Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 1 of 20
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`Exhibit 8
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`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 2 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 1 of 19
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`Cassidy Ex. J
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`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 3 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 2 of 19
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`
`PAUL ANDRE (State Bar No. 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (State Bar No. 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (State Bar No. 237978)
`jhannah@kramerlevin.com
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
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`OAKLAND DIVISION
`
`FINJAN, INC.,
`
`
`Plaintiff,
`
`
`v.
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`
`
`Defendant.
`
`
`SYMANTEC CORP.,
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`
`
`
`
`
`
`Case No.: 4:14-cv-02998-HSG
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`PLAINTIFF FINJAN, INC.’S
`SUPPLEMENTAL RESPONSES TO
`DEFENDANT SYMANTEC CORP.’S
`INTERROGATORIES (NO. 1)
`
`
`
`FINJAN, INC.’S SUPPLEMENTAL RESPONSES
`TO SYMANTEC’s INTERROGATORIES (NO. 1)
`
`CASE NO.: 4:14-CV-02998-HSG
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`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 4 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 3 of 19
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`Pursuant to Fed. R. Civ. P. 26 and 33, Plaintiff Finjan, Inc. (“Finjan”) responds to Defendant
`
`Symantec Corporation’s (“Symantec” or “Defendant”) Interrogatories (“Interrogatories”). Finjan
`
`makes these objections and supplemental response herein (collectively “Responses”) based solely on
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`its current knowledge, understanding, and belief as to the facts and information reasonably available to
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`it as of the date of the Responses.
`
`Additional discovery and investigation may lead to additions to, changes in, or modifications of
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`these Responses. The Responses, therefore, are given without prejudice to Finjan’s right to
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`supplement these Responses pursuant to Fed. R. Civ. P. 26(e), or to provide subsequently discovered
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`information and to introduce such subsequently discovered information at the time of any trial or
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`proceeding in this action.
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`GENERAL OBJECTIONS
`
`1.
`
`Finjan incorporates by reference its general objections set forth in its Responses to
`
`Symantec’s First Set of Interrogatories, dated December 4, 2014; Supplemental Responses to
`
`Symantec’s First Set of Interrogatories (No. 3), dated December 19, 2014; Supplemental Responses to
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`Symantec’s First Set of Interrogatories (Nos. 3 and 4), dated February 11, 2015; Supplemental
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`Responses to Symantec’s First Set of Interrogatories (Nos. 1, 5-11), dated April 13, 2015; Responses
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`to Symantec’s Second Set of Interrogatories (Nos. 12-16), dated April 27, 2015; Responses to
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`Symantec’s Third Set of Interrogatories (Nos. 17-19), dated November 28, 2016; Supplemental
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`Responses to Symantec’s First Set of Interrogatories (No. 1), dated December 2, 2016; Responses to
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`Symantec’s Fourth Set of Interrogatories (Nos. 20-21), dated June 2, 2017; Supplemental Responses to
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`Symantec’s Interrogatories (Nos. 1, 3, 5-18), dated June 7, 2017; Responses to Symantec’s Fifth Set of
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`Interrogatories (Nos. 22-25), dated June 9, 2017; Supplemental Responses to Symantec’s
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`Interrogatories (Nos. 18, 23-24), dated July 7, 2017; and Supplemental Responses to Symantec’s
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`Interrogatories (Nos. 1 and 12), dated July 26, 2017.
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`OBJECTIONS TO DEFINITIONS
`
`1.
