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`PART (cid:21)
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`there's no access to devices three,
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`four and five.
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`IQ. Okay. And so if we go back to the colorized version of
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`exhibit 552, which computer screen shot were we looking at
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`then?
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`A. We were looking at the left computer the one shown in
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`blue.
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`Q.
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`Now, should we look at the right one?
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`A. Yes.
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`Q. And now I'm showing, again, a screen shot
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`from exhibit
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`110, your Honor, showing right G 06, windows explore er with
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`ones three four and five enabled for right system and what is
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`this showing?
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`A. This is the windows ex er showing what the right system
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`can see for storage devices and three external devices labeled
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`blue, purple and orange.
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`Q.
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`It's a few pages later and it's also on the graphic
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`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
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`are devices three,
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`four and five.
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`MR . ALCOCK:
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`Q. Okay.
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`And so now let's go back to exhibit 564. What is
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`exhibit 564 showing?
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`A. This is a composite of the three slides we've showed for
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`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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`26
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`Oracle Ex. 1024, pg. 616
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`Oracle Ex. 1024, pg. 616
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`and the right computer.
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`Q.
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`A.
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`So what is this showing us,
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`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
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`the particular computers.
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`Q.
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`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
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`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.
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`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.
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`Q. And in effect, here it shows that those computers can't
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`even see those storage devices on their computer screen:
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`is
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`that right?
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`A.
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`How would they get access to them?
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`I was unable to do that.
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`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,
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`let me show you exhibit 611. What is exhibit 611?
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`A. This is an excerpt from the Pathlight from one of the
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`manuals.
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`It's gateway,
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`I believe. And it shows the use of
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`"the SAN director and the privileges that one might have in
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`02/22/2002 8:56 AM
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`27
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`Oracle Ex. 1024, pg. 617
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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.
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`Now, hold on one second. Let's just step back for the a
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`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:
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`I apologize.
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`It was left out.
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`You were
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`given a copy of all the graphics earlier, counsel, every
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`single one of them.
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`MR. ALCOCK:
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`‘Q. Continue.
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`A. Would you repeat the question?
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`Q. What is exhibit 611 showing?
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`A.
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`It's showing the —— how one uses the SAN director. And in
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`particular, it says that there are two different privilege
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`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
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`is —— you could look at the access control and the
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`administrator mode which allows you to actually change access
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`control.
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`Both of those actually reguire a pass word for access
`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
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`director, it asks you who you are and your pass word.
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`Q. Okay.
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`So does the products that you've tested have the
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`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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`28
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`Oracle Ex. 1024, pg. 618
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`Oracle Ex. 1024, pg. 618
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`
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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
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`that showing, sir?
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`A. This is showing the final element of claim 1 in which we
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`talk about the native low level block protocol, and the text
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`down there comes from a computer screen where I was actually
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`operating the devices with SCSI commands addressing a
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`particular device.
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`Q.
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`So the bottom is another one of those screen shots from
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`your computer?
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`A. Yes, it is.
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`'1 Q1
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`And what does that show?
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`A.
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`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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`1
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`Q. Okay.
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`Now,
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`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.
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`Is that
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`an element of this claim and some of the other claims?
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`A. Yes, it is.
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`And do these devices have that?
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`A. Yes,
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`they do.
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`Q.
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`Can you explain?
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`A Virtual local storage is what you get —— is defined as --
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`I've got blank.
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`I'm sorry. Storage that has the appearance
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`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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`I 29
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`Oracle Ex. 1024, pg. 619
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`Oracle Ex. 1024, pg. 619
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`you combine mapping, virtual -- native low level block
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`protocol and access control.
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`Q. Okay. Let me put before you an exhibit,
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`a number of which
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`I'll give you a in a second and can you explain what that is?
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`A. This is a summary of claim 1.
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`Q.
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`A.
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`It's exhibit 572 for the record, your Honor.
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`A summary of claim 1, a summary of the graphics that you’
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`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
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`graphics.
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`Q. Okay.
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`Now I'm going to put before you Claim 7.
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`'There
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`were three independent claims in the patent, sir?
