Case 3:17-cv-05659-WHA Document 432-24 Filed 04/11/19 Page 1 of 5
`Case 3:17-cv-05659-WHA Document 432-24 Filed 04/11/19 Page 1of5
`
`
`
`
`
`
`EXHIBIT 23
`EXHIBIT 23
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`Case 3:17-cv-05659-WHA Document 432-24 Filed 04/11/19 Page 2 of 5
`679
` I N D E X O F P R O C E E D I N G S
`
`681
`
`F O R T H E P L A I N T I F F 'S :
`
`E R I C C O L E
`
`C R O S S - E X A M B Y M R . P O P L A W S K I ( R E S .) P . 7 1 2
`R E D I R E C T E X A M B Y M R . A N D R E P . 7 3 1
`
`D E P O S I T I O N V I D E O S :
`
`T Y L E R A N D E R S O N P . 7 4 2
`G A R Y T O M I C P . 7 4 2
`J O H N A H L A N D E R P . 7 4 2
`C H R I S L A R S E N P . 7 4 3
`
`M I C H A E L M I T Z E N M A C H E R
`
`D I R E C T E X A M B Y M R . A N D R E P . 7 4 4
`C R O S S - E X A M B Y M R . P O P L A W S K I P . 8 5 9
`R E D I R E C T E X A M B Y M R . A N D R E P . 8 9 5
`R E C R O S S E X A M B Y M R . P O P L A W S K I P . 9 0 0
`
`D E P O S I T I O N O F S T E V E N S C H O E N F E L D P . 9 0 1
`
`I V A N C H A P E R O T
`
`D I R E C T E X A M B Y M S . L E E P . 9 0 3
`C R O S S - E X A M B Y M R . P O P L A W S K I P . 9 0 9
`R E D I R E C T E X A M B Y M S . L E E P . 9 1 2
`
`UNITED STATES COURT REPORTERS
`
`I N D E X O F E X H I B I T S
`
`682
`
` ID E N T . E V I D E N C E
`P L A I N T I F F 'S :
`
`3 7 4 2
`8 4 7 7 6
`3 4 3 7 8 6
`8 5 7 9 3
`1 6 4 9 0 2
`1 6 6 9 0 2
`1 6 7 9 0 2
`
`J O I N T :
`
`2 0 4 1 7 5 9
`2 0 0 5 7 6 2
`2 0 1 8 7 7 2
`2 0 1 3 7 8 4
`2 0 4 1 7 8 5
`2 0 0 3 8 1 6
`2 0 0 2 8 4 2
`2 0 4 1 8 5 1
`2 0 1 5 8 5 2
`2 0 2 7 9 0 1
`
`UNITED STATES COURT REPORTERS
`08/05/2015 08:59:06 AM
`
`123
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`19
`20
`21
`22
`23
`24
`25
`
`1 2
`
`3
`
`4
`
`5
`
`6
`
`7 8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`FINJAN, INC, A DELAWARE
`CORPORATION,
` PLAINTIFF,
` VS.
`BLUE COAT SYSTEMS, INC., A
`DELAWARE CORPORATION,
` DEFENDANT.
`
`CASE NO. CV-13-03999-BLF
`SAN JOSE, CALIFORNIA
`JULY 24, 2015
`VOLUME 4
`PAGES 679 - 915
`
`FOR THE PLAINTIFF:
`
`TRANSCRIPT OF TRIAL
`BEFORE THE HONORABLE BETH LABSON FREEMAN
`UNITED STATES DISTRICT JUDGE AND A JURY
`A-P-P-E-A-R-A-N-C-E-S
`KRAMER, LEVIN, NAFTALIS & FRANKEL,
`LLP
`BY: PAUL J. ANDRE
` LISA KOBIALKA
` JAMES HANNAH
` KRISTOPHER KASTENS
` HANNAH LEE
`990 MARSH ROAD
`MENLO PARK, CALIFORNIA 94025
`
`
`FOR THE DEFENDANT:
`
`WILSON, SONSINI, GOODRICH & ROSATI
`BY: EDWARD POPLAWSKI
` OLIVIA KIM
` VERA ELSON
`633 WEST FIFTH STREET, 15TH FLOOR
`LOS ANGELES, CALIFORNIA 90071
` (APPEARANCES CONTINUED ON THE NEXT PAGE.)
`OFFICIAL COURT REPORTER:
`IRENE L. RODRIGUEZ, CSR, RMR, CRR
`CERTIFICATE NUMBER 8074
` PROCEEDINGS RECORDED BY MECHANICAL STENOGRAPHY,
`TRANSCRIPT PRODUCED WITH COMPUTER.