`
`Finjan incorporates by reference its objections to Definitions set forth in its Responses
`
`to Symantec’s First Set of Interrogatories, dated December 4, 2014; Supplemental Responses to
`
`1
`FINJAN, INC.’S SUPPLEMENTAL RESPONSES
`TO SYMANTEC’s INTERROGATORIES (NO. 1)
`
`CASE NO.: 4:14-CV-02998-HSG
`
`

`

`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 5 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 4 of 19
`
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`Symantec’s First Set of Interrogatories (No. 3), dated December 19, 2014; Supplemental Responses to
`
`Symantec’s First Set of Interrogatories (Nos. 3 and 4), dated February 11, 2015; Supplemental
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`Responses to Symantec’s First Set of Interrogatories (Nos. 1, 5-11), dated April 13, 2015; Responses
`
`to Symantec’s Second Set of Interrogatories (Nos. 12-16), dated April 27, 2015; Responses to
`
`Symantec’s Third Set of Interrogatories (Nos. 17-19), dated November 28, 2016; Supplemental
`
`Responses to Symantec’s First Set of Interrogatories (No. 1), dated December 2, 16; Responses to
`
`Symantec’s Fourth Set of Interrogatories (Nos. 20-21), dated June 2, 2017; Supplemental Responses to
`
`Symantec’s Interrogatories (Nos. 1, 3, 5-18), dated June 7, 2017; Responses to Symantec’s Fifth Set of
`
`Interrogatories (Nos. 22-25), dated June 9, 2017; Supplemental Responses to Symantec’s
`
`Interrogatories (Nos. 18, 23-24), dated July 7, 2017; and Supplemental Responses to Symantec’s
`
`Interrogatories (Nos. 1 and 12), dated July 26, 2017.
`
`INTERROGATORY RESPONSES
`
`Subject to and without waiving its general objections and objections to Definitions set forth
`
`above, each of which is specifically incorporated into the specific Responses contained below, Finjan
`
`hereby responds to Symantec’s Interrogatories as follows:
`
`INTERROGATORY NO. 1:
`
`
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`State the date and location of the first conception and reduction to practice, whether actual or
`
`constructive, of each asserted claim of the Asserted Patents and identify all factual and legal support
`
`therefor, including all evidence relating to diligence between the date of conception and reduction to
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`practice and description of each person’s role and participation in the conception and reduction to
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`practice; all persons having knowledge of such conception, diligence, and reduction to practice; all
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`documents supporting your response (identified by the Bates numbers and including sufficient detail to
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`verify the date, source, and all recipients of the information); and if this information was
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`communicated in an oral or other unrecorded form, provide a complete statement of the
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`communication, the date and time of the communication, and identify all witnesses of this
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`communication.
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`2
`FINJAN, INC.’S SUPPLEMENTAL RESPONSES
`TO SYMANTEC’s INTERROGATORIES (NO. 1)
`
`CASE NO.: 4:14-CV-02998-HSG
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`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 6 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 5 of 19
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`RESPONSE TO INTERROGATORY NO. 1:
`
`Finjan objects to this Interrogatory as overbroad, unduly burdensome, and oppressive to the
`
`extent it seeks information not relevant to any claim or defense of any party and/or not reasonably
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`calculated to lead to the discovery of admissible evidence. Finjan objects to this Interrogatory to the
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`extent it is compound because it is comprised of multiple discrete subparts. Finjan also objects to this
`
`Interrogatory as vague and ambiguous, including the terms “location,” “information,” and “other
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`unrecorded form.” Finjan objects to this Interrogatory to the extent it calls for a legal conclusion.
`
`Finjan objects to this Interrogatory to the extent it seeks information protected by the attorney-client
`
`privilege, the work product doctrine, or any other applicable law, privilege, doctrine, or immunity.
