UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`
`
`CISCO SYSTEMS, INC. AND QUANTUM CORPORATION,
`Petitioners,
`
`v.
`
`CROSSROADS SYSTEMS, INC.,
`Patent Owner
`
`———————
`
`
`
`PETITION FOR INTER PARTES REVIEW
`
`OF
`
`U.S. PATENT NO. 7,934,041
`
`
`
`
`
`
`
`1 of 65
`
`CROSSROADS EXHIBIT
`Oracle Corp. v. Crossroads Systems, Inc.
`IPR2015-0(cid:1005)(cid:1004)(cid:1010)(cid:1010)
`
`2147
`
`

`
`TABLE OF CONTENTS
`
`I.  Mandatory Notices ............................................................................................. 1 
`
`A.  Real Party-in-Interest ................................................................................ 1 
`
`B.  Related Matters ......................................................................................... 1 
`
`C.  Lead and Back-up Counsel and Service Information .............................. 2 
`
`II.  Grounds for Standing ......................................................................................... 2 
`
`III.  Relief Requested ................................................................................................ 2 
`
`IV.  The Reasons for the Requested Relief ............................................................... 3 
`
`A.  Summary of Reasons ................................................................................ 3 
`
`B.  The ’041 Patent ......................................................................................... 4 
`
`1.  Overview .......................................................................................... 4 
`
`2. 
`
`Prosecution History .......................................................................... 8 
`
`C. 
`
`Identification of Challenges ..................................................................... 9 
`
`1.  Challenged Claims ........................................................................... 9 
`
`2. 
`
`Statutory Grounds for Challenges .................................................... 9 
`
`3.  Claim Construction ........................................................................ 10 
`
`i. 
`
`ii. 
`
`“native low level block protocol” ........................................... 11 
`
`“remote” .................................................................................. 12 
`
`4. 
`
`Identification of How the Claims Are Unpatentable ..................... 13 
`
`i. 
`
`Challenge #1: Claims 1-14, 16-33, 35-50 and 53 are obvious
`over the CRD Manual in view of the HP Journal ................... 13 
`
`
`
`
`
`2 of 65
`
`

`
`ii.  Challenge #2: Claims 15, 34, 51, 52 are obvious over the CRD
`Manual in view of the HP Journal and in further view of the
`Fibre Channel Standard .......................................................... 56 
`
`V.  Conclusion ....................................................................................................... 60 
`
`
`
`
`
`3 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`I. Mandatory Notices
`A. Real Party-in-Interest
`The real parties-in-interest are Cisco Systems, Inc. and Quantum
`
`Corporation (“Petitioners”).
`
`B. Related Matters
`Petition for Inter Partes Review, IPR2014-01177, filed July 18, 2014;
`
`Crossroads Systems, Inc. v. Quantum Corporation, 1-14-cv-00150, TXWD, filed
`
`February 18, 2014; Crossroads Systems, Inc. v. NetApp, Inc., 1-14-cv-00149,
`
`TXWD, filed February 18, 2014; Crossroads Systems, Inc. v. Cisco Systems, Inc.,
`
`1-14-cv-00148, TXWD, filed February 18, 2014; Crossroads Systems, Inc. v.
`
`Huawei Technologies Co. Ltd. et al, 1-13-cv-01025, TXWD, filed November 26,
`
`2013; Crossroads Systems, Inc. v. Oracle Corporation, 1-13-cv-00895, TXWD,
`
`filed October 7, 2013. Also, (i) case nos. IPR2014-01197 (filed July 23, 2014) and
`
`IPR2014-01226 (filed July 31, 2014) have been filed against U.S. Patent No.
`
`6,425,035, which is related to the ’041 patent; and (ii) case nos. IPR2014-01207
`
`(filed July 25, 2014) and IPR2014-01209 (filed July 25, 2014) have been filed
`
`against U.S. Patent No. 7,051,147, which is related to the ‘041 patent.
`
`Additionally, this petition refers to a claim construction order from Crossroads
`
`Systems, Inc. v. 3PAR, Inc., et. al., no. 1-10-cv-00652 (W.D. Tex. 2010), which is
`
`one of the district court litigations involving U.S. Patent No. 6,425,035, which is
`
`related to the ’041 patent.
