`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`FINJAN, INC.,
`Plaintiff,
`
` v.
`JUNIPER NETWORKS, INC.,
`Defendant.
` /
`
`No. C 17-05659 WHA
`
`REQUEST FOR RESPONSE
`RE EARLY MOTION FOR
`SUMMARY JUDGMENT RE
`’494 PATENT
`
`By TOMORROW AT NOON, counsel for both sides shall please address the following:
`1.
`Regarding Juniper’s “database” construction, did the PTAB actually rely upon
`Finjan’s distinction between “flat file” and “flat file database?” If not, on what authority can
`Juniper argue that Finjan’s distinction amounts to a true disclaimer?
`2.
`A WRITE command is a legitimate command, but it is disclosed as a suspicious
`computer operation in the ’194 patent at column 5 line 59. Where in the ’194 patent does it
`explain how to distinguish between a suspicious versus non-suspicious operation? Is the failure
`to give such an explanation fatal to Claim 10?
`3.
`Why shouldn’t the Court hold that “suspicious computer operations” is
`inherently subjective and Claim 10 is therefore indefinite unless limited to the specific list set
`forth in the “Example List of Operations Deemed Potentially Hostile” (’194 patent at
`5:58–6:4)?
`
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`For the Northern District of California
`
`United States District Court
`
`
`
`Case 3:17-cv-05659-WHA Document 181 Filed 08/20/18 Page 2 of 2
`
`Supplemental briefs shall not exceed EIGHT PAGES. Counsel shall cite to chapter and
`verse. Complete candor is required. No ellipses, but italics may be used.
`
`IT IS SO ORDERED.
`
`Dated: August 20, 2018.
`
`
`WILLIAM ALSUP
`UNITED STATES DISTRICT JUDGE
`
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`For the Northern District of California
`
`United States District Court
`
`
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