`
`UNITED STATES COURT REPORTERS
`
`680
`
`A P P E A R A N C E S : ( C O N T ')
`
`
`
`A L S O P R E S E N T :
`
` J I M H O Y
`
` G E O F F T H O M A S
`
` P H I L H A R T S T E I N
`
` J U L I E M A R - S P I N O L A
`
`UNITED STATES COURT REPORTERS
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`2
`3
`4
`5
`6
`
`7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1 of 140 sheets
`
`Page 679 to 682 of 915
`
`

`

`Q.
`
`A.
`
`CAN WE PLEASE SHOW THAT DEMONSTRATIVE.
`
`INCLUDES ONE OR MORE REFERENCES TO SOFTWARE COMPONENTS REQUIRED
`
`SO OVER HERE WE'RE TALKING ABOUT THE PROXYSG AND PROXYAV
`
`TO BE EXECUTED BY THE DOWNLOADABLE?
`
`AND REMEMBER THAT STANDS FOR ANTI-VIRUS.
`
`PROXYSG WAS A PRECURSOR, I GUESS, TO THE CAS PRODUCT, THE
`
`A.
`
`Q.
`
`IT'S MY UNDERSTANDING THAT THAT HAS BEEN STIPULATED.
`
`IS IT YOUR OPINION, NONETHELESS, THAT THE PROXYSG AND THE
`
`CONTENT ANALYSIS SYSTEM, THAT WE HEARD ABOUT EARLIER IN THE
`
`PROXYAV PRODUCTS MEETS THE LIMITATION OF CLAIM 9?
`
`CASE.
`
`A.
`
`YES. SO AS WE HAVE SEEN THE PROXYSG WILL DOWNLOAD A FILE,
`
`HERE THE USER WILL SEND A REQUEST TO PROXYSG AND AT SOME
`
`AND THAT FILE MAY CONTAIN ONE OR MORE SOFTWARE COMPONENTS THAT
`
`849
`
`Case 3:17-cv-05659-WHA Document 432-24 Filed 04/11/19 Page 3 of 5
`847
`06:18 1
`06:18 2
`06:18 3
`06:18 4
`06:18 5
`06:18 6
`06:18 7
`06:18 8
`06:18 9
`06:18 10
`06:18 11
`06:18 12
`06:18 13
`06:18 14
`06:18 15
`06:18 16
`06:18 17
`06:18 18
`06:19 19
`06:19 20
`06:19 21
`06:19 22
`06:19 23
`06:19 24
`06:19 25
`
`POINT IN THE PROCESS THE PROXYSG WILL GO ON THE INTERNET AND
`
`ARE TO BE EXECUTED.
`
`GET THE FILE.
`
`Q.
`
`AND IS THAT OPINION BASED ON YOUR REVIEW OF THE
`
`AND AH. HERE'S THE FILE ON THE INTERNET, THE NEWS PAGE.
`
`CONFIDENTIAL DOCUMENTS, PUBLIC DOCUMENTS, TESTIMONY, AND
`
` CONTINUE.
`
`TESTING OF THE PRODUCTS?
`
`AND ONE THING TO NOTICE IS THAT AS DR. COLE HAS TALKED
`
`ABOUT, YOU KNOW, PAGES OFTEN CONSIST OF MULTIPLE COMPONENTS.
`
`HE WAS TALKING IN THE CONTEXT OF SOFTWARE COMPONENTS OR OTHER
`
`COMPONENTS SUCH AS PICTURES OR SUCH, BUT A WEB PAGE CAN BE
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`YES, IT IS.
`
`CAN WE PUT A CHECK IN THAT BOX?
`
`YES.
`
`ALL RIGHT. LET'S TURN TO THE SECOND ELEMENT WHICH IS THE
`
`COMPOSED OF SEPARATE PIECES THAT CAN COME, IN FACT, FROM
`
`I.D. GENERATOR ELEMENT.
`
`DIFFERENT SOURCES. AND THAT'S WHAT WE'RE SHOWING HERE.
`
`PLEASE CONTINUE.
`
`A.
`
`Q.
`
`CERTAINLY.
`
`CAN YOU PLEASE -- LET ME START OFF FIRST, IS IT YOUR
`
`OKAY. SO EACH OF THOSE PIECES WILL GET DOWNLOADED FROM
`
`UNDERSTANDING THAT THE COURT HAS CONSTRUED PERFORMING A HASHING
`
`THE INTERNET OVER TO THE PROXYSG, AND THE PROXYSG MAY WANT TO
`
`FUNCTION ON THE DOWNLOADABLE AND THE SOFTWARE COMPONENTS AS
`
`SEND THEM TO THE PROXYAV OR THEY'LL BE SENT OVER AS WE'LL TALK
`
`PERFORMING A HASHING FUNCTION ON THE DOWNLOADABLE TOGETHER WITH
`
`ABOUT AS QUICKLY AS IS POSSIBLE. AND AS SOON AS THEY CAN BE
`
`THE FETCHED SOFTWARE COMPONENTS?