`
`
`
`1
`
`4 of 65
`
`

`
`
`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`C. Lead and Back-up Counsel and Service Information
`Lead Counsel
`
`David L. McCombs
`Phone: (214) 651-5533
`HAYNES AND BOONE, LLP
`Fax: (214) 200-0853
`2323 Victory Ave. Suite 700
`david.mccombs.ipr@haynesboone.com
`Dallas, TX 75219
`USPTO Reg. No. 32,271
`
`Back-up Counsel
`Andrew S. Ehmke
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`Scott T. Jarratt
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`II. Grounds for Standing
`Petitioners certify that they are not estopped or barred from requesting inter
`
`
`
`Phone: (214) 651-5116
`Fax: (214) 200-0853
`andy.ehmke.ipr@haynesboone.com
`USPTO Reg. No. 50,271
`
`Phone: (972) 739-8663
`Fax: (214) 200-0853
`scott.jarratt.ipr@haynesboone.com
`USPTO Reg. No. 70,297
`
`
`partes review of the ’041 Patent. Petitioners were each served with a complaint
`
`asserting infringement of the ’041 Patent on February 18, 2014, which is not more
`
`than one year before the filing of this Petition. Neither petitioner has initiated a
`
`civil action challenging the validity of any claim of the ’041 Patent. Petitioners
`
`also certify that the ’041 Patent is eligible for inter partes review.
`
`III. Relief Requested
`Petitioners ask that the Patent Trial and Appeal Board (“the Board”) review
`
`the accompanying prior art and analysis, institute a trial for inter partes review of
`
`claims 1-53 (all claims) of the ’041 Patent, and cancel those claims as invalid.
`
`
`
`2
`
`5 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`IV. The Reasons for the Requested Relief
`The full statement of the reasons for the relief requested is as follows:
`
`A.
`
`Summary of Reasons
`In short, the claims of the ’041 Patent simply recite obvious combinations of
`
`network storage components with functionality that was well-known at the time of
`
`the ’041 Patent invention. For example, each of the ’041 Patent’s three
`
`independent claims generally include limitations directed to (i) mapping
`
`workstations on one side of a storage router to specific storage devices on the other
`
`side of the storage router, and (ii) routing block-level data between the
`
`workstations and the storage devices based on the mapping so that the workstations
`
`may only access the particular storage devices to which they are mapped. In one
`
`embodiment of the ’041 specification, the storage router is a bridge between
`
`workstations on a Fiber Channel link and storage devices on a SCSI bus, and the
`
`block-level data flowing between the workstations and storage devices conforms to
`
`the SCSI protocol. CQ-1001, 5:34-63; Fig. 3.
`
`These elements were well known in the prior art. For example, in 1996,
`
`CMD Technologies sold a storage router, the CRD-5500 SCSI RAID Controller,
`
`that performed the functions recited in the claims. According to the CRD-5500
`
`user’s manual, the CRD-5500 Controller (i) allows users to map hosts on one side
`
`of the controller to specific storage devices on the other side of the controller and
`
`then (ii) routes SCSI commands from hosts to storage devices based on the map,
`3
`
`
`
`6 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`while blocking hosts from accessing storage devices to which they were not
`
`mapped. CQ-1004, pp. 1-1, 1-2, 1-11, 4-2, 4-5.
`
`In one configuration, the CRD-5500 Controller routes data between hosts on
`
`a SCSI bus link and storage devices on a SCSI bus link; however, the CRD-5500
`
`Controller was designed to support serial links through the use of different I/O
`
`adapter cards. CQ-1004, pp. 1-1, 2-1, 2-4; CQ-1005, p. 1. One of ordinary skill in
`
`the art at the time of the ’041 Patent would have been motivated to modify the
`
`CRD-5500 Controller using different I/O adapter cards to take advantage of the
`
`benefits of other communications links, such as Fibre Channel. CQ-1003, pp. 31-
`
`36. Fiber Channel was known to alleviate the limitations of SCSI buses (the default
`
`CRD-5500 configuration). CQ-1006, pp. 5, 94, 99.
