Case 3:17-cv-05659-WHA Document 113-6 Filed 06/22/18 Page 1 of 4
`Case 3:17-cv-05659-WHA Document 113-6 Filed 06/22/18 Page 1 of 4
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`EXHIBIT E
`EXHIBIT E
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`Case 3:17-cv-05659-WHA Document 113-6 Filed 06/22/18 Page 2 of 4
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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
`KRISTOPHER KASTENS (State Bar No. 254797)
`kkastens@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.
`
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCISCO DIVISION
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`FINJAN, INC., a Delaware Corporation,
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`
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`Plaintiff,
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`v.
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`Case No.: 3:17-cv-05659-WHA
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`PLAINTIFF FINJAN, INC.’S INITIAL
`DISCLOSURE OF ASSERTED CLAIMS
`AND INFRINGEMENT CONTENTIONS
`AND DOCUMENT PRODUCTION
`REGARDING U.S. PATENT NO. 7,418,731
`PURSUANT TO PATENT LOCAL RULES
`3-1 AND 3-2
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`
`
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`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
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`
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`Defendant.
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`____________________________________________________________________________________
`FINJAN’S ASSERTED CLAIMS & INFRINGEMENT
`CASE NO. 3:17-cv-05659-WHA
`CONTENTIONS PURSUANT TO PATENT L.R. 3-1 AND 3-2
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`Case 3:17-cv-05659-WHA Document 113-6 Filed 06/22/18 Page 3 of 4
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`Pursuant to Patent Local Rules 3-1 and 3-2 of the United States District Court for the Northern
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`District of California, Plaintiff Finjan, Inc. (“Finjan”) makes the following Initial Disclosure of
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`Asserted Claims and Infringement Contentions and Document Production Accompanying Disclosure
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`Regarding U.S. Patent No. 7,418,731 (the “’731 Patent”), including the attached claim charts (the
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`“Disclosure”) to Juniper Networks, Inc. (hereinafter “Juniper” or “Defendant”).
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`Finjan makes this Disclosure based upon information presently known and reasonably available
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`to it as of this date, as Finjan’s investigations are ongoing and Defendant has yet to provide any
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`discovery. Accordingly, Finjan reserves the right to amend, modify, supplement, or narrow any
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`portion of this Disclosure, including, but not limited to, the identification of the claims infringed by
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`Defendant, the products and/or services accused of infringement and the bases and manner of
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`infringement described in this Disclosure. Finjan reserves the right to supplement this Disclosure as
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`necessary and as appropriate in accordance with the Federal Rules of Civil Procedure and this Court’s
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`Local Rules, including Patent Local Rule 3-6, in light of future document production, interrogatory
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`responses, admissions, disclosures, contentions, fact witness testimony, expert discovery, any other
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`discovery, future rulings from the Court (including claim construction), any amendments to the
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`pleadings, any additional items of evidence, and/or for any other reason authorized by statute, rule, or
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`applicable case law. Finjan further reserves the right to rely upon the opinions of one or more experts
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`in support of its infringement contentions in accordance with the Court’s scheduling order.
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`To the maximum degree allowed by the Federal Rules of Civil Procedure and the Court’s Local
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`Rules, Finjan reserves its right to supplement, amend, modify and/or narrow this Disclosure, as
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`appropriate, as the extent of infringement becomes more fully known, the Court makes any relevant
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`rulings (including claim construction), and the case develops over the course of discovery.
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`I.
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`PATENT L.R. 3-1: DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT
`CONTENTIONS.
`A.
`Identification Of Asserted Claims And Applicable Subsections Of 35 U.S.C. § 271.
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`Finjan provides the following contentions pursuant to Patent Local Rule 3-1(a):
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`FINJAN’S ASSERTED CLAIMS & INFRINGEMENT
`CONTENTIONS PURSUANT TO PATENT L.R. 3-1 AND 3-2
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`CASE NO. 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 113-6 Filed 06/22/18 Page 4 of 4
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`Defendant directly infringed pursuant to 35 U.S.C. § 271(a) claims 1, 15, and 41 of U.S. Pat.
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`No. 6,154,844 (“the ‘844 Patent”), claims 1 and 9 of U.S. Patent No. 6,804,780 (“the ‘780 Patent”),
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`claims 15 and 22 of U.S. Patent No. 7,613,926 (“the ‘926 Patent”); claims 1, 8, 14, and 19 of U.S.
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`Patent No. 7,647,633 (“the ‘633 Patent”), claim 1 of U.S. Patent No. 8,141,154 (“the ‘154 Patent”),
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`and claims 10, 14, and 18 of U.S. Patent No. 8,677,494 (“the ‘494 Patent”), and claims 1 and 17 of the
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`‘731 Patent (collectively, the “Asserted Claims”).
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`Finjan reserves the right to amend, modify, supplement, or narrow these contentions, as
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`appropriate, pursuant to Patent Local Rule 3-6, including identifying additional asserted claims, as it
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`obtains additional information over the course of discovery and in light of the Court’s claim
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`construction order.
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`B.
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`Identification of Accused Instrumentalities.
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`Finjan provides the following contentions pursuant to Patent Local Rule 3-1(b):
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`Finjan accuses the following of Defendant’s products and/or services, and associated software
`and subscriptions, of infringing claims 1, 15, and 41 of the ‘844 Patent: SRX Gateways1, Space
`Security Director2, Sky ATP3, ATP Appliances4, and Spotlight Secure service identified in the
`attached Appendices A-1 through A-3 (“Accused Instrumentalities of the ‘844 Patent”).
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`Finjan accuses the following of Defendant’s products and/or services, and associated software
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`and subscriptions, of infringing claims 1 and 9 of the ‘780 Patent: SRX Gateways, Space Security
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`Director, Sky ATP, ATP Appliances, and Spotlight Secure service, identified in the attached
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`Appendices B-1 through B-3 (“Accused Instrumentalities of the ‘780 Patent”).
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`1 A list of accused “SRX Gateways” (also called “SRX Series Services Gateways”) are provided in
`Exhibit A attached hereto, and are collectively referred to as “SRX Gateways” or “SRX Series
`Services Gateways.”
`2 A list of the accused “Space Security Director” products is provided in Exhibit A attached hereto, and
`are collectively referred to as “Space Security Director.”
`3 A list of the accused Sky ATP service is provided in Exhibit A attached hereto, and are collectively
`referred to as “Sky ATP.”
`4 A list of the accused ATP Appliance products is provided in Exhibit A attached hereto, and are
`collectively referred to as “ATP Appliances.”
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`2
`FINJAN’S ASSERTED CLAIMS & INFRINGEMENT
`CONTENTIONS PURSUANT TO PATENT L.R. 3-1 AND 3-2
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`CASE NO. 3:17-cv-05659-WHA
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