UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CROSSROADS SYSTEMS, INC.
`Patent Owner
`
`____________
`
`Patent No. 7,051,147
`____________
`
`
`
`DECLARATION OF BRIAN BIANCHI
`
`1 of 7
`
` CROSSROADS EXHIBIT 2324
`Oracle Corp., et al v. Crossroads Systems, Inc.
` IPR2014-01207 and IPR2014-1209
`
`CROSSROADS EXHIBIT
`Oracle Corp. v. Crossroads Systems, Inc.
`IPR2015-0(cid:1005)(cid:1004)(cid:1010)(cid:1010)
`
`2324
`
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CROSSROADS SYSTEMS, INC.
`Patent Owner
`
`____________
`
`Patent No. 7,051,147
`____________
`
`
`
`DECLARATION OF BRIAN BIANCHI
`
`1 of 7
`
` CROSSROADS EXHIBIT 2324
`Oracle Corp., et al v. Crossroads Systems, Inc.
` IPR2014-01207 and IPR2014-1209
`
`CROSSROADS EXHIBIT
`Oracle Corp. v. Crossroads Systems, Inc.
`IPR2015-0(cid:1005)(cid:1004)(cid:1010)(cid:1010)
`
`2324
`
`
`
`
`
`I, Brian Bianchi, state and declare as follows:
`
`1.
`
`I am an employee of Crossroads Systems, Inc. I started my
`
`employment with Crossroads in 1998 in the position of Software Engineering
`
`Manager. I am currently in the position of Chief Operating Officer. My knowledge
`
`of the facts stated here is based on my employment with Crossroads.
`
`2.
`
`I understand the exhibits listed in Exhibit A to this declaration are
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`being filed by Crossroads in certain proceedings before the Patent Trial and Appeal
`
`Board. Regarding those exhibits:
`
`a) Exhibits 2303 and 2323 (with the exception of the exhibit labels and
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`Bates label numbers) are duplicate copies of documents contained in
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`Crossroads’ patent files and kept during the ordinary course of business.
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`b) Exhibits 2307, 2308, 2309, 2312, 2314, 2316, 2317, 2318, 2319, 2320,
`
`and 2321 are duplicate copies of Crossroads’ business records which
`
`were created or modified during the course of the Verrazano project. I am
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`familiar with Crossroads’ practices regarding the creation, modification,
`
`and keeping of such documents through my employment with
`
`Crossroads, both at the time of the Verrazano project and today. Each of
`
`these documents is a document created by Crossroads personnel during
`
`the regular course of business. While I did not create these particular
`
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`2 of 7
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`documents, it was the regular practice of Crossroads’ personnel,
`
`including those participating in the Verrazano project, to create such
`
`records at or near the time the recorded act, event, condition, or opinion
`
`occurred. It was the general practice of Crossroads’ personnel to date
`
`such documents as of the date the record was created or modified. I do
`
`not recall any instance in which similar documents were dated in the
`
`future or the past, and have no reason to doubt the dates recorded on any
`
`of these documents. Such records could only be made by someone with
`
`knowledge or from information transmitted by someone with knowledge.
`
`These records were kept in the course of Crossroads’ regularly conducted
`
`business activity, and it is my understanding they were originally
`
`delivered to Crossroads’ attorneys for the purposes of litigation.
`
`3.
`
`I have been in charge of, or deeply involved in, Crossroads’ patent
`
`program since 2004. I am also a named inventor on multiple patent applications.
`
`Based on these experiences, I have become familiar with time necessary to review
`
`draft patent applications, prepare revisions and review edits—generally, with the
`
`time necessary to file a completed patent application once an initial draft has been
`
`received. I have become familiar with the time it takes to complete this task at
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`Crossroads for multiple inventors, including myself. During ordinary conditions—
`
`i.e., a normal workload—I believe the average time between receipt of a first draft
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`3 of 7
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`of a patent disclosure to filing the final application has been around eight weeks.
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`During heavy workload periods, it is common to see this time period increase to
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`double or triple the normal time, depending on the workload. Based on my own
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`experience at Crossroads working on the “Verrazano” project, and my
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`understanding of the workload of the involved employees in the fall of 1997, it
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`does not surprise me to see that a draft patent application from counsel was
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`received in July 1997 and finally filed at the end of December 1997. This is
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`consistent with my experience at Crossroads.
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`I declare under penalty of perjury under the laws of the United States of America
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`that the foregoing is true and correct.
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`Executed on: May 2c,
`
`, 2015
`
`\
`
`Brian Bianchj
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`4of7
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`4 of 7
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`EXHIBIT A
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`Title / Description
`
`July 11, 1997 Letter and Draft Patent Application from Mr. Anthony
`Peterman (Baker & Botts LLP) to Mr. Geoffrey Hoese
`
`(Plaintiff’s Exhibit 266 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`Verrazano FC-SCSI Bridge Product Overview Presentation, June 19,
`1996
`
`(Plaintiff’s Exhibit 4 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`Verrazano Software Development, Sept. 10, 1996
`
`(Plaintiff’s Exhibit 5 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`Verrazano: System Structure Drawings, Document Number DS04100,
`Jan. 22, 1997
`
`(Plaintiff’s Exhibit 6 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`Verrazano Bare Board Drawings (latest revisions Sept. 3, 1997)
`CRDS 50579
`
`
`
`
`Exhibit
`No.
`2303
`
`2307
`
`2308
`
`2309
`
`2312
`
`
`
`5 of 7
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`Title / Description
`
`
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`Verrazano Enclosure Specification, Revision 2.1, June 5, 1997
`
`(Plaintiff’s Exhibit 264 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`CP4x00 Product Specification (Preliminary)
`
`(Plaintiff’s Exhibit 267 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`(Exhibit 10 to Deposition of Jeffry Russell, Sept. 26, 2000, taken in
`Crossroads Systems, (Texas), Inc. v. Chaparral Network Storage, Inc.,
`Docket No. A 00-CA-217 SS (W.D. Tex. 2001)).
`
`
`
`Verrazano Hardware Architecture, Revision 1.0, Aug. 25, 1997
`
`(Plaintiff’s Exhibit 268 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
`(Exhibit 2 to Deposition of Jeffry Russell, Sept. 26, 2000, taken in
`Crossroads Systems, (Texas), Inc. v. Chaparral Network Storage, Inc.,
`Docket No. A 00-CA-217 SS (W.D. Tex. 2001)).
`
`
`
`Verrazano: System Structure Drawings, Document Number DS04100,
`Sept. 3, 1997
`
`Verrazano Software Architecture, Revision 1.1, Aug. 27, 1997
`
`Verrazano Programmable Device Instructions, Version 1.1, Sept. 5,
`1997
`
`
`
`
`Exhibit
`No.
`2314
`
`2316
`
`2317
`
`2318
`
`2319
`
`2320
`
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`6 of 7
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`Exhibit
`No.
`2321
`
`2323
`
`
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`Title / Description
`
`Verrazano Component List and Insertion List Report, Sept. 29, 1997
`
`December 31, 1997 Letter and Patent Application from Mr. William
`Hulsey (Baker & Botts LLP) to Mr. Dale Quisenberry
`
`(Plaintiff’s Exhibit 275 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS (W.D.
`Tex. 2001)
`
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`7 of 7
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