`
`Consequently, this petition demonstrates that claims 1-53 merely recite
`
`features that were well known in the prior art and are therefore rendered obvious
`
`over the references presented in this petition.
`
`B.
`
`The ’041 Patent
`1. Overview
`The ’041 Patent has three independent claims (claims 1, 20, and 37) and a
`
`total of 53 claims. The ’041 Patent generally describes a “storage router” that
`
`routes storage requests between workstations and storage devices. CQ-1001,
`
`Abstract. Figure 3 of the ’041 Patent illustrates the architecture of the storage
`
`network in which the storage router operates:
`4
`
`
`
`7 of 65
`
`

`
`
`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`Storage Router
`
`SCSI Bus
`
`Workstations
`
`Fibre Channel
`link
`
`CQ-1001, Fig. 3 (annotated);
`CQ-1003, p. 13
`
`Storage devices
`
`
`
`As shown in Fig. 3, workstations on a Fiber Channel link (i.e., a transport
`
`medium) are connected to one side of the storage router (the “host side”), and
`
`storage devices on the SCSI bus communication link are connected to the other
`
`side of the storage router (the “disk side”). CQ-1001, 4:25-34. The specification
`
`describes the storage router as “a bridge device that connects a Fiber Channel link
`
`directly to a SCSI bus.” Id. at 5:59-62.
`
`According to the specification, a “SCSI command” is an example of a native
`
`low level block protocol command and the storage router enables the exchange of
`
`SCSI commands and data between the workstations and the storage devices. Id. at
`
`5:61-63. Additionally, the specification states that Fiber Channel-based
`
`workstations on one side of the storage router may communicate with SCSI-based
`
`storage devices on the other side of the storage router by encapsulating SCSI
`
`commands into Fiber Channel Protocol (FCP) requests. Id. at 6:43-55. As
`
`discussed below in more detail, encapsulating SCSI commands inside a Fiber
`
`
`
`5
`
`8 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`Channel request was a feature of the Fibre Channel standard, and was well known
`
`in the art at the time of the ’041 invention. See CQ-1006, pp. 94-95.
`
`The specification states that the storage router uses “mapping tables” to
`
`allocate subsets of storage space (e.g., partitions) on the storage devices to
`
`particular workstations. CQ-1001, 4:39-44. For example, referring to Fig. 3,
`
`“[s]torage device 62 can be configured to provide partitioned subsets 66, 68, 70
`
`and 72, where each partition is allocated to one of the workstations 58.” Id. at 4:47-
`
`49. Also, the specification states that the storage router provides “virtual local
`
`storage” such that a mapped partition is “considered by the workstation 58 to be its
`
`local storage”—i.e., the mapped partition “has the appearance and characteristics
`
`of local storage.” Id. at 4:4-14, 4:39-40. As discussed below in more detail, it was
`
`well known in the art at the time of the ’041 invention to map workstations on one
`
`side of a storage router to partitions on the other side of the storage router, and to
`
`make the partitions appear as local disks. See CQ-1004, pp. 1-2, 3-6, 4-5.
`
`According to the specification, the storage router uses the mapping
`
`functionality to facilitate both routing and access control. CQ-1001, 5:50-54. For
`
`routing, the specification states that the map between the initiators and the specific
`
`subsets of storage allows the storage router to determine “what partition is being
`
`addressed by a particular request,” thus enabling it to “distribute[] requests and
`
`data” to storage devices Id. at 9:21-27, 4:18-19. For access control, the
`
`
`
`6
`
`9 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`specification states that the storage router prevents a workstation from accessing a
`
`subset of storage not allocated to it in the map. Id. at 9:15-27. For example, in Fig.
`
`3, “subsets 66, 68, 70 and 72 can only be accessed by the associated workstation
`
`58.” Id. at 4:50-51. As discussed below in more detail, the concept of using a map
`
`to facilitate routing and access control of storage devices was well known in the art
`
`at the time of the ’041 Patent invention. See CQ-1004, pp. 1-2, 4-5.
