`
`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. 7,934,041
`
`____________
`
`PETITION FOR INTER PARTES REVIEW
`
`

`

`TABLE OF CONTENTS
`
`EXHIBIT LIST ........................................................................................................................ iv
`
`I. MANDATORY NOTICES ............................................................................................ 1
`A. Real Party-In-Interest .................................................................................................. 1
`B. Related Matters ............................................................................................................ 1
`C.
`Lead and Back-Up Counsel ....................................................................................... 1
`D.
`Service Information ..................................................................................................... 1
`
`II. PAYMENT OF FEES ...................................................................................................... 2
`
`III. REQUIREMENTS FOR INTER PARTES REVIEW .......................................... 2
`A. Grounds for Standing ................................................................................................. 2
`B.
`Identification of Challenge ......................................................................................... 2
`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 ........................................................................................ 3
`
`IV. BROADEST REASONABLE CONSTRUCTION ................................................ 4
`
`1.
`2.
`3.
`4.
`
`V. GROUNDS OF UNPATENTABILITY ................................................................... 6
`A. Claims 1-53 are Rendered Obvious by 35 U.S.C. § 103(a) by CRD-5500 User
`Manual in view of CRD-5500 Data Sheet and Smith ............................................ 6
`Introduction of the CRD-5500 References ......................................................... 6
`Introduction of the Smith Reference ..................................................................... 9
`Level of Skill in the Art ......................................................................................... 10
`The Combined System of CRD-5500 User Manual, CRD-5500 Data Sheet
`and Smith ................................................................................................................ 10
`Correspondence Between Claims 1-53 and the CRD-5500 User Manual,
`CRD-5500 Data Sheet and Smith ........................................................................... 12
`Secondary Indicia of Nonobviousness ............................................................... 24
`6.
`B. Claims 1-53 Are Rendered Obvious by Kikuchi taken in Combination with
`
`5.
`
`
`
`ii
`
`

`

`Bergsten ................................................................................................................................. 24
`1.
`Introduction of the Kikuchi Reference .............................................................. 24
`2.
`Introduction of the Bergsten Reference ............................................................. 25
`3.
`The Combined System of Kikuchi and Bergsten ............................................. 27
`4.
`Correspondence Between Claims 1-53 and Kikuchi and Bergsten ............... 30
`C. Claims 1-53 Are Rendered Obvious by Bergsten taken in Combination with
`Hirai ............................................................................................................................. 42
`Introduction of the Hirai Reference ................................................................... 42
`The Combined System of Bergsten and Hirai ................................................... 44
`Correspondence Between Claims 1-53 and Bergsten and Hirai ..................... 47
`
`1.
`2.
`3.
`
`VI. EXPLANATION OF NON-REDUNDANCY .................................................... 57
`
`VII. EARLIER PROCEEDINGS AND 35 U.S.C. §325(D) ..................................... 58
`
`VIII. CONCLUSION ........................................................................................................ 59
`
`
`
`
`
`
`
`
`iii
`
`

`

`EXHIBIT LIST
`
`U.S. Patent No. 7,934,041 (“the ‘041 Patent”)
`
`Select Portions of File History of the ‘041 Patent
`
`CRD-4400 SCSI RAID Controller User’s Manual (“CRD-5500 User
`Manual”)
`
`CRD-4400 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
`
`1001
`1002
`1003
`
`1004
`
`1005
`
`1006
`1007
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`
`
`

