PTAB

IPR2015-00852

Oracle Corp v. Crossroads Systems Inc

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Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Storage Router for Virtual Local Storage
  • Brief Description: The ’147 patent discloses a storage router that connects host devices, such as workstations, to remote storage devices over a network. The router uses mapping tables to allocate specific subsets of storage space to particular host devices, thereby providing access control and making the remote storage appear to the host device as "virtual local storage."

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 1-39 over the CRD Manual in view of the HP Journal

  • Prior Art Relied Upon: CRD Manual (CMD Technology, Inc., CRD-5500 SCSI Raid Controller User's Manual, Nov. 1996) and HP Journal (Hewlett-Packard Journal, Vol. 47, Issue 5, Oct. 1996).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of the CRD Manual and the HP Journal rendered all challenged claims obvious under 35 U.S.C. §103. The CRD Manual was asserted to disclose a modular CRD-5500 RAID controller that performs the core functions of the claimed "storage router." Specifically, the CRD-5500 controller used a "Host LUN Mapping" feature, managed by its firmware and CPU (the claimed "supervisor unit"), to create a configuration that maps hosts to specific subsets of storage called "redundancy groups." This mapping functionality was argued to provide both routing and access control, allowing a host to access only its assigned storage subset, which would "appear to the host as a different disk drive," thereby teaching the concept of "virtual local storage." The controller’s onboard cache was mapped to the claimed "buffer," and its modular slots for replaceable "I/O modules" were mapped to the "first and second controllers" recited in the claims.

      While the CRD-5500 controller as described used SCSI interfaces, Petitioner argued that the HP Journal taught the well-known benefits of replacing SCSI bus architecture with the superior Fibre Channel serial transport medium. The HP Journal detailed Fibre Channel's advantages, including increased bandwidth, longer connection distances, and simplified cabling. Critically, it also taught the encapsulation of SCSI commands within Fibre Channel frames, a technique that ensured backward compatibility with existing SCSI-based hardware and protocols.

    • Motivation to Combine: Petitioner contended that a Person of Ordinary Skill in the Art (POSITA) would have been clearly motivated to combine the teachings of the two references. The CRD Manual itself stated that the CRD-5500 controller featured a modular design for "maximum flexibility" and was explicitly "designed to support tomorrow's high speed serial interfaces, such as Fiberchannel." The HP Journal provided the direct impetus and technical guidance for this exact modification, presenting a compelling case for replacing the known, limited SCSI architecture with the faster, more flexible, and predictably beneficial Fibre Channel interface. A POSITA would combine the references to achieve the predictable result of improved system performance by upgrading the I/O modules in a system expressly designed for such an upgrade.

    • Expectation of Success: A POSITA would have had a high expectation of success in making this combination. The substitution was a straightforward replacement of I/O modules in a modular system. Success was predictable because the CRD-5500 was designed with future Fibre Channel support in mind, and the HP Journal confirmed that Fibre Channel was intended to replace SCSI and could encapsulate SCSI commands to maintain compatibility. Furthermore, the CRD-5500’s user-upgradeable firmware would have allowed a POSITA to easily make any necessary software modifications to accommodate the new Fibre Channel I/O modules, ensuring seamless operation.

4. Key Claim Construction Positions

  • maps between the device and the remote storage devices: Petitioner proposed construing this term to mean "to allocate storage on the storage devices to devices to facilitate routing and access controls." This construction was argued to be consistent with the patent's specification and was central to Petitioner's argument that the "Host LUN Mapping" feature of the CRD Manual, which allocates storage groups to specific hosts, met this critical claim limitation.
  • native low level block protocol: Petitioner proposed the construction "a protocol in which storage space is accessed at the block level, such as the SCSI protocol." This was based on the ’147 patent’s own disclosure, which identifies SCSI as an example of such a protocol. This construction was essential for Petitioner to argue that the SCSI commands used by the CRD-5500 controller satisfied this element of the claims.
  • remote: Petitioner argued for a construction of "indirectly connected through a storage router to enable connections to storage devices at a distance greater than allowed by a conventional parallel network interconnect." This construction supported the position that the CRD-5500's architecture was inherently "remote" and that implementing the long-distance Fibre Channel connection taught by the HP Journal would undisputedly satisfy this limitation.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of all challenged claims, 1-39, of the ’147 patent as unpatentable.