`
`To illustrate the general flow of I/O commands in the storage network of the
`
`’041 Patent, Fig. 3 is further annotated below:
`
`(i) workstation B sends
`a SCSI I/O command
`to its “virtual local
`storage”
`
`(ii) storage router uses map to
`determine which partition is
`allocated to workstation B
`
`CQ-1001, Fig. 3 (annotated);
`CQ-1003, p. 15
`
`(iii) partition mapped to workstation
`B receives SCSI I/O command
`
`
`
`In addition to the mode of operation shown associated with Fig. 3, the ’041
`
`specification notes that the “storage router has various modes of operation,”
`
`including a mode in which the storage router routes data between a Fibre Channel
`
`host and a Fibre Channel storage device. CQ-1001, 6:43-46.
`
`Because communicating SCSI commands over Fibre Channel, mapping
`
`workstations to storage partitions, and using the mapping for routing and access
`7
`
`
`
`10 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`control were well known in the art at the time of the ’041 invention, the storage
`
`network described by the ’041 Patent is simply a collection of components that
`
`were well known in the art at the time of the ’041 Patent invention. CQ-1003, ¶ 20-
`
`21. And, as shown below, these well-known components are arranged in a manner
`
`that would have been obvious to one of ordinary skill in the art. Id.
`
`2.
`Prosecution History
`The ’041 Patent issued on April 26, 2011, from U.S. Patent Application No.
`
`12/690,592 (“the ’592 application”) filed on Jan. 20, 2010 by Geoffrey B. Hoese
`
`and Jeffry T. Russell. The ’041 Patent is purportedly a continuation of a string of
`
`patent applications claiming priority to U.S. patent application Ser. No.
`
`09/001,799, filed on Dec. 31, 1997.
`
`During the prosecution of the ’592 application, Patent Owner, in response to
`
`a double patenting rejection over “all of the related Patent/Applications,” filed a
`
`Terminal Disclaimer disclaiming any patent term extending beyond the life of 12
`
`U.S. Patents and 10 pending-at-the-time U.S. Patent Applications. CQ-1002, pp.
`
`1647-48, 1689-99. The Examiner then issued a Notice of Allowance without a
`
`substantive rejection of the claims. CQ-1002, 1722-25.
`
`Based on the above, it appears that during the course of the prosecution of
`
`the ’041 Patent, the Patent Office never substantively considered the relevance of
`
`the CRD Manual, the HP Journal, or the Fibre Channel Standard to the claims.
`
`
`
`8
`
`11 of 65
`
`

`
`
`C.
`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`Identification of Challenges
`1.
`Challenged Claims
`Claims 1-53 of the ’041 Patent are challenged in this petition.
`
`2.
`Statutory Grounds for Challenges
`Challenge #1: Claims 1-14, 16-33, 35-50 and 53 are obvious under 35 U.S.C. §
`
`103(a) over the CRD-5500 SCSI Raid Controller User's Manual (“CRD Manual”)
`
`in view of Volume 47, issue 5 of the Hewlett-Packard Journal (“HP Journal”). The
`
`CRD Manual is dated November 21, 1996 and was available for public download
`
`from the CMD Technologies website at least by December 26, 19961, and is thus
`
`prior art under 35 U.S.C. § 102(b). The HP Journal was published in October 1996,
`
`and the HP Journal Online website notes that the “HP Journal has been available
`
`
`1 The CRD Manual was archived on by December 26, 1996 by the Internet Archive
`
`Wayback Machine and is available at
`
`http://web.archive.org/web/19961226085953/http://www.cmd.com/ftproot/pub/rai
`
`d/5500/manual/crd5500user.pdf. “Prior art disclosures on the Internet or on an on-
`
`line database are considered to be publicly available as of the date the item was
`
`publicly posted.” MPEP § 2128. The PTO identifies the Internet Archive Wayback
`
`Machine as a mechanism for determining the publication date of electronic
`
`documents such as those from the Internet. See,
`
`http://uspto.gov/patents/resources/methods/aiplafall02paper.jsp.
`
`
`
`
`
`9
`
`12 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`on the World Wide Web since early 1994.” See CQ-1011. The HP Journal is thus
`
`prior art under 35 U.S.C. § 102(b).