`
`PROCESSED, ONE OF THE FIRST STEPS IS THAT THESE PIECES WILL BE
`
`HASHED.
`
`SO THE LITTLE MEAT GRINDER IN THE VIDEO.
`
`A.
`
`Q.
`
`A.
`
`YES.
`
`AND DID YOU APPLY THAT CONSTRUCTION IN YOUR ANALYSIS?
`
`YES, I DID.
`
`06:15 1
`06:15 2
`06:15 3
`06:15 4
`06:15 5
`06:15 6
`06:15 7
`06:15 8
`06:15 9
`06:15 10
`06:16 11
`06:16 12
`06:16 13
`06:16 14
`06:16 15
`06:16 16
`06:16 17
`06:16 18
`06:16 19
`06:16 20
`06:16 21
`06:16 22
`06:16 23
`06:16 24
`06:16 25
`
`UNITED STATES COURT REPORTERS
`
`UNITED STATES COURT REPORTERS
`
`06:16 1
`06:17 2
`06:17 3
`06:17 4
`06:17 5
`06:17 6
`06:17 7
`06:17 8
`06:17 9
`06:17 10
`06:17 11
`06:17 12
`06:17 13
`06:17 14
`06:17 15
`06:17 16
`06:17 17
`06:17 18
`06:17 19
`06:17 20
`06:18 21
`06:18 22
`06:18 23
`06:18 24
`06:18 25
`
`848
`
`NOW, EACH OF THOSE PIECES IS HASHED, AS WE'VE TALKED
`
`ABOUT, USING THE MD5 FUNCTION, AND THEN WHAT WE'LL BE TALKING
`
`ABOUT IS THE I.D. IS THE COMBINATION OF THOSE HASHES TOGETHER.
`
`Q.
`
`SO LET'S TURN TO THE CLAIMS OF THE '780 PATENT. WHICH
`
`CLAIMS DID YOU FIND WERE INFRINGED BY THE PROXYSG AND PROXYAV
`
`PRODUCTS?
`A.
`
`9 AND 13.
`
`Q.
`
`AND IF YOU LOOK AT THE FIRST ONE A COMMUNICATIONS ENGINE
`
`FOR OBTAINING A DOWNLOADABLE THAT INCLUDES ONE OR MORE
`
`REFERENCES TO SOFTWARE COMPONENTS REQUIRED TO BE EXECUTED BY
`
`THE DOWNLOADABLE.
`
`DO YOU SEE THAT?
`
`YES, I DO.
`
`IS IT YOUR UNDERSTANDING THE COURT HAS CONSTRUED
`
`A.
`
`Q.
`
`DOWNLOADABLE AS APPLICATION PROGRAM WHICH IS DOWNLOADED FROM A
`
`SOURCE COMPUTER AND RUN ON A DESTINATION COMPUTER?
`
`A.
`
`YES, THAT'S THE COURT'S CONSTRUCTION AND THE DEFINITION I
`
`USED IN MY ANALYSIS.
`
`Q.
`
`AND IS IT YOUR OPINION THAT THE PROXYSG AND THE PROXYAV IS
`
`A SYSTEM FOR GENERATING A DOWNLOADABLE I.D. TO IDENTIFY A
`
`DOWNLOADABLE?
`A.
`
`YES.
`
`Q.
`
`IS IT ALSO YOUR UNDERSTANDING THAT BLUE COAT HAS
`
`STIPULATED THAT PROXYSG AND THE PROXYAV PRODUCTS CONTAIN A
`
`COMMUNICATIONS ENGINE FOR OBTAINING A DOWNLOADABLE THAT
`
`UNITED STATES COURT REPORTERS
`
`06:19 1
`06:19 2
`06:19 3
`06:19 4
`06:19 5
`06:19 6
`06:19 7
`06:19 8
`06:19 9
`06:19 10
`06:19 11
`06:19 12
`06:19 13
`06:19 14
`06:20 15
`06:20 16
`06:20 17
`06:20 18
`06:20 19
`06:20 20
`06:20 21
`06:20 22
`06:20 23
`06:20 24
`06:20 25
`
`43 of 140 sheets
`
`Page 847 to 850 of 915
`
`850
`
`Q.
`
`AND CAN YOU EXPLAIN WHAT IS REQUIRED BY THE SECOND ELEMENT
`
`OF CLAIM 9?
`A.
`
`SO THE IDEA IS WE WANT SOME I.D. ASSOCIATED WITH THE PAGE
`
`AND THE REASON WE WANT AN I.D. ASSOCIATED WITH THE PAGE IS THAT
`
`WHAT THE PROXYAV PRODUCT IS GOING TO DO IS THAT IT IS GOING TO
`
`BE EXAMINING THE WEB PAGE FOR THE POSSIBILITY OF CONTAINING A
`
`VIRUS, OTHER SORTS OF MALWARE.
