`Case 3:17-cv-05659-WHA Document 371-17 Filed 02/14/19 Page 1 of 4
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`EXHIBIT 13
`EXHIBIT 13
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`Case 3:17-cv-05659-WHA Document 371-17 Filed 02/14/19 Page 2 of 4
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`685
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`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
`Thursday, March 6, 2008
`9:00 a.m.
`Day four 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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`:
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`::
`
`v.
`SECURE COMPUTING CORPORATION,
`CYBERGUARD CORPORATION,
`WEBWASHER AG and DOES 1
`THROUGH 100,
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`774
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`Case 3:17-cv-05659-WHA Document 371-17 Filed 02/14/19 Page 3 of 4
`Edery - direct
`when in 1997 you began your work at Finjan?
`"Answer: I'm not sure.
`I think it was
`September of '97, but I'm not 100 percent sure.
`"Question:
`What was your job title when you
`began your work at Finjan?
`"Answer: I was a software developer.
`"Question:
`When did you end your employment
`
`with Finjan?
`
`"Answer: I was with Finjan for five years, so
`that would make it 2002.
`What were your job responsibilities
`"Question:
`as a software developer at Finjan?
`"Answer: When? I spent five years at Finjan,
`
`so....
`
`Fair.
`"Question:
`"When you began work at Finjan in 1997, what
`were your job responsibilities?
`"Answer: I was a developer in the team that
`wrote SurfinGate.
`"Question:
`
`Do you know what a hashing function
`
`is?
`
`"Answer: I do.
`"Question:
`Did you know what a hashing function
`was prior to your employment at Finjan?
`"Answer: I probably heard about it in the
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`Case 3:17-cv-05659-WHA Document 371-17 Filed 02/14/19 Page 4 of 4
`Edery - direct
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`775
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`university.
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`And you studied at the university
`
`"Question:
`between what dates?
`"Answer: That's a good question. I started
`around '85, '86, and did it for about seven years.
`"Question:
`So hashing functions were known to
`computer programmers while you were in school between '85
`and '91?
`
`"Answer: Hashing functions were known, yes.
`"Question:
`So hashing functions had been
`well-known for quite some time?
`"Answer: Yes.
`"Question:
`And what is the purpose of hashing
`
`functions?
`
`"Answer: You can use them for many different
`reasons. Basically to identify -- uniquely identify a block
`of data in an easy way.
`So it's been well-known that a
`"Question:
`hashing function can be used to uniquely identify a log of
`data for years, at least as early as the late 1980s?
`"Answer: Yes."
`Your Honor, Secure Computing
`MR. HOLDREITH:
`would call Dan Wallach as an expert witness.
`DAN WALLACH, having been duly
`sworn as a witness, was examined and testified as follows:
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