PTAB

IPR2014-01207

Oracle Corp v. Crossroads Systems Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Storage Router and Method for Providing Virtual Local Storage
  • Brief Description: The ’147 patent discloses a storage router that functions as a bridge between a Fibre Channel network and a SCSI bus. The router uses native low-level block protocols (NLLBP) to enable workstations on the Fibre Channel link to access remote SCSI storage devices as if they were virtual local storage, implementing access controls and routing to manage data access.

3. Grounds for Unpatentability

Ground 1: Claims 14-39 are obvious over the CRD-5500 references in view of Smith.

  • Prior Art Relied Upon: CRD-5500 User Manual (a 1996 user manual for a SCSI RAID controller), CRD-5500 Data Sheet (a 1996 data sheet for the controller), and Smith (Hewlett-Packard Journal, Oct. 1996).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the CRD-5500 references disclosed a RAID controller that provided key features of the ’147 patent, including a "supervisor unit" (the controller's CPU) that managed access to storage. The CRD-5500's "Host LUN Mapping" feature allegedly taught the claimed mapping of a host device to a specific portion of remote storage, thereby providing "virtual local storage" and controlling access. The primary element missing from the CRD-5500 system was its use of Fibre Channel (FC) as the transport medium. Smith was argued to cure this deficiency by describing the "Tachyon" chip, an off-the-shelf component designed to encapsulate and de-encapsulate SCSI commands for transport over an FC link (FCP), which is an NLLBP. Petitioner contended that incorporating the Tachyon chip into the modular I/O slots of the CRD-5500 controller would create the claimed apparatus.
    • Motivation to Combine: A POSITA would combine these references because the CRD-5500 Data Sheet explicitly stated that the controller's architecture was designed to support "tomorrow's high speed serial interfaces, such as Fibrechannel." This provided a direct suggestion to enhance the existing CRD-5500 SCSI controller with FC connectivity. Smith provided the known, commercially available component (the Tachyon chip) to implement this exact upgrade, leveraging FC's higher bandwidth and greater connection distances.
    • Expectation of Success: A POSITA would have a high expectation of success because the CRD-5500 was designed with modular I/O slots for adding new interface types. Combining the systems involved integrating a known FC protocol chip (Smith) into a controller expressly designed for such high-speed serial interfaces, which was a predictable and routine design task.

Ground 2: Claims 14-39 are obvious over Kikuchi in view of Bergsten.

  • Prior Art Relied Upon: Kikuchi (Patent 6,219,771) and Bergsten (Patent 6,073,209).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Kikuchi disclosed a control device that managed access for multiple host devices to different partitions of a storage device, using a host address to authorize access and map to specific partitions. This taught the core access control and mapping limitations. However, Kikuchi's description of virtualization was less detailed. Bergsten was argued to provide a more robust disclosure of a storage controller that virtualizes remote storage devices for hosts over a network like Fibre Channel, making the remote storage appear local. Bergsten's system used virtual addressing and mapped logical host addresses to physical storage locations, operating with standard SCSI commands over NLLBP. The combination allegedly disclosed all limitations of the independent claims, with Kikuchi providing the granular access control and Bergsten providing the advanced virtualization over an FC network.
    • Motivation to Combine: A POSITA would combine Kikuchi and Bergsten to improve the Kikuchi system with the superior virtualization and networked storage capabilities taught by Bergsten. As Bergsten noted, it was desirable for storage controllers to be hardware-agnostic and provide transparent virtualized storage. A skilled engineer would have been motivated to incorporate Bergsten's virtual storage emulation into Kikuchi's access-controlled disk apparatus to increase the number of accessible storage devices and expand the available address range, while also simplifying system administration.
    • Expectation of Success: The combination was asserted to be predictable because both systems operated on similar principles of mapping and controlling access between hosts and storage. The functionalities were compatible, and the modifications required to integrate Bergsten's virtualization techniques into Kikuchi's access control framework were argued to be routine for a person of ordinary skill in network storage design at the time.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 14-39 based on Bergsten in view of Hirai (JP Application # Hei 5[1993]-181609). This ground relied on Bergsten for the core virtualized FC-to-SCSI storage controller and combined it with Hirai's teachings on granular, per-partition access rights (read, write, create, etc.) managed via a partition control table.

4. Key Claim Construction Positions

  • "Native low-level block protocol" (NLLBP): Petitioner argued that, based on the patent's specification and the prosecution history of an ancestor patent, the broadest reasonable interpretation of NLLBP is a protocol that enables information exchange without the overhead of high-level protocols and file systems typical of network servers. The petition emphasized that protocols like SCSI and the Fibre Channel Protocol (FCP) are NLLBP, whereas protocols like TCP/IP, which require translation to a low-level protocol, are not. This construction was central to distinguishing the claimed invention from prior art that used Ethernet/TCP-IP for host-side communication.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 14-39 of the ’147 patent as unpatentable.