`
`AND IF A WEB PAGE CHECKS OUT TO BE OKAY, WE DON'T WANT TO
`
`HAVE TO NECESSARILY DO ALL OF THE PROCESS AGAIN IN ORDER TO
`
`DETERMINE THAT IT'S SAFE.
`
`SO WHAT WE WOULD LIKE IS SOME SORT OF IDENTIFIER, I.D.,
`
`THAT CAN TELL US WE HAVE SEEN THIS INFORMATION BEFORE AND
`
`THINGS ARE GOING TO BE OKAY.
`
`SO WHAT IS REQUIRED HERE IN THIS CLAIM IS THAT WE'RE GOING
`
`TO HAVE AN I.D. GENERATOR, SO IN THIS CASE WE HAVE DISCUSSED
`
`THE I.D. GENERATOR WILL BE THE PROXYAV.
`
`IT'S GOING TO BE COUPLED WITH THE COMMUNICATIONS ENGINE,
`
`RIGHT, COUPLED WITH THE PROXYSG THAT FETCHES THE COMPONENTS,
`
`THE PARTS OF THE PAGE, AS WE SAW IN MY DEMONSTRATION.
`
`THEN AFTER DOWNLOADING, SAY, ONE OR MORE OF THE
`
`REFERENCES, WE WILL PERFORM THE HASHING FUNCTION ON THE
`
`DOWNLOADABLE AND THE FETCHED SOFTWARE COMPONENTS TO GENERATE A
`
`DOWNLOADABLE I.D. AND THAT WILL WORK IN THE MANNER THAT I
`
`DESCRIBED AND WE'LL DESCRIBE IN MORE DETAIL NOW REGARDING THE
`
`USE OF MD5 AND THE COMBINATION THEREOF AS THEIR I.D.
`
`UNITED STATES COURT REPORTERS
`08/05/2015 08:59:06 AM
`
`

`

`06:20 1
`06:21 2
`06:21 3
`06:21 4
`06:21 5
`06:21 6
`06:21 7
`06:21 8
`06:21 9
`06:21 10
`06:21 11
`06:21 12
`06:21 13
`06:21 14
`06:21 15
`06:21 16
`06:21 17
`06:21 18
`06:22 19
`06:22 20
`06:22 21
`06:22 22
`06:22 23
`06:22 24
`06:22 25
`
`Q.
`
`LET'S LOOK AT JTX 2041.
`
`A.
`
`SO WE'VE BEEN TALKING ABOUT HASHING AND FINGERPRINTS. AND
`
`I'D LIKE TO MOVE JTX 2041 TO THE EXTENT IT IS NOT ALREADY,
`
`AS WE CAN SEE HERE, PROXYAV WILL TAKE TYPES OF OBJECTS AND USE
`
`YOUR HONOR.
`
`THE HASH FUNCTION TO CREATE A FINGERPRINT, AND THE COMBINATION
`
`THE COURT: JTX 2041 WILL BE ADMITTED.
`
`OF THESE FINGERPRINTS FOR A SPECIFIC DOWNLOADABLE WILL
`
`853
`
`CORRESPOND TO THE I.D. THAT I'VE BEEN DISCUSSING.
`Q.
`
`AND, DOCTOR, HAVE YOU RELIED ON YOUR TESTIMONY TO SUPPORT
`
`YES.
`
`Case 3:17-cv-05659-WHA Document 432-24 Filed 04/11/19 Page 4 of 5
`851
`06:23 1
`06:23 2
`06:23 3
`06:23 4
`06:24 5
`06:24 6
`06:24 7
`06:24 8
`06:24 9
`06:24 10
`06:24 11
`06:24 12
`06:24 13
`06:24 14
`06:24 15
`06:24 16
`06:24 17
`06:24 18
`06:24 19
`06:24 20
`06:24 21
`06:24 22
`06:24 23
`06:24 24
`06:24 25
`
`(JOINT EXHIBIT 2041 WAS RECEIVED IN EVIDENCE.)
`
`MR. HANNAH: I BELIEVE IT HAS BUT JUST TO BE SAFE.
`
`THE COURT: OH, IT HAS.
`
`BY MR. HANNAH:
`Q.
`
`TURN TO PAGE 160 OF THIS DOCUMENT. AND IF YOU HIGHLIGHT
`
`YOUR OPINION THAT THE PROXYAV AND THE PROXYSG DO THIS HASHING?
`A.
`Q.
`
`WOULD YOU PLEASE SHOW AHLANDER DEPOSITION TESTIMONY 57:14
`
`THE TOP PARAGRAPH. COULD YOU EXPLAIN TO THE JURY HOW THIS
`
`THROUGH 58:9.
`
`SUPPORTS YOUR OPINION THAT THE SECOND ELEMENT OF THE '780
`
`I'D LIKE TO READ THIS INTO THE RECORD.
