DCT

1:13-cv-00895

Crossroads Systems Inc v. Oracle Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:13-cv-00895, W.D. Tex., 10/07/2013
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Oracle regularly conducts business in the district, including marketing and selling the accused products.
  • Core Dispute: Plaintiff alleges that Defendant’s storage appliances and servers infringe patents related to storage area network (SAN) routers that provide virtualized storage by bridging different network protocols.
  • Technical Context: The technology concerns storage networking, specifically devices that allow newer, high-speed Fibre Channel networks to interface with and manage storage on older, but widely deployed, SCSI-based systems, making remote storage appear local to host computers.
  • Key Procedural History: The complaint alleges that Defendant had actual notice of U.S. Patent Nos. 6,425,035 and 7,051,147 as of November 2009, and of U.S. Patent No. 7,934,041 as of May 2011, which forms the basis for the willfulness allegations. The patents-in-suit have been subject to multiple Inter Partes Review (IPR) proceedings, which resulted in the cancellation of all claims.

Case Timeline

Date Event
1997-12-31 Priority Date for ’035, ’147, and ’041 Patents
2002-07-23 ’035 Patent Issued
2006-05-23 ’147 Patent Issued
2009-11-01 Alleged Notice Date for ’035 and ’147 Patents
2011-04-26 ’041 Patent Issued
2011-05-01 Alleged Notice Date for ’041 Patent
2013-10-07 Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 6,425,035 - "Storage router and method for providing virtual local storage," issued July 23, 2002

The Invention Explained

  • Problem Addressed: The patent describes a challenge in computer networking where accessing data over a network is significantly slower than accessing locally attached storage devices. This is partly because network access requires protocol translations by a server, adding overhead. Additionally, managing data that is distributed across many individual workstations is logistically difficult for tasks like system-wide backups. (’035 Patent, col. 1:36-60).
  • The Patented Solution: The invention proposes a "storage router" that acts as a bridge between a high-speed Fibre Channel network (connecting workstations) and a SCSI bus (connecting storage devices like disk drives). This router creates "virtual local storage" by mapping specific partitions of the remote SCSI storage to individual workstations. The router enforces these divisions through access controls, allowing workstations to access the centralized storage using fast, "native low level, block protocols" as if the storage were directly attached, bypassing the need for a slow network server. (’035 Patent, Abstract; col. 4:7-29; Fig. 3).
  • Technical Importance: This approach enabled organizations to centralize their storage for easier administration while providing users with the high-speed performance characteristic of local storage, bridging the gap between emerging Fibre Channel technology and legacy SCSI infrastructure. (’035 Patent, col. 2:27-44).

Key Claims at a Glance

  • The complaint does not identify specific asserted claims. Independent claim 1 is representative of the system claims.
  • Claim 1 recites a storage router comprising:
    • a buffer providing memory work space for the storage router;
    • a first controller operable to connect to and interface with a first transport medium;
    • a second controller operable to connect to and interface with a second transport medium; and
    • a supervisor unit coupled to the controllers and buffer, which is operable to map between devices and storage, implement access controls, and process data to allow access between the two mediums using native low level, block protocols.
  • The complaint does not explicitly reserve the right to assert other claims.

U.S. Patent No. 7,934,041 - "Storage router and method for providing virtual local storage," issued April 26, 2011

The Invention Explained

  • Problem Addressed: Similar to the ’035 patent, this patent addresses the need to provide devices on one type of network (e.g., Fibre Channel) with efficient, controlled access to storage devices on another (e.g., SCSI), overcoming the performance bottlenecks and management complexity of traditional network file servers. (’041 Patent, col. 1:50-col. 2:20).
  • The Patented Solution: The invention is a storage router with a "processing device" that maintains a "map." This map allocates storage space on remote devices to the devices on the first network. It does so by "associating representations" of the host devices with "representations of storage space." The router then uses this map to control and allow access to the remote storage using native low-level block protocols. (’041 Patent, Abstract; col. 9:40-55).
  • Technical Importance: The technology provides a framework for virtualizing storage, where the logical presentation of storage to a host is decoupled from the physical reality, enabling flexible and secure allocation of centralized storage resources. (’041 Patent, col. 2:42-49).

Key Claims at a Glance

  • The complaint does not identify specific asserted claims. Independent claim 1 is representative.
  • Claim 1 recites a storage router comprising:
    • a first controller to interface with a first, serial transport medium; and
    • a processing device configured to:
      • maintain a map associating representations of devices with representations of storage space;
      • control access to the storage space in accordance with the map; and
      • allow access to the remote storage devices using native low level block protocol.
  • The complaint does not explicitly reserve the right to assert other claims.

Multi-Patent Capsule: U.S. Patent No. 7,051,147 - "Storage router and method for providing virtual local storage," issued May 23, 2006

