

`

`the USPTO standard, and Petitioner does not acquiesce or admit to the constructions
`
`reflected herein for any purpose outside of this proceeding.
`
` “Native low-level block protocol” is described in the ‘147 Patent as being
`
`distinct from higher-level protocols that require translation to NLLBP. Ex. 1001 at
`
`1:15-28; 3:14-25 and 5:1-5. Examples of NLLBPs in the ‘147 Patent include SCSI-2
`
`commands and SCSI-3 Fibre Channel Protocol (“FCP”) commands. See e.g., Ex. 1001
`
`at 6:39-58. The ‘147 Patent distinguishes prior art systems that provided access
`
`“through network protocols that the [network] server must translate into low level
`
`requests to the storage device.” Id. at 1:51-54.
`
`During the reexamination of the parent patent the Patent Owner argued that a
`
`NLLBP is “a set of rules or standards that enables the exchange of information
`
`without the overhead of high-level protocols and file systems typically required by
`
`network servers,” citing the Markman Order of the U.S. District Court for the
`
`Western District of Texas in Crossroads v. Chaparral Network Storage, Inc., Civil Action
`
`No. A-00-CA-217-SS and Crossroads Systems, Inc., v. Pathlight Technology, Inc., Civil Action
`
`No. A-00CA-248-JN. 35 U.S.C. §301(a)(2); Ex. 1025 p. 500, Patent Owner Response
`
`at p. 21. Consistent with this, the Examiner found that “[t]he SCSI protocol/standard
`
`is considered a NLLBP. TCP/IP, e.g., used in Ethernet communications, however, is
`
`not considered to be a NLLBP.” Id. at p. 14, NIRC at p. 3.
`
`For the foregoing reasons, the broadest reasonable interpretation of NLLBP
`
`includes a protocol, such as the SCSI protocol for SCSI commands, that enables the
`
`
`5
`
`
`

`

`exchange of information without the overhead of high-level protocols and file
`
`systems typically required by network servers.
`
` V. GROUNDS OF UNPATENTABILITY
`
`Each reference is introduced in turn and those introductions are followed by
`
`an explanation of the combined system or method and the supporting rationale.
`
`Thereafter, the correspondence between the combined system or method and each
`
`claim element is explained.
`
`A. Claims 1-13 Are Rendered Obvious by CRD-5500 User’s Manual
`Taken in Combination with CRD-5500 Data Sheet and Smith
`1. Introduction of the CRD-5500 References
`The CRD-5500 SCSI RAID Controller User’s Manual (“CRD-5500 User
`
`Manual”, (Ex. 1003) and CRD-5500 SCSI RAID Controller Data Sheet (“CRD- 5500
`
`Data Sheet", Ex. 1004) were published on November 21, 1996 and December 26,
`
`1996, respectively, over a year before the earliest priority date of the ‘147 Patent
`
`(December 31, 1997). Therefore, the CRD-5500 User Manual and CRD- 5500 Data
`
`Sheet are prior art to the ‘147 Patent under 35 U.S.C. §102(b). The CRD-5500 User
`
`Manual and CRD-5500 Data Sheet were before the Examiner but were not discussed
`
`by the Examiner in any office action or referenced in any rejection.
`
`The CRD-5500 User Manual is presumed authentic under Fed.R.Evid.
`
`901(b)(4) given that it was submitted by the Patent Owner as prior art and is self-
`
`authenticating under Fed.R.Evid. 902(7) given that it bears trade inscriptions
`
`
`
`
`
`
`6
`
`

`

`demonstrating that the document is a publication by CMD Technology, Inc.
`
`released on a date certain. The CRD-5500 Data Sheet is authenticated by the
`
`declaration of Monica S. Ullagaddi. Ex. 1037.
`
`The CRD-5500 User Manual describes a RAID controller which couples one or
`
`more host devices to virtual local storage on a RAID storage disk array. Ex. 1003 at 1-
`
`1. Devices are connected to the CRD-5500 controller through a number of I/O
`
`module slots configured to receive both host interface modules and storage device
`
`interface modules. Id. at 2-1.
`
`Figure 1-1 of the CRD-5500 User Manual illustrates how the controller's RAID
`
`set configuration utility can be used to configure virtual or logical storage regions,
`
`referred to as RAID sets, by assigning individual disk drives to logical groups. Ex.
`
`1003 at 1-2. Each group may have a particular purpose and, as such, a particular
`
`configuration including, in some examples, striped partitions, data mirroring, or a
`
`combination thereof. Id.; see also id. at 1-5 and 1-7.
`
`“The controller's Host LUN [Logical Unit Number] Mapping feature makes it
`
`possible to map RAID sets” or redundancy groups (a RAID set or portion/partition
`
`thereof) “differently to each host.” Id. at 1-1, ee1-10; see also id. at 4-5. As illustrated in
`
`the “Host LUN Mapping” utility disclosed in the CRD-5500 User Manual, a particular
`
`host device (identified as “Channel 0”) is allotted access to one or more RAID
`
`redundancy groups (e.g., redundancy groups 0, 1, 5, and 6 through 31). The host
`
`device is provided an address for accessing each RAID redundancy group through a
`
`
`7
`
`
`