`
`PATENT IS MET, CLAIM 9 OF THE '780?
`A.
`
`SO ONE OF THE ASPECTS OF THE COURT'S CLAIM CONSTRUCTION
`
`"QUESTION: SO THE PROXYAV PRODUCT IS CONNECTED TO THE
`
`PROXYSG PRODUCT; CORRECT?
`
`WAS THAT THINGS WERE TO BE DONE TOGETHER AND PARTICULARLY
`
`"ANSWER: YES.
`
`TOGETHER IN TIME.
`
`"QUESTION: AT THE GATEWAY --
`
`AND WHAT WE'RE DISCUSSING IN HERE IS THAT THE OBJECT
`
`THE COURT: SLOW DOWN. I'M SORRY. WE JUST CAN'T
`
`PIPELINING ALGORITHM ALLOWS THE PROXYSG TO OPEN AS MANY
`
`GET THIS.
`
`SIMULTANEOUS TCP CONNECTIONS AS THE ORIGIN SERVER ALLOWS AND
`
`MR. HANNAH: SORRY, YOUR HONOR.
`
`RETRIEVES OBJECTS IN PARALLEL.
`
`Q.
`
`"QUESTION: AT THE GATEWAY. IT WILL RECEIVE AN INCOMING
`
`SO WHAT THIS IS SAYING IS THAT WE HAVE SEEN THE WEB PAGE
`
`FILE, AND THAT INCOMING FILE IS IMMEDIATELY -- A HASH IS
`
`CAN CONSIST OF MANY SMALL COMPONENTS.
`
`COMPUTED; CORRECT?
`
`IF YOU HAD TO WAIT AND YOU SAY, OKAY, I'M GOING TO GET THE
`
`"ANSWER: I BELIEVE SO.
`
`FIRST PART AND WAIT FOR THAT TO COME BACK; AND SAY I'M GOING TO
`
`"QUESTION: AFTER THAT HASH COMPUTED, THEN THE FILE IS
`
`GET THE SECOND PART AND WAIT FOR THAT TO COME BACK; AND GET THE
`
`SENT TO ONE OF THESE THIRD PARTY AV ENGINES; CORRECT?
`
`THIRD PART AND WAIT FOR THAT TO COME BACK, YOU'RE GOING TO BE
`
`"ANSWER: YES.
`
`UNITED STATES COURT REPORTERS
`
`UNITED STATES COURT REPORTERS
`
`854
`
`06:22 1
`06:22 2
`06:22 3
`06:22 4
`06:22 5
`06:22 6
`06:22 7
`06:22 8
`06:22 9
`06:22 10
`06:22 11
`06:22 12
`06:23 13
`06:23 14
`06:23 15
`06:23 16
`06:23 17
`06:23 18
`06:23 19
`06:23 20
`06:23 21
`06:23 22
`06:23 23
`06:23 24
`06:23 25
`
`852
`
`WAITING A LONG TIME FOR YOUR WEB PAGE. YOU MAY FIND THAT DOES
`
`HAPPEN TO YOU AT SOME POINT ALREADY WHEN YOU'RE USING THE WEB.
`
`SO THE PROXYSG IS SPECIFICALLY DESIGNED TO TRY AND PREVENT
`
`THAT, THAT IS, IT IS GOING TO TRY TO OBTAIN THE OBJECTS IN
`
`PARALLEL AS FAR AS IT CAN GET THEM AND IT WILL BE GETTING THEM
`
`ALL DOWN INTO THE SYSTEM AND THE GOAL BEING AT THE SAME TIME OR
`
`BECAUSE IT'S IN PARALLEL, IT WILL, IN FACT, BE DOWNLOADING THEM
`
`AT THE SAME TIME.
`Q.
`
`AND THOSE OBJECTS WILL THEN BE PASSED TO THE PROXYAV
`
`PRODUCT?
`A.
`Q.
`
`YES.
`
`IF WE LOOK AT JTX 2015.
`
`AND, YOUR HONOR, JTX 2015 I WOULD LIKE TO MOVE THAT INTO
`
`EVIDENCE.
`
`THE COURT: IT WILL BE ADMITTED.
`
`(JOINT EXHIBIT 2015 WAS RECEIVED IN EVIDENCE.)
`
`BY MR. HANNAH:
`Q.
`A.
`
`DOCTOR, WHAT IS JTX 2015?
`
`THIS IS A BLUE COAT DOCUMENT THAT IS DESCRIBING IN
`
`PARTICULAR THE PROXYAV APPLIANCE AND FURTHER HOW IT WORKS WITH
`
`THE PROXYSG.
`Q.
`
`AND TURN TO PAGE 11 OF THIS DOCUMENT. AND IF WE HIGHLIGHT
`
`IN THE SECOND PARAGRAPH. THANK YOU VERY MUCH.
