`Case 3:17-cv-05659-WHA Document 371-16 Filed 02/14/19 Page 1 of 4
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`EXHIBIT 12
`EXHIBIT 12
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`Case 3:17-cv-05659-WHA Document 371-16 Filed 02/14/19 Page 2 of 4
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`241
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`IN THE UNITES STATES DISTRICT COURT
`
`IN AND FOR THE DISTRICT OF DELAWARE
`- - -
`FINJAN SOFTWARE LTD.,
`Plaintiff,
`
`:
`:
`
`Civil Action
`No. 06-369(GMS)
`
`::
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`:
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`Defendants.
`- - -
`Wilmington, Delaware
`Tuesday, March 4, 2008
`8:30 a.m.
`Day Two of Trial
`- - -
`BEFORE: HONORABLE GREGORY M. SLEET, Chief Judge,
`and a Jury
`
`APPEARANCES:
`
`PHILIP A. ROVNER, ESQ.
`Potter Anderson & Corroon LLP
`-and-
`PAUL J. ANDRE, ESQ.,
`LISA KOBIALKA, ESQ.,
`JAMES HANNAH, ESQ.,
`MEGHAN WARTON, ESQ.,
`KRIS KASTENS, ESQ., and
`HANNAH LEE, ESQ.
`King & Spalding
`(Silicon Valley, California)
`Counsel for Plaintiff
`
`::
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`::
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`v.
`SECURE COMPUTING CORPORATION,
`CYBERGUARD CORPORATION,
`WEBWASHERE AG and DOES 1
`THROUGH 100,
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`415
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`Case 3:17-cv-05659-WHA Document 371-16 Filed 02/14/19 Page 3 of 4
`Vigna - direct
`With respect to Claim 65, do you find that every
`Q.
`element of Claim 65 literally infringes -- strike that.
`Do you find that the Webwasher product literally
`infringes every claim element of Claim 65?
`Yes, I think so.
`A.
`At least does the Webwasher product perform
`Q.
`substantially the same function as that described in Claim
`65?
`Yes, it does.
`A.
`Does at least the Webwasher product perform
`Q.
`substantially the same way as in Claim 65?
`Yes, it does.
`A.
`And at least does the Webwasher product yield the same
`Q.
`result as that which is claimed in Claim 65?
`Yes, it does.
`A.
`Is that for every single element in Claim 65?
`Q.
`Yes.
`A.
`Thank you.
`Q.
`So that's it for the '194 patent. I
`All right.
`would like to turn your attention to the '780 patent.
`Dr. Vigna, could you just give a very brief
`description of what is claimed in Claim 1 of the '780
`patent?
`Yes.
`A.
`
`So in this patent, a method is disclosed to
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`Case 3:17-cv-05659-WHA Document 371-16 Filed 02/14/19 Page 4 of 4
`Vigna - direct
`compute a unique ID of a downloadable for md5, a
`downloadable itself. The idea is that is that a
`But the
`downloadable is retrieved and an ID is computed.
`downloadable also references other components. Also
`together with the first component, other components are also
`analyzed and an ID is generated.
`This ID is then used to identify or to determine
`if a downloadable has been seen before. And the way in
`which this ID is created is by performing a hash function.
`Here I have to do a very short digression on
`what a hash function is.
`So, again, a hash function is, it's a way to
`take an object and generate in a secure way a unique idea.
`A secure way means that if two objects are different, then
`they will have different IDs.
`And it is very hard
`computationally, given an ID, to generate another object
`that will have the same ID. You have to sort of believe me
`here because there are actually pretty complex mathematics
`behind these type of functions. Here we are not really
`discussing these functions working or not.
`They are used in
`computer science and programs every day.
`One, for example, of the most known functions is
`called md5. Shawan (phonetic) is another example of such
`type of functions.
`They are used to generate unique IDs for
`these downloadables.
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