`Case 3:17-cv-05659-WHA Document 371-18 Filed 02/14/19 Page 1 of 4
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`Case 3:17-cv-05659-WHA Document 371-18 Filed 02/14/19 Page 2 of 4
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` Pages 1 - 115
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`Before The Honorable William H. Alsup, Judge
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`)
`FINJAN, INC.,
` )
` Plaintiff, )
` )
` VS. ) NO. C 17-05659 WHA
` )
`JUNIPER NETWORK, INC.,
`)
` )
` Defendant.
`)
` )
` San Francisco, California
` Thursday, July 26, 2018
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`TRANSCRIPT OF PROCEEDINGS
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`APPEARANCES:
`For Plaintiff:
` KRAMER, LEVIN, NAFTALIS & FRANKEL LLP
` 990 Marsh Road
` Menlo Park, California 94025
` BY: PAUL J. ANDRE, ATTORNEY AT LAW
` KRISTOPHER KASTENS, ATTORNEY AT LAW
` JAMES HANNAH, ATTORNEY AT LAW
` PHUONG (STEPHANIE) NGUYEN, ATTORNEY AT LAW
`
`For Defendant:
` IRELL & MANELLA LLP
` 1800 Avenue of the Stars - Suite 900
` Los Angeles, California 90067
` BY: JONATHAN S. KAGAN, ATTORNEY AT LAW
` CASEY CURRAN, ATTORNEY AT LAW
` JOSHUA GLUCOFT, ATTORNEY AT LAW
` SHARON SONG, ATTORNEY AT LAW
`
` IRELL & MANELLA LLP
` 840 Newport Center Drive - Suite 400
` Newport Beach, California 92660
` BY: REBECCA CARSON, ATTORNEY AT LAW
`
`Reported By: Jo Ann Bryce, CSR No. 3321, RMR, CRR, FCRR
` Official Reporter
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`
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`Case 3:17-cv-05659-WHA Document 371-18 Filed 02/14/19 Page 3 of 4
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`(reading):
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`"QUESTION: You mention a sample ID or SHA, SHA-256?
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`"ANSWER: SHA-256.
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`"QUESTION: What is a sample ID?
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`"THE WITNESS: In order to identify samples or files
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`that are coming into Sky ATP, we perform a hash, the
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`SHA-256, on the contents of the files."
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`So he admitted right there that they actually hash all the
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`incoming files, and this is from the perspective of Sky ATP.
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`THE COURT: Well, but she's saying that they do do a
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`hash on the incoming files. What they don't do is a hash on
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`the combined file of the downloadable plus the fetched file.
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`MR. HANNAH: Well, Your Honor --
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`THE COURT: So I don't see your point here.
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`MR. HANNAH: But, Your Honor, the first one that I
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`showed you on the right, that is the combined hash. That's a
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`hash on the Word document that includes -- they hash in
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`multiple instances. So we can -- we're just picking slices
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`that are -- we're just picking slices. So that first document
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`that comes in with the dropped ransom executable, that's number
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`one. That Word file contains --
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`THE COURT: Well, what is the fetch in that one?
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`MR. HANNAH: Exactly. So it's the dropped ransom
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`executable. So once you fetch that, they take that and store
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`it in.
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`So, I mean --
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`THE COURT: Wait. Wait. Wait a minute. I thought
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`you were saying that the Microsoft Word document was the
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`downloadable.
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`MR. HANNAH: It is.
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`THE COURT: And so what would be the fetched document?
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`MR. HANNAH: The dropped ransom executable, which is
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`within the Microsoft Word document.
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`THE COURT: But that's not a fetched if it's already
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`in there when it comes into the system.
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`MR. HANNAH: No. So, Your Honor --
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`THE COURT: Your patent requires that you do two
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`steps. It's -- well, first you do the -- obtain the
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`downloadable, and then you go and fetch something to make it
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`work.
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`MR. HANNAH: Right. So when you're executing it --
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`and I can turn to the specification of the '780, which
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`specifically says that you prefetch the information that can
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`include something that's embodied within that, and that's --
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`they actually dropped this issue on their -- in their reply.
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`THE COURT: Well, wait. You mean you're saying that
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`the downloadable can include everything that's the malware and
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`you don't have to go fetch anything?
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`MR. HANNAH: Right. So it's fetching it from the --
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`THE COURT: But didn't you say something to the PTO --
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