`
`Subject to and without waiving the foregoing general and specific objections, Finjan responds
`
`as follows:
`
`The date of conception for the asserted claims of U.S. Patent No. 6,154,844 (‘the ‘844 Patent”)
`
`is November 8, 1996 when Provisional Application No. 60/030,639 was filed. The date of reduction to
`
`practice for the asserted claims of the ‘844 Patent is November 8, 1996. Shlomo Touboul and
`
`Nachshon Gal were involved with, and may have knowledge related to, the conception and reduction
`
`to practice of the ‘844 Patent.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,613,926 (“the ‘926 Patent”)
`
`is November 8, 1996. The date of reduction to practice of the asserted claims of the ‘926 Patent is
`
`November 6, 1997. Yigal Edery, Nimrod Vered, David Kroll, and Shlomo Touboul were involved
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`with, and may have knowledge related to the conception, diligence, and reduction to practice of the
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`‘926 Patent. Mr. Edery, Mr. Vered, Mr. Kroll, and Mr. Touboul were reasonably diligent in reducing
`
`the inventions of the asserted claims to practice between the date of conception and reduction to
`
`practice. The prosecuting attorney was reasonably diligent from the time of conception in working to
`
`prepare U.S. Patent Application No. 08/964,388.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,757,289 (“the ‘289 Patent”)
`
`is December 12, 2005. The date of reduction to practice of the asserted claims of the ‘289 Patent is
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`3
`FINJAN, INC.’S SUPPLEMENTAL RESPONSES
`TO SYMANTEC’s INTERROGATORIES (NO. 1)
`
`CASE NO.: 4:14-CV-02998-HSG
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`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 7 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 6 of 19
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`December 12, 2005. David Gruzman and Yuval Ben-Itzhak were involved with, and may have
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`knowledge related to the conception and reduction to practice of the ‘289 Patent.
`
`The date of conception for the asserted claims of U.S. Patent No. 8,141,154 (“the ‘154 Patent”)
`
`is December 12, 2005. The date of reduction to practice of the asserted claims of the ‘154 Patent is
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`December 12, 2005. David Gruzman and Yuval Ben-Itzhak were involved with, and may have
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`knowledge related to the conception and reduction to practice of the ‘154 Patent.
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`The date of conception for the asserted claims of U.S. Patent No. 8,667,494 (“the ‘494 Patent”)
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`is November 8, 1996. The date of reduction to practice of the asserted claims of the ‘494 Patent is
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`November 8, 1996. Yigal Edery, Nimrod Vered, David Kroll, and Shlomo Touboul were involved
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`with, and may have knowledge related to the conception and reduction to practice of the ‘494 Patent.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,930,299 (“the ‘299 Patent”)
`
`is no later than November 30, 2005. The date of reduction to practice of the asserted claims of the
`
`‘299 Patent is no later than November 30, 2005. Yuval Ben-Itzhak and Limor Elbaz were involved
`
`with, and may have knowledge related to the conception and reduction to practice of the ‘299 Patent.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,756,996 (“the ‘996 Patent”)
`
`is no later than January 30, 2004. The date of reduction to practice of the asserted claims of the ‘996
`
`Patent is no later than January 30, 2004. Shlomo Touboul was involved with, and may have
`
`knowledge related to the conception and reduction to practice of the asserted claims of the ‘996 Patent.
`
`The date of conception for the asserted claims of U.S. Patent No. 8,015,182 (“the 182 Patent”)
`
`is no later than November 30, 2005. The date of reduction to practice of the asserted claims of the
`
`‘182 Patent is no later than November 30, 2005. Yuval Ben-Itzhak and Limor Elbaz were involved
`
`with, and may have knowledge related to the conception and reduction to practice of the asserted
`
`claims of the ‘182 Patent.
`
`Documents supporting this response include: FINJAN-SYM 000001-3051. Finjan’s
`
`investigation of this matter is ongoing and it will comply with Fed. R. Civ. P. 26(e) should additional
`
`information become known to it.
`
`4
`FINJAN, INC.’S SUPPLEMENTAL RESPONSES
`TO SYMANTEC’s INTERROGATORIES (NO. 1)
`
`CASE NO.: 4:14-CV-02998-HSG
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`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 8 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 7 of 19
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`FIRST SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 1:
`
`Finjan incorporates by reference its prior served objections and response to this Interrogatory.