`

`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
`
`(SUBSTITUTE. Storagepath Fibre Channel Drive System, SWS/Storagepath,
`available at
`web.archive.org/web/19970114010450/http://www.storagepath.com/fi
`bre.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
`
`1035
`
`1036
`
`1037
`
`Deel et al., Moving Uncompressed Video Faster Than Real Time, Society of
`Motion Picture and Television Engineers, Inc., December 1996
`
`(SUBSTITUTE. Emulex LightPulse Fibre Channel PCI Host Adapter,
`Emulex Corporation, available at
`web.archive.org/web/19980213052222/http://www.emulex.com/fc/lig
`htpulse2.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. 6,425,035)
`
`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-00895Asserting
`Infringement of the ‘041 Patent
`
`Litigation Complaint in Crossroads Systems, Inc. v. Huawei Technologies Co.
`Ltd. et al., W.D.Tex, Case No. 1-13-cv-01025 Asserting Infringement of
`the ‘041 Patent
`
`Litigation Complaint in Crossroads Systems, Inc. v. NetApp, Inc., W.D.Tex,
`Case No. 1-14-cv-00149 Asserting Infringement of the ‘041 Patent
`
`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 provide 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 ‘041 Patent is
`
`asserted in co-pending litigation matters 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 ‘041 patent is also
`
`the subject IPR2014-01177 (not instituted due to incorporation by reference from
`
`the expert declaration) and IPR2014-01463 (pending). 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).
`
`D. Service Information
`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 Email: cpdocketgardella@oblon.com,
`cpdocketmckeown@oblon.com
`(703) 413-3000 / (703) 413-2220
`
`Tel./Fax:
`
`II.
`
`PAYMENT OF FEES
`The undersigned authorizes the Office to charge to Deposit Account No. 15-
`
`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 ‘041 Patent is satisfied.
`
`
`A. Grounds for Standing
`Petitioner certifies that is not estopped or barred from requesting inter partes
`
`review of the ‘041 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).
`
`B. Identification of Challenge
`Pursuant to 37 C.F.R. §§ 42.104(b) and (b)(1), Petitioner requests inter partes
`
`
`
`2
`
`

`

`review of claims 1-53 of the ‘041 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 ‘041 Patent is
`
`requested in view of the following grounds:
`
`(a) Claims 1-53 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 1-53 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
`
`(c) Claims 1-53 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).
`
`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 1-53 of
`
`the ‘041 Patent are unpatentable, including the identification of where each claim
`
`
`
`3
`
`

`

`element is found in the prior art, is provided in Section V 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 V.
`
`IV. BROADEST REASONABLE CONSTRUCTION
`Petitioner bases this petition upon the broadest reasonable interpretation of
`
`the claim language. All claimed terms not specifically addressed in this section have
`
`been accorded their broadest reasonable interpretation in light of the patent
`
`specification 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 U.S. Patent and Trademark Office (“USPTO”). Any
`
`claim construction offered by Petitioner in this petition is directed to 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 specification as being
`
`distinct from higher-level protocols that require translation to NLLBP. Ex. 1001 at
`
`
`
`4
`
`

`

`1:43-56; 3:43-54; 5:29-33. Examples of NLLBPs in the ‘041 Patent include SCSI-2
`
`commands and SCSI-3 Fibre Channel Protocol (FCP) commands. See e.g., id. at 6:56-
`
`7:13. The specification 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 2:12-14.
`
`During the reexamination of the grandparent patent the Patent Owner argued
`
`that a NLLBP is “a set of rules or standards that enable computers to exchange
`
`information and do not involve 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 v. Pathlight Technology, Inc., Civil
`
`Action No. A-00CA- 248-JN. 35 U.S.C. §301(a)(2); Ex. 1025 at 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, Id. at
`
`NIRC a tp. 3.
`
`For the foregoing reasons, the broadest reasonable interpretation of NLLBP
`
`includes a protocol, such as SCSI command protocol, that enables the exchange of
`
`information without the overhead of high-level protocols and file systems typically
`
`required by network servers.
`
`
`
`5
`
`

`

`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 1-53 are Rendered Obvious by 35 U.S.C. § 103(a) by
`CRD-5500 User Manual in view of 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 ‘041 Patent
`
`(December 31, 1997). Therefore, the CRD-5500 User Manual and CRD- 5500 Data
`
`Sheet are prior art to the ‘041 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
`
`demonstrating that the document is a publication by CMD Technology, Inc.
`
`released on a date certain. Furthermore the CRD-5500 Data Sheet is authenticated by
`
`
`
`6
`
`

`

`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; see also id. at 110; 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 “Host LUN” (logical unit number, an addressing mechanism). See
`
`
`
`7
`
`

`

`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 high
`speed serial interfaces, such as Fibrechannel (FCAL)[].
`
`
`
`8
`
`