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`A. Yes, that's right.
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`Q.
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`And is this the next
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`independent claim?
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`A. This is the next one.
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`Q. And how does is this different from the other claim that
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`we just looked at?
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`A.
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`The first claim that we looked at was the claim that
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`described the storage router. This one starts off describing
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`a storage network, Pathlight product.
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`It's not a network,
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`it's a router.
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`Q. Okay. But does it go in a network?
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`A
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`Yes, it does.
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`Q. Does it have any use other than being in a network?
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`25'
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`A
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`Nothing substantial.
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`02/22/2002 8:56 AM
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`30
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`Oracle Ex. 1024, pg. 620
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`Oracle Ex. 1024, pg. 620
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`Q. Okay. And so does the products have all the elements of
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`claim 7?
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`A. Yes, it does.
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`Q. Okay.
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`I've put before you exhibit 575. Does that help
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`you explain this quickly?
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`A. Yes, it does. But we have a storage network which has
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`such characteristics which show a photograph of the device of
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`the Pathlight SAN gateway.
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`The block diagram, again. We have
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`a fiber channel transport medium emphasized in red here. We
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`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
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`references all through the documentation to work stations.
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`Plurality of SCSI storage devices connected to the SCSI bus,
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`connected to the fiber channel.
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`So it has all the elements of
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`claim 7.
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`It has all the elements of claim 7, and the storage
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`router itself is in the middle of this network, and it has
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`exactly the same characteristics that are described in claim
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`1.
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`Q.
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`Can you check those off?
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`A. Yes. Mapping, access controls, native low level block
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`protocol.
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`Q. Okay.
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`Now, claim 11 is the last independent claim.
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`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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`I
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`i
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`Oracle Ex. 1024, pg. 621
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`Oracle Ex. 1024, pg. 621
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`
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`06I11I2001 Tria|, Day 3
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`A.
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`The other claims claim specific hardware. This claims a
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`method of doing something which looks remarkably familiar to
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`you by now.
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`Q. And just quickly showing you exhibit 578. Does it neat
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`the elements of the method claim 11?
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`A. Yes, it does. We have, again, we have a means describe --
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`that's described by looking at the product itself and at the
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`block diagram. We have a means of connecting to the Fibre
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`Channel, means of connect together the SCSI bus.
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`Q.
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`Can you check the boxes for us?
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`A. Uh—huh. We have another graphic on the rest of that?
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`Q. Exhibit 579?
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`A. Yes, means of maintaining a configuration. We've got
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`through that. Access controls, means of allowing access in
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`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.
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`Q.
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`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
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`briefly about the dependent claims. Right now we've covered
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`three independent claims. What's a dependent claim?
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`A.
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`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
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`you exhibit 580. Did they infringe those claims?
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`A. Yes,
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`they do. Claim 2,
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`8 and 14 are all similar and they.
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`02/22/2002 8:56 AM
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`'
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`32
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`Oracle Ex. 1024, pg. 622
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`Oracle Ex. 1024, pg. 622
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`
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`0H11R001 Tfim,Day3
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`require that one have only one computer that has access to a
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`particular device and the access control that I defined in
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`previously was -- covers that.
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`Q. Okay.
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`I'm showing you exhibit 581 and I'll ask your
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`opinion with respect to claims 3 and 13.
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`A. Claims 3 and 13 indicate that the Fibre Channel devices
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`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
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`web site and various diagrams.
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`Q. Okay.
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`Now, exhibit 582 showing claims 4,
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`9 and 14.
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`To
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`they infringe those claims?
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`A. Yes,
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`the SCSI storage devices,
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`the hard disk drives,
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`they
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`show pictures and discussion of that throughout the
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`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?
`V
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`Q. Exhibit 569 and I'm going to focus you on the bottom two
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`claims.
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`A. This way I don't leave anything out. Claim 5 describes
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`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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`33
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`Oracle Ex. 1024, pg. 623
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`Oracle Ex. 1024, pg. 623
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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.
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`Q. Okay. Have a seat, sir. While you're doing that,
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`I'm
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`going to put up a page of exhibit 153.