`

`“Host LUN” (logical unit number, an addressing mechanism). See e.g., id. at 4-5; 4-10;
`
`and 6-10. An administrator can allocate a particular disk as a redundancy group, such
`
`that a host LUN maps to a single physical disk or partition thereof. See, e.g., id. at 2-3,
`
`2-4, 3-3, 3-4. Accordingly, the “Host LUN Mapping” utility of the CRD-5500
`
`controller provides virtual local storage to a host device by presenting access to one or
`
`more RAID redundancy groups using LUN-based addressing. Id. at 4-5. Further, the
`
`“Host LUN Mapping” utility allows the CRD-5500 controller to restrict a particular
`
`host’s access to a given memory region on the RAID array by withholding addresses
`
`(i.e., “Host LUNs”) for particular RAID redundancy groups to that host (e.g.,
`
`redundancy groups 2 through 4 have been excluded from the list of redundancy
`
`groups for which Host LUNs have been assigned to the host illustrated). See e.g., id. at
`
`1-1, “You make the same redundancy group show up on different LUNs to different
`
`hosts, or make a redundancy group visible to one host but not to another.”; id. at 1-11,
`
`“the CRD-5500 defines each RAID set or partition of a RAID set as a ‘redundancy
`
`group.’ These redundancy groups may be mapped to host LUNs, either in a direct
`
`one-to-one relationship or in a manner defined by the user.”) The CRD-5500 Data
`
`Sheet notes that the modular design of the storage controller supports interfacing with
`
`host and/or storage devices via a high speed serial connection such as a Fibre
`
`Channel transport medium:
`
`Unlike other RAID controllers, CMD's advanced ‘Viper’ RAID
`architecture and ASICs were designed to support tomorrow’s
`
`8
`
`
`
`
`

`

`high speed serial interfaces, such as Fibrechannel (FCAL)[].
`Ex. 1004 at p. 1 (emphasis added).
`2. Introduction of the Smith Reference
`Smith et al., Tachyon: A Gigabit Fibre Channel Protocol Chip, Hewlett-
`
`Packard Journal, October 1996 (“Smith”. was published in October of 1996, over a year
`
`before the earliest priority date of the ‘147 Patent (December 31, 1997). Smith is
`
`therefore prior art under 35 U.S.C. §102(b).
`
`Smith describes the off-the-shelf Tachyon controller which is used in the
`
`preferred embodiment of the ‘147 Patent. Ex. 1001 at 6:30. The Tachyon chip is
`
`designed to serve as, among other things, a bridge between a Fibre Channel and a
`
`SCSI channel by encapsulating SCSI packets and sending them over the Fibre
`
`Channel. Ex. 1005 at 4. Indeed,
`
`[t]he second major design goal was that Tachyon should support SCSI
`encapsulation over Fibre Channel (known as FCP). From the
`beginning of the project, Tachyon designers created SCSI assists to
`support SCSI initiator transactions. . .Early in the design, Tachyon
`only supported SCSI initiator functionality with its SCSI hardware
`assists. It became evident from customer feedback, however, that
`Tachyon must support SCSI target functionality as well, so SCSI target
`functionality was added to Tachyon hardware assists. Id.
`The SCSI target functionality allows for mass storage support by adapting the Fibre
`
`Channel controller chip for use in a Fibre Channel target adapter card, such as the
`
`host interface modules of the CRD-5500. Id. at 3.
`
`
`
`
`
`
`9
`
`

`

`3. Level of Skill in the Art
`The prior art discussed herein demonstrates that a person of ordinary skill in
`
`the field, at the time the ‘147 Patent was effectively filed, was familiar with block
`
`storage systems (disks, RAID, and the SCSI command abstraction), storage volume
`
`management concepts, and networking technologies. Ex. 1010 ¶14. A person skilled
`
`in the art would have at least an undergraduate degree in electrical or computer
`
`engineering or its equivalent and several years of experience with the foregoing
`
`technologies. This level of skill in the art is used for all grounds raised herein.
`
`4. The Combined System of CRD-5500 User Manual,
`CRD-5500 Data Sheet and Smith
`
`It would have been obvious to one of ordinary skill in the art to combine the
`
`CRD-5500 User Manual, the CRD-5500 Data Sheet, and Smith to enhance the
`
`communication and storage options of a host computing device on a Fibre Channel
`
`transport medium, benefit from the “Host LUN Mapping” feature of the storage
`
`controller, and avail the host computing device of ubiquitous mass storage
`
`applications (e.g., RAID). Ex. 1010 ¶¶39-43. This combination is specifically suggested
`
`in the CRD-5500 Data Sheet, which explains that “CMD's advanced ‘Viper’ RAID
`
`architecture and ASICs were designed to support tomorrow's high speed serial
`
`interfaces, such as Fibrechannel[]” Ex. 1004 p. 1. The high bandwidth of Fibre
`
`Channels and capability of extended distances between hosts and the storage
`
`controller each provided a strong motivation to adopt the CRD- 5500 Data Sheets’s
`
`
`
`
`
`
`10
`
`