`
`Subject to and without waiving the incorporated general and specific objections, Finjan responds as
`
`follows:
`
`The date of conception for the asserted claims of U.S. Patent No. 6,154,844 (‘the ‘844 Patent”)
`
`is November 8, 1996 when Provisional Application No. 60/030,639 was filed. The date of reduction to
`
`practice for the asserted claims of the ‘844 Patent is November 8, 1996. Shlomo Touboul and
`
`Nachshon Gal were involved with, and may have knowledge related to, the conception and reduction
`
`to practice of the ‘844 Patent. Relevant documents are: FINJAN-SYM 065928-60, FINJAN-SYM
`
`000001-227.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,613,926 (“the ‘926 Patent”)
`
`is November 8, 1996. The date of reduction to practice of the asserted claims of the ‘926 Patent is
`
`November 6, 1997. Yigal Edery, Nimrod Vered, David Kroll, and Shlomo Touboul were involved
`
`with, and may have knowledge related to the conception, diligence, and reduction to practice of the
`
`‘926 Patent. Mr. Edery, Mr. Vered, Mr. Kroll, and Mr. Touboul were reasonably diligent in reducing
`
`the inventions of the asserted claims to practice between the date of conception and reduction to
`
`practice. The prosecuting attorney was reasonably diligent from the time of conception in working to
`
`prepare U.S. Patent Application No. 08/964,388. Relevant documents are: FINJAN-SYM 065928-60,
`
`FINJAN-SYM 000228-541, FINJAN-SYM 068465-702.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,757,289 (“the ‘289 Patent”)
`
`is December 12, 2005. The date of reduction to practice of the asserted claims of the ‘289 Patent is
`
`December 12, 2005. David Gruzman and Yuval Ben-Itzhak were involved with, and may have
`
`knowledge related to the conception and reduction to practice of the ‘289 Patent. Relevant documents
`
`are: FINJAN-SYM 000696-981.
`
`The date of conception for the asserted claims of U.S. Patent No. 8,141,154 (“the ‘154 Patent”)
`
`is December 12, 2005. The date of reduction to practice of the asserted claims of the ‘154 Patent is
`
`December 12, 2005. David Gruzman and Yuval Ben-Itzhak were involved with, and may have
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`5
`FINJAN, INC.’S SUPPLEMENTAL RESPONSES
`TO SYMANTEC’s INTERROGATORIES (NO. 1)
`
`CASE NO.: 4:14-CV-02998-HSG
`
`

`

`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 9 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 8 of 19
`
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`knowledge related to the conception and reduction to practice of the ‘154 Patent. Relevant documents
`
`are: FINJAN-SYM 001797-2076; FINJAN-SYM 000696-981.
`
`The date of conception for the asserted claims of U.S. Patent No. 8,667,494 (“the ‘494 Patent”)
`
`is November 8, 1996. The date of reduction to practice of the asserted claims of the ‘494 Patent is
`
`November 8, 1996. Yigal Edery, Nimrod Vered, David Kroll, and Shlomo Touboul were involved
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`with, and may have knowledge related to the conception and reduction to practice of the ‘494 Patent.
`
`Relevant documents are: FINJAN-SYM 065928-60, FINJAN-SYM 002077-3051.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,930,299 (“the ‘299 Patent”)
`
`is no later than November 30, 2005. The date of reduction to practice of the asserted claims of the
`
`‘299 Patent is no later than November 30, 2005. Yuval Ben-Itzhak and Limor Elbaz were involved
`
`with, and may have knowledge related to the conception and reduction to practice of the ‘299 Patent.
`
`Relevant documents are: FINJAN-SYM 000982-1336; FINJAN-SYM 073484-96.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,756,996 (“the ‘996 Patent”)
`
`is no later than January 30, 2004. The date of reduction to practice of the asserted claims of the ‘996
`
`Patent is no later than January 30, 2004. Shlomo Touboul was involved with, and may have
`
`knowledge related to the conception and reduction to practice of the asserted claims of the ‘996 Patent.
`
`Relevant documents are: FINJAN-SYM 000542-695.