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`It's page 109 of
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`exhibit 153.
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`It's a page from if Pathlight web site.
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`So far,
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`Dr. Hodges, have all the tests that you've done,
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`the screen
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`shots that we've shown have been used with this VPS software?
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`- 9
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`A. That's correct.
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`Now, earlier you mentioned you tested it with another kind
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`of software. What was that?
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`A. That's called channel zoning.
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`Q. Okay. And showing exhibit 109 and I'm putting a portion
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`of it, Pathlight SAN gateway solve these type of problems with
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`two levels of access control.
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`The first method offered by SAN
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`gateway is channel access control or zoning.
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`Is that the
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`other kind that question haven't talked about yet?
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`A. Yes;
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`MR. BAHLER: Counselor, you just mentioned 109. Are
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`you within Plaintiff's Exhibit 153?
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`MR. ALCOCK: Exhibit 153 point 109 and at the end of
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`your book are a handful of pages and in it is this included.
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`MR. BAHLER:
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`Thank you.
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`MR. ALCOCK:
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`'25
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`Q: Let me take a look at page 110.
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`Panels Pathlight's
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`02/22/2002 8:56 AM
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`V
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`34
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`Oracle Ex. 1024, pg. 624
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`Oracle Ex. 1024, pg. 624
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`channel access control inhibits devices from knowing that the
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`storage channel exists, making it inaccessible.
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`Do you agree
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`with that statement?
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`A. Yes.
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`Q Q. And what test did you perform the confirm that in fact is
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`the case?
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`A.
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`I reconfigured my test setup so that each of the computers
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`was on a separate fiber channel port and I reconfigured the
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`' disk drives to have some of them on two different SCSI ports.
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`Q. Okay. Let me show you exhibit 607. What is exhibit 607?
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`A. This is a screen shot for the Pathlight SAN director
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`again, channel zoning control, and the color is added.
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`Q. And what are you doing here?
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`A. What I'm doing here is setting up the access control for
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`the channel zoning.
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`Q. Okay. Let me show you exhibit 606. What does that show,
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`sir?
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`A. This shows a picture of how things are connected. This is
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`again the Pathlight SAN director.
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`They have an information
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`screen that will show you this kind of thing.
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`You can see
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`that the -- in the upper section,
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`the SCSI devices,
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`there are
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`three devices connected to SCSI channel one and two connected
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`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.
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`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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`35
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`Oracle Ex. 1024, pg. 625
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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?
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`A. That's what
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`I was just talking about.
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`Q. Oh,
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`I'm sorry.
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`So which are connected to which fiber a
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`channel?
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`A.
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`The checkmarks in the previous graphic show that Fibre
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`Channel one was connected to SCSI channel one and not to SCSI
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`channel
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`two.
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`So you'll see the Fibre Channel one outlined in
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`red here connected to SCSI channel one should be able to see
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`only devices one,
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`three and five which are connected to the
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`SCSI for that channel.
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`And the same -- similarly for fiber
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`channel
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`two.
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`Q. Okay.
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`So let me show you exhibit 608. What is that a
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`screen shot of?
`
`A.
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`Screen shot of the windows explore er showing what is
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`available to the left computer.
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`The left computer, you'll
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`recall, was on fiber channel 1 and was allowed access to SCSI
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`kennel
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`1 which contained devices one,
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`three and five,
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`that is
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`the red, blue and orange devices.
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`Q. Okay. And let me show you exhibit 609. What is that
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`. depict?
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`2
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`A. That is the right computer, windows explore er showing
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`what's accessible to the right computer. Again,.it was on --
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`it was on fiber channel
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`two with access to SCSI channel
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`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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`36
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`Oracle Ex. 1024, pg. 626
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`Oracle Ex. 1024, pg. 626
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`06/11/2001 Trial, Day 3
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`2.
`
`3
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`4
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`5
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`8
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`13
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`14
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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.
`
`Q. Does it do it in a substantially the same way?
`
`A. Yes, it does.
`
`Q. Does it achieve the same result?
`
`A
`
`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?
`
`15
`
`i
`
`A. Yes,
`
`they are.
