Oracle Corp v. Crossroads Systems Inc

1. Case Identification

• Case #: IPR2015-01064
• Patent #: 7,051,147
• Filed: April 17, 2015
• Petitioner(s): Oracle Corporation
• Patent Owner(s): Crossroads Systems, Inc.
• Challenged Claims: 1-13

2. Patent Overview

• Title: Storage Router and Method for Providing Virtual Local Storage
• Brief Description: The ’147 patent discloses a storage router that provides virtual local storage to connected devices (e.g., workstations) by managing access to remote storage devices (e.g., hard disk drives). The router uses a configuration map and access controls to present remote storage as if it were local to the host devices over a transport medium like Fibre Channel (FC).

3. Grounds for Unpatentability

Ground 1: Obviousness over CRD-5500 and Smith - Claims 1-13 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 (a 1996 Hewlett-Packard Journal article describing the Tachyon FC chip).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the CRD-5500 Manual and Data Sheet disclosed a RAID controller that functions as the claimed "storage router." This controller provided virtual storage through its "Host LUN Mapping" feature, which maps redundancy groups (subsets of storage) to specific host devices and implements access controls. Smith disclosed the Tachyon chip, an off-the-shelf component designed to provide an FC interface and bridge SCSI commands over an FC network, fulfilling the role of the claimed first and second FC controllers.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine these references because the CRD-5500 Data Sheet explicitly stated its architecture was "designed to support tomorrow's high speed serial interfaces, such as Fibrechannel." Smith provided the exact, commercially available chip to implement this suggested upgrade, offering the known benefits of FC technology like higher bandwidth and longer connection distances.
  • Expectation of Success: A POSITA would have a high expectation of success, as Smith's Tachyon chip was designed specifically for this type of integration into host and storage interface modules for bridging SCSI and FC protocols.

Ground 2: Obviousness over Kikuchi and Bergsten - Claims 3, 6-9, and 12 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 connecting host devices to storage via FC and SCSI, respectively, and performed access control by checking a host's address against a registration unit. Bergsten taught a more advanced storage controller with detailed FC-to-SCSI bridging functionality (via emulation and physical drivers) and a two-stage virtual mapping system that virtualized storage for hosts. The combination enhances Kikuchi's basic controller with Bergsten's more sophisticated virtualization and bridging capabilities.
  • Motivation to Combine: A POSITA would combine the teachings to improve the Kikuchi system with the known advantages of Bergsten's advanced, hardware-independent virtualized storage. This would increase the number of accessible storage devices, expand the address range, and allow for easier system administration, such as reassigning storage regions without host-side involvement.
  • Expectation of Success: The combination would have been straightforward because the architectures were generally compatible. Bergsten's driver-based system was designed to bridge protocols like FC and SCSI, making its integration into Kikuchi's similar system predictable.

Ground 3: Obviousness over Bergsten and Hirai - Claims 3, 6-9, and 12 are obvious over Bergsten in view of Hirai.

• Prior Art Relied Upon: Bergsten (Patent 6,073,209) and Hirai (JP Application Publication No. Hei 5[1993]-181609).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that while Bergsten disclosed a storage controller with sophisticated virtualization, it lacked a detailed implementation of granular access controls. Hirai remedied this by teaching a detailed access control system using a partition control table to assign specific rights (e.g., read, write, create, delete) to different hosts on a per-partition basis. Incorporating Hirai's access control map into Bergsten's controller provides the fine-grained security missing from Bergsten alone.
  • Motivation to Combine: A POSITA would have been motivated to add Hirai's granular access controls to Bergsten's virtualized storage system to enhance security and functionality. In a shared storage environment, it is highly desirable to provide different levels of access to different users or systems (e.g., read-only for some, read/write for others), which Hirai's system directly addresses.
  • Expectation of Success: A POSITA would have reasonably expected success in applying Hirai's mapping-based access control logic at the logical addressing level of Bergsten's system, as it represented a predictable application of known security principles to a storage network.

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 and FC Protocol (FCP) that enable direct exchange of information without the overhead of higher-level protocols and file systems. This construction distinguishes NLLBP from protocols like TCP/IP, which the patent owner had argued during reexamination were not NLLBPs. This construction was central to mapping prior art protocols onto the claims.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise discretionary denial under 35 U.S.C. §325(d) based on a previously filed petition (IPR2014-01209). The earlier petition was denied institution not on the substantive merits of the prior art arguments, but on the procedural ground that it improperly attempted to incorporate by reference arguments from a supporting expert declaration. This petition corrected that defect by presenting all prior art arguments and evidence fully within the petition itself, warranting a full consideration on the merits.

6. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-13 of the ’147 patent as unpatentable.