`
`The date of conception for the asserted claims of U.S. Patent No. 8,015,182 (“the 182 Patent”)
`
`is no later than November 30, 2005. The date of reduction to practice of the asserted claims of the
`
`‘182 Patent is no later than November 30, 2005. Yuval Ben-Itzhak and Limor Elbaz were involved
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`with, and may have knowledge related to the conception and reduction to practice of the asserted
`
`claims of the ‘182 Patent. Relevant documents are: FINJAN-SYM 001337-1796, FINJAN-SYM
`
`073484-96.
`
`Finjan’s investigation of this matter is ongoing and it will comply with Fed. R. Civ. P. 26(e)
`
`should additional information become known to it.
`
`6
`FINJAN, INC.’S SUPPLEMENTAL RESPONSES
`TO SYMANTEC’s INTERROGATORIES (NO. 1)
`
`CASE NO.: 4:14-CV-02998-HSG
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`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 10 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 9 of 19
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`SECOND SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 1:
`
`Finjan incorporates by reference its prior served objections to this Interrogatory. Subject to and
`
`without waiving the incorporated general and specific objections, Finjan responds as follows:
`
`The date of conception for the asserted claims of U.S. Patent No. 6,154,844 (‘the ‘844 Patent”)
`
`is November 8, 1996 when Provisional Application No. 60/030,639 was filed. The date of reduction to
`
`practice for the asserted claims of the ‘844 Patent is November 8, 1996. Shlomo Touboul and
`
`Nachshon Gal were involved with, and may have knowledge related to, the conception and reduction
`
`to practice of the ‘844 Patent. Relevant documents are: FINJAN-SYM 065928-60, FINJAN-SYM
`
`000001-227.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,613,926 (“the ‘926 Patent”)
`
`is November 8, 1996. The date of reduction to practice of the asserted claims of the ‘926 Patent is
`
`November 6, 1997. Yigal Edery, Nimrod Vered, David Kroll, and Shlomo Touboul were involved
`
`with, and may have knowledge related to the conception, diligence, and reduction to practice of the
`
`‘926 Patent. Mr. Edery, Mr. Vered, Mr. Kroll, and Mr. Touboul were reasonably diligent in reducing
`
`the inventions of the asserted claims to practice between the date of conception and reduction to
`
`practice. The prosecuting attorney was reasonably diligent from the time of conception in working to
`
`prepare U.S. Patent Application No. 08/964,388. Relevant documents are: FINJAN-SYM 065928-60,
`
`FINJAN-SYM 000228-541, FINJAN-SYM 068465-702.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,757,289 (“the ‘289 Patent”)
`
`is at least by October 31, 2005. The date of reduction to practice of the asserted claims of the ‘289
`
`Patent is December 12, 2005. David Gruzman, Yuval Ben-Itzhak and Marc Berger were involved
`
`with, and may have knowledge related to the conception and reduction to practice of the ‘289 Patent.
`
`Mr. Gruzman, Mr. Ben-Itzhak and Mr. Berger were reasonably diligent in reducing the invention of
`
`the asserted claims practiced between the date of conception and reduction to practice. Relevant
`
`documents related to the date of conception and diligent reduction to practice are: FINJAN-SYM
`
`000696-981, FINJAN-SYM141836-55, FINJAN-SYM141856-65, FINJAN-SYM141938-42, and
`
`FINJAN-SYM141943-46.
`
`7
`FINJAN, INC.’S SUPPLEMENTAL RESPONSES
`TO SYMANTEC’s INTERROGATORIES (NO. 1)
`
`CASE NO.: 4:14-CV-02998-HSG
`
`

`

`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 11 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 10 of 19
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`The date of conception for the asserted claims of U.S. Patent No. 8,141,154 (“the ‘154 Patent”)
`
`is at least by October 31, 2005. The date of reduction to practice of the asserted claims of the ‘154
`
`Patent is December 12, 2005. David Gruzman, Yuval Ben-Itzhak and Marc Berger were involved
`
`with, and may have knowledge related to the conception and reduction to practice of the ‘154 Patent.
