`
`
`
`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.
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`SAN FRANCISCO DIVISION
`
`FINJAN, INC., a Delaware Corporation,
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
`
`
`Defendant.
`
`
`
`Case No.: 3:17-cv-05659-WHA
`
`DECLARATION OF KRISTOPHER
`KASTENS IN SUPPORT OF PLAINTIFF
`FINJAN, INC.’S OPENING CLAIM
`CONSTRUCTION BRIEF
`
`Date:
`Time:
`Courtroom:
`Before:
`
`
`TBD
`8:00 a.m.
`Courtroom 12, 19th Floor
`Hon. William Alsup
`
`
`
`
`
`
`
`
`DECLARATION OF KRISTOPHER KASTENS IN SUPPORT OF CASE NO. 3:17-cv-05659-WHA
`FINJAN’S OPENING CLAIM CONSTRUCTION BRIEF
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`Case 3:17-cv-05659-WHA Document 176-1 Filed 08/06/18 Page 2 of 3
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`I, Kristopher Kastens, duly declare as follows:
`1.
`
`I am an attorney at Kramer Levin Naftalis & Frankel LLP, a counsel of record for the
`
`plaintiff, Finjan, Inc. (“Finjan”), in the above referenced matter. I have personal knowledge of the
`
`facts stated below and can testify competently to those facts. I submit this declaration in support of
`
`Finjan’s Opening Claim Construction brief.
`2.
`
`Attached hereto as the Exhibit 1 is a true and correct copy of the U.S. Patent No.
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`7,647,633 (“‘633 Patent”).
`3.
`
`Attached hereto as the Exhibit 2 is a true and correct copy of the U.S. Patent No.
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`7,613,926.
`4.
`
`6,804,780.
`5.
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`6,154,844.
`6.
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`8,141,154.
`7.
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`Attached hereto as the Exhibit 3 is a true and correct copy of the U.S. Patent No.
`
`Attached hereto as the Exhibit 4 is a true and correct copy of the U.S. Patent No.
`
`Attached hereto as the Exhibit 5 is a true and correct copy of the U.S. Patent No.
`
`Attached hereto as the Exhibit 6 is a true and correct copy of the Final Written Decision
`
`(Paper 49) entered on March 16, 2017 by the Patent Trial and Appeal Board in IPR2015-01974, Palo
`
`Alto Networks, Inc. v. Finjan, Inc..
`8.
`
`Attached hereto as the Exhibit 7 is a true and correct copy of the Notice of Intent to
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`Issue Ex Parte Reexamination Certificate for U.S. Application No. 90/013,652, related to the ‘633
`
`Patent, dated May 10, 2016.
`9.
`
`Attached hereto as the Exhibit 8 is a true and correct copy of the Declaration of Aviel
`
`D. Rubin dated September 24, 2015, filed in support of Palo Alto Networks, Inc.’s petition for Inter
`
`Partes Review of U.S. Patent No. 7,647,633 in IPR2015-01974.
`10.
`
`Attached hereto as the Exhibit 9 is a true and correct copy of the Joint Claim
`
`Construction Pre-hearing Statement in Finjan, Inc. v. Symantec Corp., Case No. 14-cv-02998-HSG,
`
`Dkt. No. 68, filed on March 16, 2015.
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`1
`DECLARATION OF KRISTOPHER KASTENS IN SUPPORT OF CASE NO. 3:17-cv-05659-WHA
`FINJAN’S OPENING CLAIM CONSTRUCTION BRIEF
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`Case 3:17-cv-05659-WHA Document 176-1 Filed 08/06/18 Page 3 of 3
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`
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`11.
`
`Attached hereto as the Exhibit 10 is a true and correct copy of a Joint Claim
`
`Construction Pre-hearing Statement Finjan, Inc. v. Sophos Inc., Case No. 14-cv-01197-WHO, Dkt. No.
`
`54, filed on October 14, 2014.
`12.
`
`Attached hereto as the Exhibit 11 is a true and correct copy of excerpts from the
`
`Declaration of Jack W. Davidson dated September 10, 2015, filed in support of Symantec
`
`Corporation’s petition for Inter Partes Review in IPR2015-01893.
`13.
`
`Attached hereto as the Exhibit 12 is a true and correct copy of excerpts from the
`
`Declaration of Jack W. Davidson dated September 10, 2015 filed in support of Symantec
`
`Corporation’s petition for Inter Partes Review in IPR2015-01895
`14.
`
`Attached hereto as the Exhibit 13 is a true and correct copy of excerpts from the
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`Declaration of Aviel D. Rubin filed on November 5, 2015 in support of Palo Alto Networks, Inc.’s
`
`petition for Inter Partes Review in IPR2016-00151.
`
`I declare under penalty of perjury under the laws of the United States that the foregoing is true
`
`and correct. Executed on August 6, 2018 in Menlo Park, California.
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`__/s/ Kristopher B. Kastens_________________
` Kristopher B. Kastens
`
`2
`DECLARATION OF KRISTOPHER KASTENS IN SUPPORT OF CASE NO. 3:17-cv-05659-WHA
`FINJAN’S OPENING CLAIM CONSTRUCTION BRIEF
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