`
`16 _
`
`Q. And do they do it in substantially the same way?
`
`17
`
`18
`
`19
`
`A. Substantially the same way.
`
`Q. And does it achieve substantially the same result with
`
`respect to every claim element?
`
`'20
`
`A. Yes, it does.
`
`21
`
`22
`
`23
`
`24
`
`25
`
`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.
`
`02/22/2002 8:56 AM
`
`-
`
`‘
`
`37
`
`Oracle Ex. 1024, pg. 627
`
`Oracle Ex. 1024, pg. 627
`
`
`
`06/11/2001 Trial, Day 3
`
`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 mind?
`
`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
`
`1
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`2
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`3
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`4
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`14
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`19
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`20-
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`something-attached the a local compute.
`
`21
`
`22
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`23
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`24
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`25
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`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.
`
`02/22/2002 8:56 AM
`
`38
`
`Oracle Ex. 1024, pg. 628
`
`Oracle Ex. 1024, pg. 628
`
`
`
`06I11I2001 Trial, Day 3
`
`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.
`
`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 -9
`
`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?
`
`10
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`11
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`1:
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`13
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`14
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`23
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`24
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`-25‘
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`A. Yes..
`
`02/22/2002 8:56 AM
`
`39
`
`Oracle Ex. 1024, pg. 629
`
`Oracle Ex. 1024, pg. 629
`
`
`
`06/11/2001 Trial, Day 3
`
`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 33L
`
`Do you see that, sir?
`
`A.
`
`I see what are you referring to?
`
`Q. Well, it talks about
`
`the management stat
`
`ion 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.
`
`Q.
`
`Can I read the rest of that paragraph,
`
`sir?
`
`Sure.
`
`Do you have a copy of the patent?
`
`A. Yes,
`
`I do. This is which column?
`
`Q".
`
`A.
`
`Q.
`
`A.
`
`Column 4,
`
`line 33..
`
`Column 4?
`
`Column 4,
`
`line 33.
`
`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
`
`10
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`11
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`02/22/2002 8:56 AM
`
`40
`
`Oracle Ex. 1024, pg. 630
`
`Oracle Ex. 1024, pg. 630
`
`
`
`06/11/2001 Trial, Day 3
`
`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.
`
`Q.
`
`.
`
`No, sir.
`
`How is it different?
`
`A. vIt'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.
`
`1
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`2
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`3
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`4
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`5
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`21
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`22
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`23
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`24
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`25'
`
`02/22/2002 8:56 AM
`
`41
`
`Oracle Ex. 1024, pg. 631
`
`Oracle Ex. 1024, pg. 631
`
`
`
`06I11I2001 Trial, Day 3
`
`1
`
`2
`
`3
`
`4
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`5
`
`6
`
`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.
`
`7i
`
`Q.
`
`You could actually put it in more than one work station,
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`right?
`
`A. One could do that.
`
`Q.
`
`A.
`
`You could put it in all work stations, right?v
`
`If you wanted to do that.
`
`Q. And in that case, all hosts could get access, right?
`
`A. All hosts could -— would have the capability -- all hosts
`
`.14
`
`would be management stations.
`
`15
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`16
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`18
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`20
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`21
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`22
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`23
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`2 4
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`25
`
`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 .
`
`A.
`
`We 11 ,
`
`- -
`
`Itfs no different from having dedicated management
`
`02/22/2002 8:56 AM
`
`2
`
`42
`
`Oracle Ex. 1024, pg. 632
`
`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 wi1ly—ni11y
`
`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
`
`1
`
`2
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`3
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`4
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`5
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`_ 17
`
`the work station can —— is what can change the access control
`
`18
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`19
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`20
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`21
`
`22
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`23
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`24
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`25
`
`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
`
`A
`
`A
`
`43
`
`Oracle Ex. 1024, pg. 633
`
`Oracle Ex. 1024, pg. 633
`
`
`
`06/11/2001 Trial, Day 3
`
`1
`
`2
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`3
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`23
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`24
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`25
`
`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?
