Oracle Corp v. Crossroads Systems Inc

1. Case Identification

• Case #: IPR2015-01066
• Patent #: 7,934,041
• Filed: April 17, 2015
• Petitioner(s): Oracle Corporation
• Patent Owner(s): Crossroads Systems, Inc.
• Challenged Claims: 1-53

2. Patent Overview

• Title: Storage Router and Method for Providing Virtual Local Storage
• Brief Description: The ’041 patent describes a storage router that provides host computing devices with virtual local storage by managing access to remote physical storage devices. The router uses a map to associate host devices with specific storage spaces, making the remote storage appear local and transparent to the host.

3. Grounds for Unpatentability

Ground 1: Obviousness over CRD-5500 and Smith - Claims 1-53 are obvious over the CRD-5500 User Manual, the CRD-5500 Data Sheet, and Smith.

• Prior Art Relied Upon: CRD-5500 User Manual (a 1996 manual for a RAID controller), CRD-5500 Data Sheet (a 1996 data sheet for the controller), and Smith (a 1996 journal article).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the CRD-5500 references disclose a RAID controller that functions as a storage router by providing virtual local storage to host devices. This is achieved through a "Host LUN Mapping" feature that maps RAID redundancy groups to host LUN addresses, thereby controlling access and making remote storage appear local. However, the CRD-5500 controller natively used SCSI interfaces. Smith discloses the "Tachyon" chip, a Fibre Channel (FC) protocol chip designed to bridge between FC and SCSI by encapsulating SCSI packets for transport over FC. The combined system would use the Tachyon chip in host interface modules for the CRD-5500 controller. This enables the controller to receive commands over a first low-level block protocol (FCP) and forward them using a second low-level block protocol (SCSI) to the RAID array, meeting key limitations of independent claims 1, 20, and 37.
  • Motivation to Combine: A POSITA would combine these references to enhance the CRD-5500 controller with high-speed serial interfaces. The CRD-5500 Data Sheet explicitly stated that the controller’s architecture was designed to support high-speed interfaces like Fibre Channel. Smith’s Tachyon chip was an off-the-shelf solution for implementing the FC-to-SCSI bridging needed to achieve this upgrade, providing a clear path to integrate the technologies.
  • Expectation of Success: A POSITA would have a high expectation of success because the components were designed for interoperability; the data sheet anticipated such an upgrade, and the Tachyon chip was specifically designed for this type of bridging application.

Ground 2: Obviousness over Kikuchi and Bergsten - Claims 1-53 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 a control device (a storage router) that connects host devices via Fibre Channel to a SCSI storage unit. Kikuchi’s device uses an address registration unit and correlation charts to manage host access to different partitions of the storage, effectively providing virtualized storage. Bergsten enhances this disclosure by teaching a more advanced storage controller that virtualizes remote storage subsystems for hosts using virtual addressing, emulation drivers, and physical drivers to manage a FC-to-SCSI bridge. Bergsten’s system makes the physical storage location transparent to the host. Combining the references, Bergsten’s sophisticated virtualization and protocol bridging functionality would be incorporated into Kikuchi’s access control framework.
  • Motivation to Combine: A POSITA would combine Kikuchi and Bergsten to improve the Kikuchi system with the advantages of virtualized, networked storage as taught by Bergsten. Bergsten explained the desirability of a storage controller that is not dependent on any particular hardware or software configuration. Incorporating Bergsten's virtual storage emulation would increase the number of accessible storage devices and the available address range in the Kikuchi system, while also allowing an administrator to update equipment without host-side involvement.
  • Expectation of Success: The architectures were compatible, making the integration of Bergsten’s features into Kikuchi’s system a routine modification for a person of ordinary skill.

Ground 3: Obviousness over Bergsten and Hirai - Claims 1-53 are obvious over Bergsten in view of Hirai.

• Prior Art Relied Upon: Bergsten (Patent 6,073,209) and Hirai (JP Application # Hei 5[1993]-181609).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Bergsten teaches a storage controller that provides virtual local storage over a network, connecting hosts via Fibre Channel to remote SCSI disk arrays and managing the mapping between virtual and physical addresses. While Bergsten mentions write-protection, it lacks detail on implementing granular access controls. Hirai remedies this by disclosing a system that uses a "partition control table" to manage access rights (e.g., read, write, create, delete) for multiple computers sharing magnetic disk devices. The table maps specific hosts to specific partitions with specific rights. In the combined system, Hirai’s table-based access control logic would be incorporated into Bergsten’s storage controller to manage access at the logical address level.
  • Motivation to Combine: A POSITA would combine the teachings to improve the rudimentary access controls of the Bergsten system. Hirai’s mapping-based access controls would allow for more sophisticated and granular security, enabling an administrator to allocate varying levels of access (e.g., read-only vs. read/write) to different hosts for the same data, a clear advantage in an enterprise environment.
  • Expectation of Success: Applying Hirai’s logical, table-based access controls to Bergsten’s virtualized storage system would be a predictable and straightforward design choice for a skilled engineer seeking to enhance system security.

4. Key Claim Construction Positions

• Petitioner based its arguments on the broadest reasonable interpretation standard. A key term addressed was "native low-level block protocol" (NLLBP).
• Petitioner argued that, consistent with the specification and prosecution history, an NLLBP is a protocol, such as SCSI or Fibre Channel Protocol (FCP), that enables the exchange of information without the overhead of high-level protocols and file systems typically required by network servers. This construction distinguishes it from protocols like TCP/IP.

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under 35 U.S.C. §325(d) based on a prior related proceeding, IPR2014-01177.
• Petitioner contended that the Board declined to institute the prior IPR on procedural grounds, specifically finding that the prior petition improperly attempted to incorporate by reference arguments and citations from a supporting expert declaration. Petitioner asserted that the current petition corrects this defect by presenting all prior art evidence and arguments 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 1-53 of the ’041 patent as unpatentable.