`
`CAN YOU EXPLAIN TO THE JURY HOW THIS SUPPORTS YOUR OPINION
`
`THAT THE SECOND ELEMENT OF CLAIM 9 IS MET?
`
`06:24 1
`06:25 2
`06:25 3
`06:25 4
`06:25 5
`06:25 6
`06:25 7
`06:25 8
`06:25 9
`06:25 10
`06:25 11
`06:25 12
`06:25 13
`06:25 14
`06:25 15
`06:25 16
`06:25 17
`06:25 18
`06:25 19
`06:26 20
`06:26 21
`06:26 22
`06:26 23
`06:26 24
`06:26 25
`
`"QUESTION: ONCE THAT ANALYSIS IS COMPLETE, THEN A VERDICT
`
`IS REACHED?
`
`"ANSWER: YES.
`
`"AND ONCE THAT VERDICT IS REACHED, IT'S ASSOCIATED WITH A
`
`HASH THAT WAS GENERATED ON THAT INCOMING FILE --
`
`"ANSWER: YES.
`
`"QUESTION: -- AND THEN STORED WITHIN THE PROXYAV PRODUCT;
`
`CORRECT".
`
`"ANSWER: YES, TEMPORARILY."
`
`CAN YOU EXPLAIN HOW MR. AHLANDER'S TESTIMONY SUPPORTS YOUR
`
`OPINION?
`A.
`
`YEAH. SO, AGAIN, WHAT WE SEE HERE IS WHEN YOU HAVE
`
`DOWNLOADABLE CONSISTING OF MULTIPLE COMPONENTS OR CONCLUDING
`
`MULTIPLE COMPONENTS, THESE COMPONENTS WILL COME IN TO THE
`
`PROXYAV PRODUCT AND BE GIVEN A HASH CORRESPONDING FINGERPRINT,
`
`AND THE COMBINATION OF THESE FINGERPRINTS FORMING THE I.D. THAT
`
`I DISCUSSED.
`Q.
`
`LET'S TURN TO THE SOURCE CODE JTX 2076. AND IF WE CAN GO
`
`TO 330. 2330, PLEASE. THANK YOU VERY MUCH. THANK YOU, SIR.
`
`CAN YOU PLEASE EXPLAIN HOW THE SOURCE CODE SUPPORTS YOUR
`
`OPINION THAT THE SECOND ELEMENT OF CLAIM 9 IS MET?
`A.
`
`OKAY. SO, AGAIN, IT'S JUST DISCUSSING HERE THAT IT'S
`
`GOING TO BE USING AND STORING MD5 INFO. AS YOU GO THROUGHOUT
`
`THE CODE YOU SEE SEVERAL REFERENCES TO THE MD5 IN THE MANNER
`
`I'VE BEEN DISCUSSING.
`
`08/05/2015 08:59:06 AM
`
`Page 851 to 854 of 915
`
`44 of 140 sheets
`
`UNITED STATES COURT REPORTERS
`
`UNITED STATES COURT REPORTERS
`
`

`

`06:26 1
`06:27 2
`06:27 3
`06:27 4
`06:27 5
`06:27 6
`06:27 7
`06:27 8
`06:27 9
`06:27 10
`06:27 11
`06:27 12
`06:28 13
`06:28 14
`06:28 15
`06:28 16
`06:28 17
`06:28 18
`06:28 19
`06:28 20
`06:28 21
`06:28 22
`06:28 23
`06:28 24
`06:28 25
`
`AND IF WE GO TO PAGE 341 OF THE SOURCE CODE, IT'S 2341.
`
`A.
`
`THERE'S A CERTAIN I.D. FOR THE DOWNLOADABLE WHICH CONSISTS
`
`IS THIS ANOTHER SOURCE CODE FILE THAT EXPLAINS THAT THE
`
`OF THE COMBINATION, THE VARIOUS MD5 APPLICATIONS TO THE
`
`857
`
`Q.
`
`A.
`
`Case 3:17-cv-05659-WHA Document 432-24 Filed 04/11/19 Page 5 of 5
`855
`06:29 1
`06:29 2
`06:30 3
`06:30 4
`06:30 5
`06:30 6
`06:30 7
`06:30 8
`06:30 9
`06:30 10
`06:30 11
`06:30 12
`06:30 13
`06:30 14
`06:30 15
`06:30 16
`06:30 17
`06:30 18
`06:30 19
`06:30 20
`06:31 21
`06:31 22
`06:31 23
`06:31 24
`06:31 25
`
`ACCUSED PRODUCTS USE HASHING?
`
`INDIVIDUAL COMPONENTS.