  • Technology Synopsis: The ’147 patent discloses a storage router that provides virtual local storage to devices on a first Fibre Channel network from remote storage devices on a second Fibre Channel network. A supervisor unit maintains a configuration map that governs access, allowing devices to use native block protocols to access assigned portions of the remote storage as if it were local. (’147 Patent, Abstract; col. 9:5-col. 10:19).
  • Asserted Claims: The complaint does not specify asserted claims. Independent claims include 1, 6, 10, 14, 21, 28, and 34.
  • Accused Features: The complaint alleges that the Pillar Axiom 300 and 600 product lines, with their various Fibre Channel and iSCSI configurations, infringe the ’147 patent. (Compl. ¶27).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are various enterprise storage products, including the Sun ZFS Storage 7120, 7320, and 7420 Appliances; Oracle Servers with Solaris with SCSI Target Mode Framework; the Pillar Axiom 300 and 600 series SAN Slammers; and the Oracle Sun Storage 2540-M2 Array. (Compl. ¶¶9, 18, 27).
  • Functionality and Market Context:
    • The complaint identifies these products as storage systems and servers that are sold, marketed, and used in enterprise data centers. (Compl. ¶¶5, 9, 10). The complaint alleges that these products provide storage services over networks using protocols such as Fibre Channel, iSCSI, and SCSI. (Compl. ¶¶9, 18, 27). The underlying infringement theory suggests these products inherently perform storage virtualization, protocol bridging, and access control functionalities that are central to the patents-in-suit.
    • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or detailed infringement analysis mapping specific product features to claim limitations. Instead, it makes a general allegation that Defendant’s products directly, contributorily, and by inducement infringe the patents-in-suit. (Compl. ¶¶8-11, 17-20, 26-29). The narrative theory is that the accused storage products, by their nature of providing virtualized storage to hosts across a network, necessarily perform the claimed functions of mapping storage, controlling access, and interfacing between different protocols.

  • Identified Points of Contention:
    • Pleading Sufficiency: The complaint’s lack of specific factual allegations mapping product features to claim elements raises the question of whether it meets the plausibility standard for patent infringement pleading established by the Supreme Court in Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal. A defendant may argue that merely naming products and patents without explaining how they infringe is insufficient.
    • Scope Questions: The patents describe bridging a Fibre Channel medium with a SCSI medium. The accused products are alleged to include various combinations of Fibre Channel and iSCSI. (Compl. ¶¶9, 27). This raises the question of whether the patent claims, which are rooted in a Fibre Channel-to-SCSI architecture, can be construed to read on the different protocol combinations present in the accused products.
    • Technical Questions: A central question will be whether the software and hardware architecture of the accused products aligns with the specific structures claimed in the patents. For instance, for the ’035 Patent, discovery would need to establish whether the accused products contain a distinct "supervisor unit", "first controller", and "second controller" or functional equivalents, as opposed to a more integrated, software-defined architecture.

V. Key Claim Terms for Construction

  • The Term: "supervisor unit" (’035 Patent, Claim 1)

    • Context and Importance: This unit performs the core intelligent functions of the invention: mapping, implementing access controls, and processing data for the interface. The definition of this term is critical because it will determine whether the claim is limited to a specific hardware arrangement or can cover a broader range of software-based storage management systems. Practitioners may focus on this term because its construction could decide whether a general-purpose CPU running virtualization software meets the limitation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language describes the "supervisor unit" in functional terms ("operable to map," "to implement," "to process"), which may support a construction not limited to a specific structure. ( ’035 Patent, col. 9:22-31).
      • Evidence for a Narrower Interpretation: The detailed description and figures show the "supervisor unit" (86) as a distinct block connected to the Fibre Channel controller (80), SCSI controller (82), and buffer (84). This could support an argument that the term requires a specific supervisory hardware component distinct from the data-path controllers. (’035 Patent, Fig. 4; col. 5:11-15).

  • The Term: "map" (’041 Patent, Claim 1)

    • Context and Importance: The act of "maintaining a map" is the central element for allocating and controlling access to virtualized storage. The scope of "map" will be highly contested. A broad definition could encompass any form of configuration data, while a narrow one might require a specific type of data structure used for real-time translation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent states the router "uses tables to map devices from one medium to the other" and can use "mapping tables or other mapping techniques," suggesting flexibility in the implementation. (’041 Patent, col. 4:4-6, col. 4:14-16).
      • Evidence for a Narrower Interpretation: A defendant might argue that the term "map" should be limited by the context of creating "virtual local storage," where partitions of a physical device are made to appear as a complete local drive to a host. This could be used to argue against infringement by systems that perform more general network routing or LUN masking without creating the specific "virtual local" appearance. (’041 Patent, col. 4:12-14).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides "product instruction and/or advertising" that encourages and facilitates infringing use by end users. (Compl. ¶¶10, 19, 28). It further alleges contributory infringement, stating the accused products are not staple articles of commerce and are especially made for use in an infringing manner. (Compl. ¶¶11, 20, 29).
  • Willful Infringement: Willfulness is alleged for all three patents. The claims for the ’035 and ’147 patents are based on alleged "constructive and/or actual notice" since "at least as early as November 2009." (Compl. ¶¶12, 30). The claim for the ’041 patent is based on notice since "at least as early as May 2011." (Compl. ¶21).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A central threshold issue will be one of pleading sufficiency: Does the complaint's recitation of accused product families, without specific factual allegations explaining how those products meet the limitations of any asserted claim, satisfy the plausibility standard required to proceed to discovery, or is it vulnerable to a motion to dismiss?
  • The core technical dispute will likely be a question of architectural correspondence: Do the accused Oracle and Sun storage systems, which may use integrated, software-defined architectures, practice the specific hardware-block structures recited in the patent claims, such as the "supervisor unit" and distinct "controllers" of the ’035 patent?
  • A key claim construction battle will focus on definitional scope: Can terms like "map" and "supervisor unit", which are described in the context of a Fibre Channel-to-SCSI bridge, be construed broadly enough to cover the potentially different virtualization and protocol management techniques used in modern iSCSI and Fibre Channel storage appliances?