`

`suggestion to enhance the CRD-5500 controller with the Fibre Channel-to-SCSI
`
`bridging capabilities of host and/or storage device modules designed with Tachyon
`
`chips. Ex. 1004 pp. 1-2.
`
`In the combined system, the Tachyon chip is incorporated into Fibre Channel
`
`enabled host device interface modules installed in I/O slots of the CRD-5500
`
`controller. See e.g., Ex. 1010 ¶¶39-43. Professor Chase explains that the Tachyon chip
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`encapsulates and de-encapsulates SCSI commands on FC transport media that
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`enables bridging to SCSI transport media. Ex. 1010 ¶¶39-43; Ex. 1005 at pp. 4, 9, and
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`10; see also Ex. 1004 at pp. 1-2. The CRD- 5500 controller, in the combined system, is
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`configured to provide virtual local storage to up to four Fibre Channel host interface
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`modules (each interfacing with a host computing device) through the “Host LUN
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`Mapping” feature. Ex. 1010 ¶¶39-43. A figure representing the combined system is
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`shown below. See e.g., Ex. 1003 at Fig. 1-2.
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`In operation, the CRD-5500 controller coordinates the following process for
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`managing a host storage command. Ex. 1010 ¶¶42-43. A FCP packet containing a
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`SCSI storage access command (e.g., read or write request) is transmitted to the CRD-
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`5500 controller by a host. Id. At the host interface module, the Tachyon chip de-
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`encapsulates the FCP packet to access the SCSI command. Id. The host identity can
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`be derived from either the incoming packet (e.g., FCP header or SCSI header) or the
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`channel of the host module slot receiving the communication, if recognized. Id. The
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`Tachyon chip pulls the host’s storage address (e.g., LUN-based address) from the
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`FCP header and passes the host identity and storage address as well as the SCSI
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`payload to the CRD-5500 processor, where the host information is cross-referenced
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`with the “Host LUN Mapping” maintained by the CRD-5500 controller to identify a
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`redundancy group of the RAID storage disk array corresponding to the host storage
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`address. Id. The CRD-5500 controller routes the SCSI command to the corresponding
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`disk drive in the RAID array where the command is acted upon. Id.
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`5. Correspondence Between Claims 1-13 and the CRD-
`5500 User Manual, CRD-5500 Data Sheet and Smith
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`The discussion below demonstrates the correspondence between the ‘147
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`Patent claim terms and the CRD-5500 User Manual, CRD-5500 Data Sheet and Smith.
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`1. a) A storage router for providing virtual local storage on remote storage devices to a
`device, comprising:
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`The CRD-5500 Manual discloses this limitation because it teaches a CRD-
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`5500 RAID controller that routes data between host computers and SCSI disk
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`arrays. Ex. 1003 at 1-1, 1-4, 1-5 and 2-4. As discussed above, one or more
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`redundancy groups can be created. Each redundancy group can be assigned a
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`physical disk. Ex. 1003 at 1-5; Ex. 1010 ¶44. An example of groupings of physical
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`disk drives into redundancy groups is illustrated in Fig. 1-1 of the CRD-5500 User
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`Manual. See id. at 1-1, 1-2; Ex. 1010 ¶44. This provides a “virtual storage” region on
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`each disk. Further, as detailed previously, the configuration provides for mapping
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`the redundancy groups to host LUN addresses to provide the hosts with addressing
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`capability to each redundancy group. See id. at 1-1, 4-5; Ex. 1010 ¶44.
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`b) a buffer providing memory work space for the storage router;
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`The combined system includes “a buffer providing memory work space for the
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`storage router”. The CRD-5500 controller includes an onboard cache with “up to 512
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`megabytes of memory” that temporarily stores data flowing between the hosts and the
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`storage devices. Ex. 1003 at 1-4; Ex. 1010 ¶45.
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`c) a first [FC] controller operable to connect to and interface with a first [FC] transport
`medium;
`d) a second [FC] controller operable to connect to and interface with a second [FC]
`transport medium; and
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`The combined system includes “a first controller” created through the
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`incorporation of the Tachyon chip into a FC host interface module designed for
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`installation in a host I/O slot of the CRD-5500 controller, as detailed above. Ex.
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`1003 at 1-1, 2-1, 2-4, 3-1. The “first controller” is “operable to interface with a first
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`transport medium” (FC transport medium). Id. As illustrated in Fig. 6 of Smith, for
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`example, the Tachyon logic of the host interface module would interface with the
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`FC transport medium (illustrated as the “Link”). Ex. 1005 at 8; Exhibit 1010 ¶46.
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`The combined system includes a “second controller” (Tachyon logic of the
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`storage device interface module) “operable to connect to and interface with a