`
`Challenge #2: Claims 15, 34, 51 and 52 are obvious under 35 U.S.C. § 103(a) over
`
`the CRD Manual and the HP Journal, further view of the Fibre Channel Physical
`
`and Signaling Interface (FC-PH) X3.230 (“Fibre Channel Standard”). The Fibre
`
`Channel Standard is dated June 1, 1994 and was published by the American
`
`National Standards Institute. Thus, it is prior art under 35 U.S.C. § 102(b).
`
`3.
`Claim Construction
`This petition presents claim analysis in a manner that is consistent with the
`
`broadest reasonable construction in light of the specification. See 37 C.F.R. §
`
`42.100(b). Under the broadest reasonable construction, claim terms are given their
`
`ordinary and accustomed meaning as would be understood by one of ordinary skill
`
`in the art in the context of the entire disclosure. In re Translogic Tech., Inc., 504
`
`F.3d 1249, 1257 (Fed. Cir. 2007). Additionally, because the claim constructions
`
`proposed herein are based on the broadest reasonable construction, they do not
`
`necessarily apply to other proceedings that use different claim construction
`
`standards. See Samsung Electronics Co., Ltd v. Virginia Innovation Sciences, Inc.,
`
`IPR2013-00569, Paper 9 at *2, Oct. 30, 2013 (“[B]ecause the Board applies the
`
`broadest reasonable construction standard, the Board’s construction may not be the
`
`same as that adopted by a district court, which may apply a different standard.”).
`
`
`
`10
`
`13 of 65
`
`

`
`
`
`i.
`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`“native low level block protocol”
`This claim term is found in claims 1, 6, 20, 25, 37 and 42. In the Crossroads
`
`Systems, Inc. v. 3PAR litigation2 (in connection with related U.S. Patent No.
`
`6,425,035), the District Court construed “native low level block protocol” to mean
`
`“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.” CQ-1010, p. 13.
`
`The specification does not provide an explicit definition of “native low level
`
`block protocol.” The specification, however, contrasts a workstation accessing “a
`
`local storage device” using “native low level, block protocols” with a workstation
`
`accessing network-based storage devices through a “network server” which
`
`“implements a file system and transfers data to workstations 12 only through high
`
`level file system protocols.” CQ-1001, 3:46-50. With reference to Fig. 3, the
`
`specification states that subsets 66, 68, 70, and 72 of storage space are “accessed
`
`using native low level, block protocols” and that “storage access involves native
`
`low level, block protocols.” Id. at 4:47-53. One example in the specification of a
`
`native low level block protocol command is a “SCSI command.” Id. at 5:59-63.
`
`Thus, based upon the plain language of the claims and consistent with the
`
`
`2 Crossroads Systems, Inc. v. 3PAR, Inc., et. al., no. 1-10-cv-00652 (W.D. Tex.
`
`2010).
`
`
`
`11
`
`14 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`specification, one of ordinary skill in the art would understand the broadest
`
`reasonable construction of “native low level block protocol” to be “a protocol in
`
`which storage space is accessed at the block level, such as the SCSI protocol.”
`
`CQ-1003 at ¶¶ 27-31.
`
`Whether the District Court construction or the foregoing construction is
`
`applied, the prior art references relied upon in this petition teach this claim term.
`
`See CQ-1003, pp. 55-57, 62-64.
`
`ii.
`
` “remote”
`This term is found in claims 1-4, 7, 12, 13, 19-23, 26, 31, 32, 37-40, 43, 48,
`
`49 and 53. In the 3Par litigation (in connection with related U.S. Patent No.
`
`6,425,035), the District Court construed “remote” to mean “indirectly connected
`
`through at least one serial network transport medium.” CQ-1010, p. 12.
`
`The specification does not provide an explicit definition of “remote.” The
`
`specification does describe that “the storage space considered by the workstation
`
`58 to be its local storage is actually a partition (i.e., logical storage definition) of a
`
`physically remote storage device 60, 62 or 64 connected through storage router
`
`56.” CQ-1001, 5:8-14 (emphasis added). The specification also describes that
`
`“[t]ypical storage transport mediums provide for a relatively small number of
`
`devices to be attached over relatively short distances. One such transport medium
`
`is a Small Computer System Interface (SCSI) protocol.” Id. at 1:51-59.