`
`YES. SO WE SEE HERE THIS MD5IO YOU CAN SEE FROM THE
`
`THE USE OF THIS WOULD, FOR EXAMPLE, IF YOU DOWNLOADED THE
`
`COMMENT IT'S GOING TO PERFORM AN MD5 CHECKSUM OVER THE PROGNAME
`
`SAME WEB PAGE OVER AGAIN WITH THE SOFTWARE COMPONENTS, IF THERE
`
`AND REFERS TO SOME FILE OR OBJECT THAT IT WILL BE USING MD51.
`
`WAS ANY PROBLEM, YOU WOULD BE ABLE TO REJECT IT AND SAY, ALL
`
`Q.
`
`CAN YOU PUT UP THE CLAIMS. WHEN YOU WERE REVIEWING THE
`
`RIGHT, I KNOW THAT THIS IS HERE AND I DON'T NEED TO WORRY ABOUT
`
`DOCUMENTS AND THE TESTIMONY IN THIS CASE, WAS IT YOUR OPINION
`
`THIS AND I CAN JUST REJECT IT NOW.
`
`THAT IT WAS FUNCTIONING IN SUBSTANTIALLY THE SAME WAY WITH
`
`SO THE SAME RESULT OF BEING ABLE TO SAVE YOURSELF
`
`REGARD TO PERFORMING A --
`
`PROCESSING TIME, PROCESSING ENERGY, TAKING ADVANTAGE OF THE
`
`THE COURT: THIS LANGUAGE IS VERY DIFFICULT TO GET
`
`FACT OF WHETHER YOU HAVE SEEN SOMETHING BEFORE AND KNOW WHETHER
`
`ON THE RECORD.
`
`IT'S SAFE OR NOT LEADS TO AT THE VERY LEAST SUBSTANTIALLY THE
`
`MR. HANNAH: I'M SORRY, YOUR HONOR.
`
`THE COURT: WELL, IT'S YOUR RECORD.
`
`BY MR. HANNAH:
`
`Q.
`
`I'LL START OVER.
`
`SAME RESULT WITH REGARD TO THIS CLAIM.
`
`Q.
`
`AND FOR THE RECORD, IS IT YOUR OPINION AND DOES THE
`
`EVIDENCE DEMONSTRATE, THE EVIDENCE BEING YOUR TESTING OF THE
`
`ACCUSED PRODUCTS, THE DOCUMENTS, THE TESTIMONY THAT YOU
`
`WHEN YOU WERE DOING YOUR TESTING OF THE PROXYSG AND THE
`
`REVIEWED, THE SOURCE CODE, THAT THE PROXYSG AND THE PROXYAV
`
`PROXYAV AND YOUR REVIEW OF THE DOCUMENTS AND THE TESTIMONY IN
`
`CONTAIN AN I.D. GENERATED COUPLED TO THE COMMUNICATIONS ENGINE
`
`THIS CASE, IS IT YOUR OPINION THAT THE PROXYSG AND THE PROXYAV
`
`THAT FETCHES AT LEAST ONE SOFTWARE COMPONENT IDENTIFIED BY THE
`
`WAS FUNCTIONING THE SAME AS THIS CLAIM ELEMENT WITH REGARD TO
`
`ONE OR MORE REFERENCES AND FOR PERFORMING A HASHING FUNCTION ON
`
`PERFORMING A HASHING FUNCTION ON THE DOWNLOADABLE AND THE
`
`THE DOWNLOADABLE AND THE FETCHED SOFTWARE COMPONENTS TO
`
`FETCHED SOFTWARE COMPONENTS TO GENERATE A DOWNLOADABLE I.D.?
`
`GENERATE A DOWNLOADABLE I.D.?
`
`A.
`
`Q.
`
`A.
`
`YES.
`
`AND CAN YOU PLEASE EXPLAIN WHY?
`
`A.
`
`Q.
`
`YES.
`
`AND IT'S YOUR OPINION THAT THIS ELEMENT HAS BEEN MET
`
`CERTAINLY. SO WE'VE TALKED ABOUT MD5 AS BEING A HASHING
`
`LITERALLY?
`
`UNITED STATES COURT REPORTERS
`
`UNITED STATES COURT REPORTERS
`
`856
`
`858
`
`FUNCTION THAT IS APPLIED TO THE COMPONENTS, AND I'VE DISCUSSED
`
`A.
`
`Q.
`
`YES, IT IS.
`
`AND IS IT YOUR OPINION THAT THIS ELEMENT IS MET UNDER THE
`
`06:28 1
`06:28 2
`06:28 3
`06:28 4
`06:28 5
`06:28 6
`06:29 7
`06:29 8
`06:29 9
`06:29 10
`06:29 11
`06:29 12
`06:29 13
`06:29 14
`06:29 15
`06:29 16
`06:29 17
`06:29 18
`06:29 19
`06:29 20
`06:29 21
`06:29 22
`06:29 23
`06:29 24
`06:29 25
`
`HOW YOU CAN USE THE COMBINATION OF THOSE AS A HASHING FUNCTION
`
`ON A DOWNLOADABLE THAT INCLUDES THE ORIGINAL FILE THAT YOU SENT
`
`FOR ALONG WITH ALL OF THOSE COMPONENTS.