`
`Mr. Gruzman, Mr. Ben-Itzhak and Mr. Berger were reasonably diligent in reducing the invention of
`
`the asserted claims practiced between the date of conception and reduction to practice. Relevant
`
`documents related to the date of conception and diligent reduction to practice are: FINJAN-SYM
`
`000696-981, FINJAN-SYM141836-55, FINJAN-SYM141856-65, FINJAN-SYM141938-42, and
`
`FINJAN-SYM141943-46.
`
`The date of conception for the asserted claims of U.S. Patent No. 8,667,494 (“the ‘494 Patent”)
`
`is November 8, 1996. The date of reduction to practice of the asserted claims of the ‘494 Patent is
`
`November 8, 1996. Yigal Edery, Nimrod Vered, David Kroll, and Shlomo Touboul were involved
`
`with, and may have knowledge related to the conception and reduction to practice of the ‘494 Patent.
`
`Relevant documents are: FINJAN-SYM 065928-60, FINJAN-SYM 002077-3051.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,930,299 (“the ‘299 Patent”)
`
`is no later than November 30, 2005. The date of reduction to practice of the asserted claims of the
`
`‘299 Patent is no later than November 30, 2005. Yuval Ben-Itzhak and Limor Elbaz were involved
`
`with, and may have knowledge related to the conception and reduction to practice of the ‘299 Patent.
`
`Relevant documents are: FINJAN-SYM 000982-1336; FINJAN-SYM 073484-96.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,756,996 (“the ‘996 Patent”)
`
`is no later than January 30, 2004. The date of reduction to practice of the asserted claims of the ‘996
`
`Patent is no later than January 30, 2004. Shlomo Touboul was involved with, and may have
`
`knowledge related to the conception and reduction to practice of the asserted claims of the ‘996 Patent.
`
` Relevant documents are: FINJAN-SYM 000542-695. The date of conception for the asserted
`
`claims of U.S. Patent No. 8,015,182 (“the 182 Patent”) is no later than November 30, 2005. The date
`
`of reduction to practice of the asserted claims of the ‘182 Patent is no later than November 30, 2005.
`
`Yuval Ben-Itzhak and Limor Elbaz were involved with, and may have knowledge related to the
`
`8
`FINJAN, INC.’S SUPPLEMENTAL RESPONSES
`TO SYMANTEC’s INTERROGATORIES (NO. 1)
`
`CASE NO.: 4:14-CV-02998-HSG
`
`

`

`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 12 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 11 of 19
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`conception and reduction to practice of the asserted claims of the ‘182 Patent. Relevant documents
`
`are: FINJAN-SYM 001337-1796, FINJAN-SYM 073484-96.
`
`Finjan’s investigation of this matter is ongoing and it will comply with Fed. R. Civ. P. 26(e)
`
`should additional information become known to it.