`
`
`
`12
`
`15 of 65
`
`

`
`
`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`Thus, consistent with the surrounding language of the claims and the
`
`specification, one of ordinary skill in the art would understand the broadest
`
`reasonable construction of “remote” to be “indirectly connected through a storage
`
`router to enable connections to storage devices at a distance greater than allowed
`
`by a conventional parallel network interconnect.” CQ-1003 at ¶¶ 32-36.
`
`Whether the District Court construction or the foregoing construction is
`
`applied, the prior art references relied upon in this petition teach this claim term.
`
`See CQ-1003, pp. 39-40, 57, 90, 104-105.
`
`4.
`
`Identification of How the Claims Are Unpatentable
`i. Challenge #1: Claims 1-14, 16-33, 35-50 and 53 are obvious
`over the CRD Manual in view of the HP Journal
`(a)
`Summary of the CRD Manual
`The CRD Manual describes the features and operation of the CRD-5500
`
`SCSI RAID Controller. The CRD-5500 Controller routes commands and data
`
`between hosts (i.e., initiators) and storage devices (i.e., targets) coupled to the
`
`controller. CQ-1004, pp. 1-1, 1-4.
`
`Hosts attached to SCSI bus links are connected to the CRD-5500 Controller
`
`(the “host side”) and storage devices attached to SCSI bus links are connected to
`
`the CRD-5500 Controller (the “disk side”). Id. at p. 2-4. The CRD-5500 Controller
`
`enables the exchange of SCSI commands and data between the hosts and the
`
`storage devices. Id. at pp. 1-1, 1-4, 2-1, 2-4. Figure 1-2 in the CRD Manual
`
`
`
`13
`
`16 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`illustrates the storage network in which the CRD-5500 Controller operates:
`
`Hosts
`
`CRD-5500 Controller
`
`Host SCSI Buses
`
`Storage Device SCSI Buses
`
`CQ-1004, p. 1-2
`(annotated);
`CQ-1003, p. 25
`
`Storage
`d i
`
`The CRD-5500 Controller includes a Monitor Utility in its user-upgradeable
`
`firmware that gives a user “complete control over the configuration and operation
`
`of the controller.” CQ-1004, pp. 4-1, 4-14. The Monitor Utility includes a “Host
`
`LUN Mapping” feature that allows a user to map subsets of storage space on the
`
`storage devices (referred to as “redundancy groups”) to specific hosts. Id. at pp. 1-
`
`2, 1-11, 4-2, 4-5. A “LUN” is a logical unit number used to represent storage
`
`space. CQ-1003, p. 25. Specifically, as shown below, the Host LUN Mapping
`
`feature maintains a mapping table for each host, where each mapping table has a
`
`set of virtual LUNs (numbered 0-31) to which the redundancy groups are mapped.
`
`CQ-1004, pp. 1-2, 1-11, 4-2, 4-5. A host accesses the redundancy groups by
`
`referencing its virtual LUNs. Id. For example, in the below Host LUN Mapping
`
`configuration, the host associated with channel 0 may access redundancy group 5
`
`by addressing SCSI commands to LUN 4. CQ-1003, p. 26:
`
`
`
`14
`
`17 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`Mapping for
`the host
`associated
`with
`channel 0
`
`
`
`Redundancy
`groups (storage
`space)
`mapped to the
`host’s LUNs
`CQ-1004, p. 4-5
`(annotated);
`CQ-1003, p. 26
`
`
`
`
`
`As an aspect of this, each mapped redundancy group “will appear to the host as a
`
`different disk drive.” CQ-1004, p. 3-6.