`

`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 ‘041 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 ‘041 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 ‘041 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 ¶¶41-45. 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 Sheet’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 ¶ 47. Professor Chase explains that the Tachyon chip
`
`encapsulates and de-encapsulates SCSI commands on FC transport media that
`
`enables bridging to SCSI transport media. See e.g., id. ¶ 36, 38, 40, 43- 45; Ex. 1005 at
`
`pp. 4, 9, and 10; see also Ex. 1004 at pp. 1-2. The CRD- 5500 controller, in the
`
`combined system, is configured to provide virtual local storage to up to four Fibre
`
`Channel host interface modules (each interfacing with a host computing device)
`
`through the “Host LUN Mapping” feature. See e.g., id. ¶ 37, 43-44, 46. A figure
`
`representing the combined
`
`system is shown at right. See
`
`e.g., Ex. 1003 at Fig. 1-2.
`
`In operation, the
`
`CRD-5500 controller
`
`coordinates the following
`
`process for managing a host
`
`storage command. Ex. 1010
`
`
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`11
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`

`

`¶¶44, 45. A FCP packet containing a SCSI storage access command (e.g., read or
`
`write request) is transmitted to the CRD-5500 controller by a host. Id. At the host
`
`interface module, the Tachyon chip de-encapsulates the FCP packet to access the
`
`SCSI command. Id. The host identity can be derived from either the incoming packet
`
`(e.g., FCP header or SCSI header) or the channel of the host module slot receiving
`
`the communication, if recognized. Id. The Tachyon chip pulls the host’s storage
`
`address (e.g., LUN-based address) from the FCP header and passes the host identity
`
`and storage address as well as the SCSI payload to the CRD-5500 processor, where
`
`the host information is cross-referenced with the “Host LUN Mapping” maintained
`
`by the CRD-5500 controller to identify a redundancy group of the RAID storage
`
`disk array corresponding to the host storage address. Id. The CRD-5500 controller
`
`routes the SCSI command to the corresponding disk drive in the RAID array where
`
`the command is acted upon. Id.
`
`5. Correspondence Between Claims 1-53 and the
`CRD-5500 User Manual, CRD-5500 Data Sheet
`and Smith
`The discussion below demonstrates the correspondence between the claim
`
`terms and the CRD-5500 User Manual, CRD-5500 Data Sheet, and Smith.
`
`1. a. A storage router for providing virtual local storage on remote storage devices,
`comprising:
`The CRD-5500 Manual discloses this limitation because it teaches a CRD-
`
`5500 RAID controller that routes data between host computers and SCSI disk
`
`
`
`12
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`

`

`arrays. Ex. 1003 at 1-1, 1-4, 1-5 and 2-4. As discussed above, one or more
`
`redundancy groups can be created. Each redundancy group can be assigned a SCSI
`
`disk. Ex. 1003 at 1-5. An example of groupings of physical disk drives into
`
`redundancy groups is illustrated in Fig. 1-1 of the CRD-5500 User Manual
`
`(reproduced below). See id. at 1-1, 1-2. This provides a “virtual storage” region on
`
`each disk. Further, as detailed previously, the configuration provides for mapping the
`
`redundancy groups to host LUN addresses to provide the hosts with addressing
`
`capability to each redundancy group. See id. at 1-1, 4-5. As discussed above, the “Host
`
`LUN Mapping” utility of the CRD-5500 controller allows an administrator to assign
`
`RAID redundancy groups to host LUN addresses to provide the hosts with virtual
`
`local addressing capability to the remote storage partitions such that, from the
`
`viewpoint of the host, the remote storage device is local storage. Ex. 1003 at 1-1, 4-5;
`
`see also Ex. 1010 ¶¶46-52.
`
`b) a first controller operable to interface with a first transport medium, wherein the first
`medium is a serial transport media; and
`
`The CRD-5500 as modified by Smith includes “a first controller” created
`
`through the incorporation of the Tachyon chip into a Fibre Channel host interface
`
`module designed for installation in a host I/O slot of the CRD-5500 controller, as
`
`detailed above. Ex. 1003, p. 1-1, 2-1, 2-4, 3-1. The “first controller” is “operable to
`
`interface with a first transport medium” (FC medium), and “the first medium is a
`
`serial transport media.” Fibre Channel is a serial transport protocol. Ex. 1001 at
`
`
`
`13
`
`

