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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`___________________
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`JUNIPER NETWORKS, INC.,
`Petitioner,
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`v.
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`FINJAN, INC.,
`Patent Owner.
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`____________________
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`Case IPR2019-00031
`Patent 8,141,154
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`__________________________________________________________
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`PATENT OWNER’S PRELIMINARY RESPONSE
`UNDER 37 C.F.R. § 42.107
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`Case 3:17-cv-05659-WHA Document 390-21 Filed 03/14/19 Page 2 of 2
`Patent Owner’s Preliminary Response
`IPR2019-00031 (U.S. Patent No. 8,141,154)
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`identify any capability in either Ji or Gladstone to “inspect” a function input, let
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`alone a security computer that inspects a transmitted input. Although Ji discloses
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`that “parameters to the suspicious function” are passed to the pre-filter, Ji is silent
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`with respect to inspecting those parameters. See Ji at 5:57–62. Additionally,
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`Gladstone’s Event Processing Server only processes event messages, which as
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`discussed above, are not function inputs. Accordingly, Petitioner’s proposed
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`combination of Ji and Gladstone does not result in “transmitting the input to the
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`security computer for inspection, when the first function is invoked.” ‘154
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`Patent, claim 1 (emphasis added).
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`Second, this argument requires modification to Ji and Gladstone such that
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`function inputs are transmitted as a result of the invocation of a first function
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`whose call includes the input. As acknowledged by Petitioner, Ji’s pre-filter is
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`executed locally, and no input is transmitted anywhere. See Petition at 18
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`(showing that the “safety check” occurs on the client machine). Gladstone does
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`not cure this deficiency because it only transmits event messages as a result of
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`encountering an operating system event, not as a result of invoking a first function.
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`In other words, Petitioner’s proposed combination of Ji and Gladstone does not
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`result in “transmitting the input to the security computer for inspection, when the
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`first function is invoked.” ‘154 Patent, claim 1 (emphasis added).
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