Oracle Corp v. Crossroads Systems Inc

1. Case Identification

• Case #: IPR2015-01063
• Patent #: 6,425,035
• Filed: April 17, 2015
• Petitioner(s): Oracle Corporation
• Patent Owner(s): Crossroads Systems, Inc.
• Challenged Claims: 1-14

2. Patent Overview

• Title: Storage Router for Providing Virtual Local Storage on Remote Storage Devices
• Brief Description: The ’035 patent discloses a storage router that provides host computing devices with virtual local storage on remote storage devices. The router manages access between a first transport medium (e.g., Fibre Channel) connecting the hosts and a second transport medium (e.g., SCSI) connecting the storage devices, using a supervisor unit to map storage and implement access controls.

3. Grounds for Unpatentability

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

• Prior Art Relied Upon: CRD-5500 SCSI RAID Controller User’s Manual (“CRD-5500 Manual”), CRD-5500 SCSI RAID Controller Data Sheet (“CRD-5500 Data Sheet”), and Smith et al., Tachyon: A Gigabit Fibre Channel Protocol Chip (Hewlett-Packard Journal, Oct. 1996) (“Smith”).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the CRD-5500 Manual and Data Sheet disclose a modular RAID controller (a "storage router") that provides virtual storage via a "Host LUN Mapping" feature, which maps redundancy groups to specific hosts. The CRD-5500 Data Sheet explicitly states the controller's architecture was designed to support high-speed serial interfaces like Fibre Channel. Smith discloses the "Tachyon" chip, an off-the-shelf component designed to bridge Fibre Channel and SCSI protocols by encapsulating SCSI packets for transmission over Fibre Channel. Petitioner asserted that incorporating the Tachyon chip into the I/O modules of the CRD-5500 controller, as suggested by the Data Sheet, would create the claimed system. The CRD-5500's CPU would serve as the "supervisor unit," and its "Host LUN Mapping" feature would perform the claimed mapping and access control functions.
  • Motivation to Combine: A POSITA would combine these references because the CRD-5500 Data Sheet expressly motivated adapting the controller for high-speed interfaces like Fibre Channel to leverage its superior bandwidth and distance capabilities. Smith provided a well-known, commercially available solution (the Tachyon chip) to implement this exact Fibre Channel-to-SCSI bridging functionality, making the combination a straightforward design choice to enhance the capabilities of the CRD-5500 system.
  • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved integrating a standard protocol-bridging chip (Smith) into a modular controller (CRD-5500) explicitly designed to accommodate such interface upgrades.

Ground 2: Obviousness over Kikuchi and Bergsten - Claims 1-4 and 7-14 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 discloses the basic architecture of the claimed invention: a control device that connects host devices via a Fibre Channel (FC) transport medium to a storage unit via a SCSI transport medium. Kikuchi's controller performs access control by checking a host address against a registration unit. Bergsten was argued to provide the missing details for virtualized storage and protocol conversion, disclosing emulation drivers to manage FC communications and physical drivers for SCSI communications, all coordinated by a central operating system. Bergsten's two-stage virtualization mapping (host logical address to internal logical address to physical address) was alleged to teach the claimed "virtual local storage" transparently to the host.
  • Motivation to Combine: A POSITA would combine Kikuchi and Bergsten to improve Kikuchi's system with the advantages of virtualized, networked storage taught by Bergsten. As of 1997, it was desirable for a storage controller to be independent of any specific hardware configuration. Incorporating Bergsten’s virtual storage emulation into Kikuchi’s system would increase the number of accessible storage devices, expand the address range, and improve system flexibility by allowing an administrator to reassign storage without host-side involvement.
  • Expectation of Success: The combination would have been straightforward, as the architectures were compatible. A POSITA could have routinely implemented Bergsten's virtual mapping functionality into Kikuchi's correlation chart to achieve the combined system.

• Additional Grounds: Petitioner asserted that claims 5 and 6 are obvious over the combination of Kikuchi, Bergsten, and Smith, with Smith providing specific details of a standard FC adapter card architecture. Petitioner also argued that claims 3, 7-10, and 13 are obvious over Bergsten in view of Hirai (JP Application # Hei 5[1993]-181609), where Hirai provides a more detailed disclosure of mapping-based access control functionality to supplement Bergsten.

4. Key Claim Construction Positions

• "Native low-level block protocol" (NLLBP): Petitioner argued that, based on the patent's specification and prosecution history, the broadest reasonable interpretation of NLLBP includes protocols like SCSI that enable information exchange without the overhead of high-level protocols and file systems typically required by network servers. This construction is critical because it ensures that protocols like Fibre Channel Protocol (FCP), which encapsulates SCSI commands, fall within the scope of the claims, aligning with the teachings of the prior art.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §325(d) was inappropriate. A prior petition involving the same patent (IPR2014-01197) was denied institution not on the merits of the prior art, but on a procedural defect—improper incorporation of arguments by reference from an expert declaration. Petitioner contended that the present petition corrects this procedural flaw by presenting all arguments and evidence fully within the petition itself, and therefore the Board should consider the substantive merits of the challenges.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of Patent 6,425,035 as unpatentable.