`
`THIRD SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 1:
`
`Finjan incorporates by reference its prior served objections to this Interrogatory. Subject to and
`
`without waiving the incorporated general and specific objections, Finjan responds as follows:
`
`The date of conception for the asserted claims of U.S. Patent No. 6,154,844 (‘the ‘844 Patent”)
`
`is November 8, 1996 when Provisional Application No. 60/030,639 was filed. The date of reduction to
`
`practice for the asserted claims of the ‘844 Patent is November 8, 1996. Shlomo Touboul and
`
`Nachshon Gal were involved with, and may have knowledge related to, the conception and reduction
`
`to practice of the ‘844 Patent. Relevant documents are: FINJAN-SYM 065928-60, FINJAN-SYM
`
`000001-227.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,613,926 (“the ‘926 Patent”)
`
`began November 8, 1996 and continued through May 2000. The date of constructive reduction to
`
`practice of the asserted claims of the ‘926 Patent is no later than March 7, 2006. Yigal Edery, Nimrod
`
`Vered, David Kroll, and Shlomo Touboul were involved with, and may have knowledge related to the
`
`conception, diligence, and reduction to practice of the ‘926 Patent. Mr. Edery, Mr. Vered, Mr. Kroll,
`
`and Mr. Touboul were reasonably diligent in reducing the inventions of the asserted claims to practice
`
`between the date of conception and reduction to practice. Relevant documents are: FINJAN-SYM
`
`065928-60, FINJAN-SYM 000228-541, FINJAN-SYM 068465-702. See also the deposition of the
`
`David Kroll.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,757,289 (“the ‘289 Patent”)
`
`is at least by October 31, 2005. The date of reduction to practice of the asserted claims of the ‘289
`
`Patent is December 12, 2005. David Gruzman, Yuval Ben-Itzhak and Marc Berger were involved
`
`with, and may have knowledge related to the conception and reduction to practice of the ‘289 Patent.
`
`Mr. Gruzman, Mr. Ben-Itzhak and Mr. Berger were reasonably diligent in reducing the invention of
`
`9
`FINJAN, INC.’S SUPPLEMENTAL RESPONSES
`TO SYMANTEC’s INTERROGATORIES (NO. 1)
`
`CASE NO.: 4:14-CV-02998-HSG
`
`

`

`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 13 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 12 of 19
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`the asserted claims practiced between the date of conception and reduction to practice. Relevant
`
`documents related to the date of conception and diligent reduction to practice are: FINJAN-SYM
`
`000696-981, FINJAN-SYM141836-55, FINJAN-SYM141856-65, FINJAN-SYM141938-42, and
`
`FINJAN-SYM141943-46.
`
`The date of conception for the asserted claims of U.S. Patent No. 8,141,154 (“the ‘154 Patent”)
`
`is at least by October 31, 2005. The date of reduction to practice of the asserted claims of the ‘154
`
`Patent is December 12, 2005. David Gruzman, Yuval Ben-Itzhak and Marc Berger were involved
`
`with, and may have knowledge related to the conception and reduction to practice of the ‘154 Patent.
`
`Mr. Gruzman, Mr. Ben-Itzhak and Mr. Berger were reasonably diligent in reducing the invention of
`
`the asserted claims practiced between the date of conception and reduction to practice. Relevant
`
`documents related to the date of conception and diligent reduction to practice are: FINJAN-SYM
`
`000696-981, FINJAN-SYM141836-55, FINJAN-SYM141856-65, FINJAN-SYM141938-42, and
`
`FINJAN-SYM141943-46.
`
`The date of conception for the asserted claims of U.S. Patent No. 8,667,494 (“the ‘494 Patent”)
`
`began October 31, 1996 and continued through May 2000. The date of constructive reduction of
`
`practice of the asserted claims of the ‘494 Patent is no later than November 7, 2011. Yigal Edery,
`
`Nimrod Vered, David Kroll, and Shlomo Touboul were involved with, and may have knowledge
`
`related to the conception and reduction to practice of the ‘494 Patent. Relevant documents are:
`
`FINJAN-SYM 065928-60, FINJAN-SYM 002077-3051, in particular FINJAN-SYM 002223. See
`
`also the deposition of the David Kroll.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,930,299 (“the ‘299 Patent”)
`
`is no later than November 30, 2005. The date of reduction to practice of the asserted claims of the
`
`‘299 Patent is no later than November 30, 2005. Yuval Ben-Itzhak and Limor Elbaz were involved
`
`with, and may have knowledge related to the conception and reduction to practice of the ‘299 Patent.