`

`1:54-60. As illustrated in Fig. 8 of Smith, for example, the Tachyon would interface
`
`with a SCSI transport medium via the host-based data structures, while the frame
`
`manager module of the Tachyon would interface with the FC transport medium
`
`(illustrated as the “Link”). Ex. 1005 at 8, Ex. 1010 ¶47. Professor Chase explains in
`
`his declaration that in the combined system, the FC-enabled host device interface
`
`module installed in the CRD-5500 controller is coupled to Fibre Channel, a serial
`
`transport media, on the host side. (See e.g., Ex. 1010 at ¶¶ 36, 47)
`
`c) a processing device coupled to the first controller,
`
`The CRD-5500 as modified by Smith includes “a processing device” coupled
`
`to the first controller. Ex. 1003 at 1-1, 1-3, 2-1, and Fig. 2-1. The Tachyon would
`
`interface with the MIPS R3000 RISC CPU of the CRD-5500 controller. Ex. 1003 at
`
`1-3. Further, as explained above, a portion of the processing capability may be
`
`resident upon any or all of the interface modules installed in the nine I/O slots of the
`
`CRD-5500 Controller. See also discussion at 1010 ¶48.
`
`d) wherein the processing device is configured to maintain a map to allocate storage
`space on the remote storage devices to devices connected to the first transport medium
`by associating representations of the devices connected to the first transport medium
`with representations of storage space on the remote storage devices,
`
`As described above, each redundancy group can be assigned a remote disk
`
`storage device. Ex. 1003 at 1-1, 1-2. The LUN mapping feature of the CRD-5500
`
`can associate the redundancy groups with host devices. Ex. 1003 at 1-1, 4-5. As
`
`illustrated in the Host LUN Mapping utility (Id. at 4-5), the map associates storage
`
`
`
`14
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`

`

`space on the remote disks assigned to the redundancy groups to “devices connected
`
`to the first transport medium by associating representations of the devices connected
`
`to the first transport medium with representations of storage space on the remote
`
`storage devices.” See also Ex. 1010 ¶49.
`
`e) wherein each representation of a device connected to the first transport medium is
`associated with one or more representations of storage space on the remote storage
`devices;
`
`In the example of a first device connected to the first transport medium (e.g.,
`
`the host at Channel 0), the host device is represented by Channel 0, and the storage
`
`space is represented by a series of RAID redundancy groups (e.g., “one or more
`
`representations of storage space on the remote storage devices”) including
`
`redundancy groups 0, 1, 5, and 6 through 31. Ex. 1003 at 1-2, 4-5. Similar mappings
`
`can be configured for the remaining two to four hosts connected to the CRD-5500
`
`controller. Id.; see also Ex. 1010 ¶51.
`
`f) control access from the devices connected to the first transport
`medium to the storage space on the remote storage devices in accordance with the
`map; and
`
`The CRD-5500’s processing device (discussed above) uses the map to
`
`“control access from the devices connected to the first transport medium to the
`
`storage space on the remote storage devices” by accepting only host LUN addresses
`
`for which a mapping to a redundancy group exists and is associated with the
`
`requesting host. Ex. 1003 at 1-1, 4-5. As described by the CRD-5500 User Manual,
`
`
`
`15
`
`

`

`for example, the Host LUN Mapping utility allows an administrator to prevent a
`
`particular redundancy group from being visible to a particular host, effectively
`
`blocking access to that storage region by the particular host. See id. at 4-5; see also Ex.
`
`1010 ¶51.
`
`g) allow access from devices connected to the first transport medium to
`the remote storage devices using native low level block protocol.
`
`The CRD-5500’s processing device (discussed above) “allow[s] access from
`
`devices connected to the first transport medium to the remote storage devices using
`
`native low level block protocol.” Ex. 1003 at 4-18. Through the LUN Mapping
`
`utility of the CRD-5500 controller, a host device addresses remote RAID storage
`
`regions through LUN addressing, an addressing mechanism used to allow host
`
`devices to access and address storage as though it were local storage. See, e.g., id. at 4-
`
`10. The native low level block protocol carrying the LUN address is the FC or FCP
`
`protocol. See, e.g., Ex. 1001 at 8:22-25, claim 8. The CRD-5500, using the Host LUN
`
`Mapping, identifies a RAID redundancy group mapped to the LUN identified within
`
`the FCP request for