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`second transport medium” (FC transport medium connecting to the physical storage
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`drive). Ex. 1003 at 1-1, 2-1, 2-4, 3-1. As illustrated in Fig. 6 of Smith, the Tachyon
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`logic of the storage device interface module would interface with the FC transport
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`medium (illustrated as the “Link”). Ex. 1005 at 8; Ex. 1010 ¶47.
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`e) a supervisor unit coupled to the first and second [FC] controllers and the buffer,
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`The combined system includes “a supervisor unit” coupled to the first
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`controller, the second controller, and the buffer. The CRD-5500 controller has a
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`MIPS R3000 RISC CPU programmed to function as a supervisor unit and coupled
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`to the host interface module, the storage device interface module, and the buffer
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`memory. Ex. 1003 at 1-1, 1-3, 4-1, 4-14; Ex. 1010 ¶48. The CPU provides a
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`“monitor utility [that] provides complete control over the configuration and
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`operation of the controller.” Id. Further, a portion of the supervisor unit processing
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`capability may be resident upon any or all of the interface modules installed in the
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`nine I/O slots of the CRD-5500 Controller. Id.; Ex. 1010 ¶48.
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`f) . . . operable to maintain a configuration for remote storage devices connected to the second
`[FC] transport medium that maps between the device and the remote storage devices and
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`The supervisor unit is operable to “map between devices connected to the
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`first transport medium and the storage devices.” As described above, each
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`redundancy group can be assigned a remote disk storage device. See id. at 2-3, 2-4, 3-
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`3, 3-4. The Host LUN Mapping feature of the CRD-5500 can associate the
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`redundancy groups with host devices. See id. at 1-1, 4-5. As illustrated in the Host
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`LUN Mapping utility at §4.3.3., the map associates storage space on the storage
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`devices assigned to the redundancy groups to “devices connected to the first
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`transport medium.” Ex. 1003 at 4-5, §4.3.3; Ex. 1010 ¶49.
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`Further, the Monitor Utility in the executable firmware of the CRD-5500 RAID
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`controller provides a “Host LUN Mapping feature” that allows a user to “assign
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`redundancy groups to a particular host,” where each redundancy group is “any
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`combination of disk drives” or “partition” of the disk drives. Ex. 1003 at 1-2, 1-11,
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`4-2, 4-5.
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`g) that implements access controls for storage space on the remote storage devices; and
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`In the combined system, the supervisor unit “implement[s] access controls
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`for storage space on the storage devices” by accepting only LUN addresses for
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`which a mapping to a redundancy group exists and is associated with the requesting
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`host. Ex. 1003 at 1-1, 4-5. As described by the CRD-5500 User Manual, for
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`example, the Host LUN Mapping utility allows an administrator to prevent a
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`particular RAID redundancy group from being visible to a particular host,
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`effectively blocking access to that storage region by the particular host. Ex. 1003 at
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`4-5. The combined system of the CRD-5500 controller with FC-enabled host
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`interface modules and FC-enabled storage device interface modules functions
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`identically in this regard. Ex. 1010 ¶50.
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`h) to process data in the buffer to interface between the first [FC] controller and the second
`[FC] controller to allow access from [FC] initiator devices to the remote storage devices
`using [NLLBP] in accordance with the configuration.
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`The supervisor unit of the combined system “allow[s] access from devices
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`connected to the first transport medium to the remote storage devices using native
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`low level block protocol.” Through the LUN Mapping utility of the CRD-5500
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`controller, a host device addresses remote RAID storage regions through LUN
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`addressing, an addressing mechanism used to allow host devices to access and
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`address storage as though it were local storage. Ex. 1003 at 4-10. The native low
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`level block protocol carrying the LUN address is the FC or FCP protocol. See, e.g.,
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`Ex. 1001 at 8:22-25. The CRD-5500, using the Host LUN Mapping, identifies a
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`RAID redundancy group mapped to the LUN identified within the FCP request for
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`the particular requesting host and allows access to the mapped RAID redundancy
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`group. Ex. 1010 ¶51.
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`In the combined system, access is allowed through “process[ing] data in the
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`buffer to interface between the first controller and the second controller.” Ex. 1010
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`¶52. As described above in relation to the read and write operations of the
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`com