`
`SO ESSENTIALLY IT'S LIKE A BIT OF A JIGSAW PUZZLE, YOU
`
`CALCULATE THE INDIVIDUAL PIECES, PUT ALL OF THE PIECES
`
`TOGETHER, AND YOU GET THE I.D., AND THAT'S FUNCTIONING REALLY
`
`IN THE SAME -- DOING THE SAME FUNCTION AS WHAT IS DESCRIBED
`
`HERE IN ORDER TO CREATE AN I.D. FOR THE DOWNLOADABLE.
`
`Q.
`
`A.
`
`Q.
`
`AND IS IT ALSO SUBSTANTIALLY THE SAME FUNCTION?
`
`SO AT THE VERY LEAST SUBSTANTIALLY THE SAME FUNCTION, YES.
`
`AND IS IT YOUR OPINION THAT PROXYSG AND PROXYAV ARE DOING
`
`THE FUNCTIONS IN SUBSTANTIALLY THE SAME WAY AS THIS CLAIM
`
`ELEMENT?
`
`A.
`
`Q.
`
`A.
`
`ABSOLUTELY.
`
`AND CAN YOU PLEASE EXPLAIN WHY?
`
`CERTAINLY. I MEAN, AS YOU CAN SEE IT'S ALL BASED ON
`
`FORMING AN I.D. BASED ON HASHING, AND AS I DESCRIBED, THAT'S
`
`APPROXIMATELY WHAT THE MD5 DOES, IT PERFORMS THE HASHING IN
`
`SUBSTANTIALLY THE SAME WAY.
`
`Q.
`
`IN REVIEWING THE EXHIBITS, TESTIMONY, AND THE PRODUCTS,
`
`DID YOU FIND THAT THE PROXYSG AND THE PROXYAV YIELDED
`
`SUBSTANTIALLY THE SAME RESULT AS THIS ELEMENT?
`
`A.
`
`Q.
`
`YES, I DID.
`
`AND COULD YOU PLEASE EXPLAIN WHY?
`
`UNITED STATES COURT REPORTERS
`
`06:31 1
`06:31 2
`06:31 3
`06:31 4
`06:31 5
`06:31 6
`06:31 7
`06:31 8
`06:31 9
`06:31 10
`06:31 11
`06:31 12
`06:31 13
`06:31 14
`06:31 15
`06:31 16
`06:31 17
`06:32 18
`06:32 19
`06:32 20
`06:32 21
`06:32 22
`06:32 23
`06:32 24
`06:32 25
`
`45 of 140 sheets
`
`Page 855 to 858 of 915
`
`DOCTRINE OF EQUIVALENTS?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`YES, THAT IS RIGHT.
`
`IF WE CAN TURN TO -- CAN I PUT A CHECK IN THE BOX?
`
`YES.
`
`OKAY. THANKS.
`
`LET'S TURN TO THE NEXT CLAIM, THE FINAL CLAIM. THIS IS
`
`CLAIM 13. IS IT YOUR UNDERSTANDING THAT BLUE COAT HAS
`
`STIPULATED THAT CLAIM 13 IS FOUND IN THE PROXYSG AND THE
`
`PROXYAV PRODUCTS?
`
`A.
`
`SO IT'S MY UNDERSTANDING THAT THIS IS A DEPENDENT CLAIM,
`
`IT DEPENDS ON CLAIM 9, AND MY UNDERSTANDING IS THAT THEY
`
`STIPULATED TO THE OR WHEREIN THE DOWNLOADABLE INCLUDES HTML
`
`CODE, THAT IS CORRECT?
`
`Q.
`
`AND IS IT YOUR OPINION, REGARDLESS, THAT THE PROXYSG AND
`
`THE PROXYAV PRODUCTS ARE THE SYSTEM OF OR MEET THE LIMITATION
`
`OF CLAIM 9 WHEREIN THE DOWNLOADABLE INCLUDES HTML CODE?
`
`A.
`
`Q.
`
`YES, IT IS.
`
`AND IS THAT OPINION BASED ON YOUR REVIEW OF THE EVIDENCE,
`
`INCLUDING THE DOCUMENTS, THE TESTIMONY, SOURCE CODE, AND THE
`
`TESTING OF THE ACCUSED PRODUCTS?
`
`A.
`
`Q.
`
`YES, IT IS.
`
`LET'S DO A BRIEF RECAP OF THE '780 PATENT AND WHERE YOU
`
`FOUND THESE ELEMENTS.
`
`UNITED STATES COURT REPORTERS
`08/05/2015 08:59:06 AM
`
`