`
`I
`
`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‘
`
`44
`
`Oracle Ex. 1024, pg. 634
`
`Oracle Ex. 1024, pg. 634
`
`
`
`06/1112001 Trial, Day 3
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`1
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`3
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`19
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`21
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`22
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`23
`
`24
`
`25
`
`Q. Management station isn't in that claim,
`
`is it?
`
`A. 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.t They do not.
`
`Q. Could be set by the SCSI reserve command, right?
`
`A. No.
`
`Q. Why not?
`
`A.
`
`The SCSI reserve command being implemented according to
`
`the SCSI specification is not sufficient access control.
`
`Q. Why not?
`
`A. Because it does not provide the kind of access control
`
`02/22/2002 8:56 AM
`
`45
`
`Oracle Ex. 1024, pg. 635
`
`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?
`
`1
`
`2
`
`3
`
`4
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`02/22/2002 8:56 AM
`
`46
`
`Oracle Ex. 1024, pg. 636
`
`Oracle Ex. 1024, pg. 636
`
`
`
`06/11/2001 Trial, Day 3
`
`1
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`2
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`3
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`4
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`19
`
`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
`
`-20
`
`router the capability for doing the same kind of access
`
`21
`
`22
`
`23
`
`24
`
`25
`
`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
`
`47
`
`Oracle Ex. 1024, pg. 637
`
`Oracle Ex. 1024, pg. 637
`
`
`
`06/11/2001 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.
`
`'
`
`Q.
`
`A.
`
`Q.
`
`THE COURT:
`
`The objection's overruled.
`
`MR. BAHhER: Thank you, your Honor.
`(BY MR. BAHLER)
`Do you need the question again, sir?
`
`I'm not aware there was a question.
`
`Please repeat it.
`
`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
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`subsequent —— by other work stations will be prohibited from
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`accessing storage that is reserved,
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`right?
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`A. No, sir.
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`Q. Well,
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`is one of the reasons because those other work
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`stations can issue a reset?
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`A. According to the SCSI command, according to the SCSI
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`02/22/2002 8:56 AM
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`48
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`Oracle Ex. 1024, pg. 638
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`Oracle Ex. 1024, pg. 638
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`06/11I2001 Trial, Day 3
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`standard, any of those work stations could revoke the reserve
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`at any time. Therefore,
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`the capability for prohibiting access
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`does not exist within the router if you use SCSI reserve.
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`Q.
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`If the capability exists to override,
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`then there is no
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`access control.
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`Is that what you just said?
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`A.
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`If the capability -- if the access control inherently has
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`the capability to be overridden by any work station without
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`any further authority,
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`that is not access control.
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`Q. All right.
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`So if any work station can override the access
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`controls,
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`then there is no access control?
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`A. That's not what
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`I said.
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`Q. All right.
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`I couldn't understand completely and I
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`apologize. Maybe I'm thick this morning.
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`MR. ALCOCK: Your Honor, move to strike. That's not
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`‘appropriate.
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`THE COURT: Counsel, let's just calm down.
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`Q.
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`(BY MR. BAHLER) Could you explain that again, please?
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`A. What would you like for me to explain?
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`Q.
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`The part about where any —- well,
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`let me just start down
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`the same track, only differently. These work stations shown
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`in figure 3 could be configured to issue reserve commands,
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`right? Any one?
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`A.
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`SCSI reserve commands?
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`Q. Yes, sir.
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`A. Yes,
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`theyicould.
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`02/22/2002 8:56 AM
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`49
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`Oracle Ex. 1024, pg. 639
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`Oracle Ex. 1024, pg. 639
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`Q. And if the router were so programmed, work station A could
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`reserve for itself storage A and storage B and work station B
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`could reserve storage B, et Cetera.
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`In other words,
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`this
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`exact configuration shown in figure 3 could be established
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`“ using the SCSI reserve commands, correct?
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`A.
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`The configuration as described in the patent would not be
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`the same.
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`Q. Well, work station A could issue a reserve command and it
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`would be stored in the storage router and it would reserve for
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`work station A, work station A storage on storage device 62,
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`right?
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`A. That is not acce