`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CROSSROADS SYSTEMS, INC.
`Patent Owner
`
`Patent No. 7,051 ,147
`
`DECLARATION OF JOHN MIDDLETON
`
`1 of 3
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` CROSSROADS EXHIBIT 2305
`Oracle Corp., et al v. Crossroads Systems, Inc.
` IPR2014-01207 and IPR2014-1209
`
`CROSSROADS EXHIBIT
`Oracle Corp. v. Crossroads Systems, Inc.
`IPR2015-0(cid:1005)(cid:1004)(cid:1010)(cid:1008)
`
`2305
`
`
`
`I, John Middleton, state and declare as follows:
`
`1.
`
`I was an employee of Crossroads Systems, Inc. from 1997 until 2001. ·
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`I started at Crossroads in February of 1997. For most of my tenure at Crossroads I
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`was a vice-president of engineering.
`
`2.
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`During 1997, I worked on the "Verrazano" project, which ultimately
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`became Crossroad's first storage bridge product. During this time period, I worked
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`with both Geoffrey Hoese and Jeffrey Russell on the Verrazano project. My role
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`on V errazano was hardware engineering manager
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`3.
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`During the last half of 1997, it is my recollection that Crossroads had
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`approximately 10 technical employees (in other words, those that would be
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`involved in designing and building working products). During that time, all of
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`those personnel, including myself, were dedicated to work on the V errazano
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`project-
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`that is, creating a functional, working product.
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`4.
`
`Neither Verrazano, nor its ultimate embodiment in Crossroads'
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`storage bridge products, utilized the access controls. By access controls, I mean the
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`ability to control access from a host computer to the same storage available to
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`another host computer. Access controls were later added to Crossroads' router
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`products after the Verrazano project was completed. However, development of the
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`Verrazano project (which was Crossroads' initial storage bridge) was required in
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`1
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`2 of 3
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`
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`order to create a product having access controls, as access controls were
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`incorporated into the storage bridge and require the bridge's components in order
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`to function. Without a working storage bridge, there was not a way to implement
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`access controls. In other words, until the Verrazano bridge could be completed,
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`Crossroads had no working device which could implement access controls.
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`I declare under penalty of perjury under the laws of the United States of America
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`that the foregoing is true and correct.
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`Executed on: May ll, 2015
`
`~Middleton
`
`2
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`3 of 3
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