`
`Relevant documents are: FINJAN-SYM 000982-1336; FINJAN-SYM 073484-96.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,756,996 (“the ‘996 Patent”)
`
`is no later than January 30, 2004. The date of reduction to practice of the asserted claims of the ‘996
`
`10
`FINJAN, INC.’S SUPPLEMENTAL RESPONSES
`TO SYMANTEC’s INTERROGATORIES (NO. 1)
`
`CASE NO.: 4:14-CV-02998-HSG
`
`

`

`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 14 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 13 of 19
`
`
`Patent is no later than January 30, 2004. Shlomo Touboul was involved with, and may have
`
`knowledge related to the conception and reduction to practice of the asserted claims of the ‘996 Patent.
`
` Relevant documents are: FINJAN-SYM 000542-695. The date of conception for the asserted
`
`claims of U.S. Patent No. 8,015,182 (“the 182 Patent”) is no later than November 30, 2005. The date
`
`of reduction to practice of the asserted claims of the ‘182 Patent is no later than November 30, 2005.
`
`Yuval Ben-Itzhak and Limor Elbaz were involved with, and may have knowledge related to the
`
`conception and reduction to practice of the asserted claims of the ‘182 Patent. Relevant documents
`
`are: FINJAN-SYM 001337-1796, FINJAN-SYM 073484-96.
`
`Finjan’s investigation of this matter is ongoing and it will comply with Fed. R. Civ. P. 26(e)
`
`should additional information become known to it.
`
`FOURTH SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 1:
`
`Finjan incorporates by reference its prior served objections to this Interrogatory. Subject to and
`
`without waiving the incorporated general and specific objections, Finjan responds as follows:
`
`The date of conception for the asserted claims of U.S. Patent No. 6,154,844 (‘the ‘844 Patent”)
`
`is November 8, 1996 when Provisional Application No. 60/030,639 was filed. The date of reduction to
`
`practice for the asserted claims of the ‘844 Patent is November 8, 1996. Shlomo Touboul and
`
`Nachshon Gal were involved with, and may have knowledge related to, the conception and reduction
`
`to practice of the ‘844 Patent. Relevant documents are: FINJAN-SYM 065928-60, FINJAN-SYM
`
`000001-227.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,613,926 (“the ‘926 Patent”)
`
`began November 8, 1996 and continued through May 2000. The date of constructive reduction to
`
`practice of the asserted claims of the ‘926 Patent is no later than March 7, 2006. Yigal Edery, Nimrod
`
`Vered, David Kroll, and Shlomo Touboul were involved with, and may have knowledge related to the
`
`conception, diligence, and reduction to practice of the ‘926 Patent. Mr. Edery, Mr. Vered, Mr. Kroll,
`
`and Mr. Touboul were reasonably diligent in reducing the inventions of the asserted claims to practice
`
`between the date of conception and reduction to practice. Relevant documents are: FINJAN-SYM
`
`11
`FINJAN, INC.’S SUPPLEMENTAL RESPONSES
`TO SYMANTEC’s INTERROGATORIES (NO. 1)
`
`CASE NO.: 4:14-CV-02998-HSG
`
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`

`

`Case 3:17-cv-05659-WHA Document 111-8 Filed 06/15/18 Page 15 of 20
`Case 4:14-cv-02998-HSG Document 242-11 Filed 08/18/17 Page 14 of 19
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`065928-60, FINJAN-SYM 000228-541, FINJAN-SYM 068465-702, FINJAN-SYM 447977. See also
`
`the deposition of the David Kroll.
`
`The date of conception for the asserted claims of U.S. Patent No. 7,757,289 (“the ‘289 Patent”)
`
`is at least by October 31, 2005. The date of reduction to practice of the asserted claims of the ‘289
`
`Patent is December 12, 2005. David Gruzman, Yuval Ben-Itzhak and Marc Berger were involved
`
`with, and may have knowledge related to the conception and reduction to practice of the ‘289 Patent.
`
`Mr. Gruzman, Mr. Ben-Itzhak and Mr. Berger were reasonably diligent in reducing the invention of
`
`the asserted claims practiced between the date of conception and reduction to practice. Relevant
`
`documents related to the date of conception and di