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`EXHIBIT 3
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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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`BLUE COAT SYSTEMS, INC.,
`Petitioner,
`v.
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`FINJAN, INC.,
`Patent Owner.
`____________________
`
`Case IPR2016-01443
`Patent 8,677,494
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`__________________________________________________________
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`DECLARATION OF NENAD MEDVIDOVIC, PH.D. ON THE
`VALIDITY OF CLAIMS 7–9 AND 16–18 OF U.S. PATENT NO. 8,677,494
`IN SUPPORT OF PATENT OWNER’S PRELIMINARY RESPONSE
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`Patent Owner Finjan, Inc. - Ex. 2007, p. 1
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`
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`Case 3:17-cv-05659-WHA Document 54-3 Filed 04/13/18 Page 2 of 2
`Declaration of Dr. Nenad Medvidovic
`IPR2016-01443 (U.S. Patent No. 8,677,494)
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`Behavior Patterns, Virus Bulletin Conference, September 1995 (Ex. 1005,
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`“Swimmer”); Ji et al. U.S. Patent No. 5,983,348 (Ex. 1006, “Ji”); Ari Luotonen et
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`al., World-Wide Web Proxies (1994) (Ex. 1007, “Luotonen”); Apperson et al. U.S.
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`Patent No. 5,978,484 (Ex. 1008, “Apperson”); and Lo et al., Towards a Testbed for
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`Malicious Code Detection (1991) (Ex. 1009, “Lo”). I have also reviewed the
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`declaration of inventor, Shlomo Touboul, located on pgs. 288–90 of Ex. 1004.
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`18.
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`I understand that I am submitting a declaration in connection with the
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`above-referenced Inter Partes review (“IPR”) proceeding involving the ‘494
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`Patent.
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`II.
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`SCOPE OF ASSIGNMENT AND APPROACH
`19.
`I have been retained as an expert on behalf of Patent Owner, Finjan,
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`Inc., (“Finjan”), to provide information and opinions to the Patent Trial and Appeal
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`Board (hereinafter “the Board”) to assist in the determination of the validity of
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`certain of Finjan’s patent claims of the ‘494 Patent for which the Board has
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`instituted an IPR proceeding. Specifically, counsel for Finjan asked me to provide
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`opinions regarding the validity of claims 7–9 and 16–18 of the ‘494 Patent in view
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`of certain prior art references cited by Petitioner, Blue Coat Systems, Inc. (“Blue
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`Coat”).
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`20.
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`I have been informed by counsel and I understand that the analysis of
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`whether a patent is anticipated or obvious is performed from the perspective of a
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`Patent Owner Finjan, Inc. - Ex. 2007, p. 8
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