`
`The CRD-5500 Controller uses the Host LUN Mapping tables to facilitate
`
`routing and access control. Figure 1-2 illustrates the general flow for routing
`
`commands from a host to a redundancy group:
`
`(i) host sends a SCSI I/O command to
`its “LUN 0”
`
`(ii) CRD-5500 uses a map to determine which
`redundancy group is mapped to LUN 0
`
`(iii) redundancy group mapped to LUN
`0 receives SCSI I/O command
`CQ-1004, Figure 1-2 (annotated); CQ-1003, p. 27
`
`Additionally, because a host transmits SCSI commands to its set of virtual
`
`LUNs rather than the physical storage devices, the CRD-5500 Controller can
`
`“make a redundancy group visible to one host but not to another.” CQ-1004, p. 1-
`
`1. For example, the CRD-5500 Controller “may make redundancy group 8
`
`
`
`15
`
`18 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`available on LUN 4 on host channel 0 and block access to it on host channel 1.” Id.
`
`at p. 4-5. Thus, the CRD-5500 not only routes commands, but can control access.
`
`Further, the CRD-5500 Controller includes numerous slots for I/O adapter
`
`cards through which the controller communicates with hosts and storage devices.
`
`CQ-1004, pp. 1-1, 2-1, 2-4. A key feature of the CRD-5500 Controller is that it
`
`“employs a modular design for maximum flexibility.” Id. at p. 1-1. Specifically,
`
`the controller’s slots accept different types of I/O adapter cards. Id. at pp. 1-1, 2-1,
`
`2-4. Figure 2-1 illustrates the modular nature of the controller:
`
`I/O adapter cards
`connected to SCSI buses
`
`Slots for additional
`I/O adapter cards
`
`CQ-1004, Figure 2-1 (annotated); CQ-1003, pg. 31
`
`
`
`Notably, the designers of the CRD-5500 Controller intended for the CRD-
`
`5500 to work not only with SCSI bus links but also with other types of
`
`communication links. A data sheet advertising the features of the CRD-5500
`
`Controller states that the controller’s “RAID architecture and ASICs were
`
`designed to support tomorrow's high speed serial interfaces, such as
`
`Fiberchannel (FCAL) and Serial Storage Architecture (SSA).” CQ-1005, p. 1
`
`(emphasis added).
`
`
`
`16
`
`19 of 65
`
`

`
`
`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`Summary of the HP Journal
`(b)
`Volume 47, issue 5 of the Hewlett-Packard Journal includes a number of
`
`articles that address the growing problem in 1997 of “I/O channels becom[ing]
`
`bottlenecks to system performance.” CQ-1006, p. 5. Specifically, one article in the
`
`issue provides an introduction to the Fibre Channel I/O interface and describes it as
`
`“a flexible, scalable, high-speed data transfer interface that can operate over a
`
`variety of both copper wire and optical fiber at data rates up to 250 times faster
`
`than existing communications interfaces.” Id. at p. 94. The article additionally
`
`provides many reasons a Fibre Channel communication link is superior to a SCSI
`
`bus (e.g., longer distances and higher bandwidth, smaller connectors). Id. at p. 94.
`
`It further notes that SCSI commands may be “encapsulated and transported within
`
`Fibre Channel frames” to support existing storage hardware. Id. at pp. 94-95.
`
`A second article in the same issue of the HP Journal describes a Fibre
`
`Channel protocol chip made by HP called “Tachyon.” CQ-1006, pp. 99-112. The
`
`article states that the Tachyon chip implements the Fibre Channel standard and
`
`“enables low-cost gigabit host adapters on industry-standard buses.” Id. at p. 101.
`
`Additionally, the article provides details about how to implement a Fibre Channel
`
`I/O adapter card that uses the Tachyon chip. Id. at p. 111.
`
`(c) Reasons to Combine the CRD Manual and the HP Journal
`One of ordinary skill in the art would have been motivated to combine the
`
`teachings of the CRD Manual and the HP Journal to replace the SCSI I/O host
`17
`
`
`
`20 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`modules in the CRD-5500 Controller with a Fibre Channel I/O host module. See
`
`CQ-1003 at ¶¶ 48-57.
`
`First, the CRD Manual teaches that the modular design of CRD-5500
`
`Controller accepts different types of modules to interface with different transport
`
`media. CQ-1004, pp. 1-1, 2-1. Persons of ordinary skill in the art were informed
`
`that the CRD-5500 Controller was specifically “designed to support tomorrow's
`
`high speed serial interfaces, such as Fiberchannel.” CQ-1005, p. 1.
`
`Second, the HP Journal teaches that “today’s parallel bus architectures are
`
`reaching their limits.” CQ-1006, p. 5. More specifically, the HP Journal teaches
`
`that there are a number of inherent limitations in the SCSI bus architecture that
`
`prevent it from “keeping pace with ever-increasing processor speeds and data rate
`
`requirements.” Id. at p. 99. The HP Journal further teaches that the Fibre Channel
`
`serial transport medium solves these limitations because its “increased bandwidth
`
`provides distance flexibility, increased addressability, and simplified cabling.” Id.
`
`at 99. In particular, the HP Journal teaches that Fibre Channel “can operate from
`
`2.5 to 250 times faster than existing communications interfaces” and that “[a]
`
`single 100-Mbyte/s Fibre Channel port can replace five 20-Mbyte/s SCSI ports, in
`
`terms of raw through put.” Id. at p. 94 (emphasis added). Additionally, “Fibre
`
`Channel resolves the ‘slots and watts’ problem” because Fibre Channel supports
`
`the same I/O services with fewer number of slots. Id. at 100, 101. Further, the HP
`
`
`
`18
`
`21 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`Journal notes that Fibre Channel is backwards compatible with SCSI-based
`
`hardware because SCSI commands may be “encapsulated and transported within
`
`Fibre Channel frames.” Id. at pp. 94-95; CQ-1003, ¶ 51.
`
`The HP Journal additionally teaches one of ordinary skill in the art how to
`
`implement a generic Fibre Channel I/O adapter board using the Tachyon chip. CQ-
`
`1006, pp. 101-111; Fig. 14. Notably, the Tachyon chip was designed to be “easily
`
`adaptable” to a variety of system types. Id. at p. 101; CQ-1003, ¶ 53.
`
`Given the teachings of the CRD Manual and the HP Journal, one of ordinary
`
`skill in the art would have been motivated to replace the SCSI I/O modules on the
`
`“host side” of the CRD-5500 Controller with a Fibre Channel I/O host module.
`
`CQ-1003, ¶ 53. In some instances, one of ordinary skill in the art would have also
`
`been motivated to replace the SCSI I/O modules on the “disk side” of the
`
`controller with one or more Fibre Channel I/O modules. Both substitutions would
`
`have been simple because (i) the CRD-5500 Controller has a modular design that
`
`accepts different types of I/O modules and (ii) the Tachyon Fibre Channel chip is
`
`“easily adaptable” to different systems. Id. Further, the HP Journal specifically
`
`teaches that a Fibre Channel I/O module was intended to “replace” SCSI I/O
`
`modules. A Fibre Channel-based I/O module would have allowed the CRD-5500
`
`Controller to communicate with hosts and/or disks via a Fibre Channel transport
`
`medium rather than via SCSI buses, thereby overcoming many of the known
`
`
`
`19
`
`22 of 65
`
`

`
`Petition for Inter Partes Review of U.S. Patent No. 7,934,041
`
`
`limitations of SCSI buses as described in the HP Journal. Id.
`
`Additionally, the beneficial result of modifying the CRD-5500 Controller to
`
`interface with a Fibre Channel transport medium would have been predictable
`
`because (i) the CRD-5500 Controller was specifically designed to support Fibre
`
`Channel, (ii) the HP Journal specifically contemplates replacing multiple SCSI
`
`ports with a single Fibre Channel port, and (iii) Fibre Channel frames are intended
`
`to encapsulate SCSI commands to create backwards compatibility with SCSI-based
`
`devices, such as the CRD-5500 Controller. CQ-1006, pp. 94-95; CQ-1003, ¶¶ 54,
`
`55.
`
`Moreover, to the extent any modifications of the CRD Manual would have
`
`been needed in order to accommodate the teachings of the HP Journal, such
`
`modifications would have been within the level of ordinary skill in the art of
`
`network storage. CQ-1003, ¶