Case 3:17-cv-05659-WHA Document 96-8 Filed 06/07/18 Page 1 of 10
`Case 3:17-cv-05659-WHA Document 96-8 Filed 06/07/18 Page 1 of 10
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`EXHIBIT 4
`EXHIBIT 4
`
`

`

`Case 3:17-cv-05659-WHA Document 96-8 Filed 06/07/18 Page 2 of 10
`
`Juniper’s Sky Advanced Threat Prevention
`6,804,780
`The statements and documents cited below are based on information available to Finjan, Inc. at the time this chart
`was created. Finjan reserves its right to supplement this chart as additional information becomes known to it.
`
`For purposes of this chart, “Sky ATP” is the cloud service and all support infrastructure maintained by Juniper, and
`includes the services and components in Exhibit A, as will be described in greater detail herein. Based on public
`information, Sky ATP operates identically with respect to the identified claims and only vary based on software
`specifications and/or deployment options.
`
`As identified and described element by element below, the one or more of the Sky ATP specifically listed above
`infringe at least claims 1and 9 of the ’780 Patent.
`
`Claim 1
`1a. A computer-based method
`for generating a
`Downloadable ID to identify
`a Downloadable, comprising:
`
`
`
`Sky ATP meet the recited claim language because it provides a computer-based
`method for generating a Downloadable ID to identify a Downloadable.
`
`As used herein, and throughout these contentions, Downloadable is “an executable
`application program, which is downloaded from a source computer and run on the
`destination computer.”
`
`Sky ATP meet the recited claim language because Sky ATP generates a
`Downloadable ID by creating malware attack profiles which include a hash to
`identify a Downloadable, such as malware. The analysis includes scanning the
`Downloadables which include references to software components required to be
`executed by the Downloadable (e.g., suspicious web page content containing
`HTML, PDFs, JavaScript, drive-by downloads, obfuscated code, or other blended
`web malware).
`
`Sky ATP obtains a Downloadable then generates a profile that includes generating
`a Downloadable ID (e.g., a SHA-256 or a MD5 hash) to identify a Downloadable
`and whether it is malicious and to create a risk score or verdict.
`
`
`
`1
`
`

`

`Case 3:17-cv-05659-WHA Document 96-8 Filed 06/07/18 Page 3 of 10
`
`1b. obtaining a Downloadable
`that includes one or more
`references to software
`components required to be
`executed by the
`Downloadable;
`
`
`
`https://www.juniper.net/documentation/en_US/release-independent/sky-
`atp/information-products/topic-collections/sky-atp-open-apis.html (showing a
`SHA-256 generated for the downloadable to indentify the downloadable).
`
`Sky ATP meets the recited claim language because it obtains a Downloadable that
`includes one or more references to software components required to be executed
`by the Downloadable.
`
`Sky ATP meets the recited claim language because Sky ATP obtains suspicious
`traffic flows for analysis through a application program interface, and the content
`in these traffic flows include Downloadables such as web page and/or email
`attachments. These Downloadables include references to software components
`required to be executed by the Downloadable (e.g. suspicious web page content
`containing HTML, PDFs, JavaScript, drive-by downloads, obfuscated code, or
`other blended web malware).
`
`Downloadables that includes one or more references to software components
`required to be executed by the Downloadable include a web page that includes
`references to JavaScript, visual basic script, ActiveX, injected iframes; and a PDF
`that includes references to JavaScript, swf files or other executables. Typically,
`Juniper characterizes them as drive-by-downloads or droppers as such
`Downloadables are usually programmed to take advantage of a browser,
`application, or OS that is out of date and has a security flaw. The initial
`downloaded code is often small enough that it wouldn’t be noticed, since its job is
`often simply to contact another computer where it can pull down the rest of the
`code on to the computer. In particular, such software components are usually
`programmed to be downloaded and run in the background in a manner that is
`invisible to the user and without the user taking any conscious actions as just the
`act of viewing a web-page that harbors this malicious code is typically enough for
`the download and execution to occur.
`
`
`
`2
`
`

`

`Case 3:17-cv-05659-WHA Document 96-8 Filed 06/07/18 Page 4 of 10
`
`Sky ATP obtains and scans Downloadables that may include malware embedded
`in images, JavaScript, text and Flash files. As shown below, Sky ATP obtains
`and conducts analysis on Downloadables such as Executable files (e.g., “.bin,
`.com, .dat, .exe, .msi, .msm, .mst”), PDF files, Java (e.g., “.class, .ear, .jar, .war”),
`MS Office file types, Flash and Silverlight applications, Script files, and installer
`files through an application program interface.
`
`
`
`
`
`
`https://www.juniper.net/documentation/en_US/release-independent/sky-
`atp/topics/reference/general/sky-atp-profile-overview.html.
`
`
`
`As shown below, Sky ATP performs behavioral analysis such as potential dropper
`infection for Downloadables. Potential dropper infections “Drop PE” (e.g.,
`references to software components required to be executed by the Downloadable).
`
`3
`
`

`

`Case 3:17-cv-05659-WHA Document 96-8 Filed 06/07/18 Page 5 of 10
`
`
`As shown below, Sky ATP a cache lookup of a file and its components using a
`hash value to prevent rescanning of known files and their components.
`
`
`1c. fetching at least one
`software component
`identified by the one or more
`references; and
`
`
`
`https://www.juniper.net/documentation/en_US/release-independent/sky-
`atp/topics/concept/sky-atp-malware-analyze.html
`
`Sky ATP meet the recited claim language because it fetches at least one software
`component identified by the one or more references.
`
`Sky ATP meet the recited claim language because Sky ATP perform analysis on
`malware containing multiple software components and capture traffic containing
`malware for analysis, including suspicious web page content containing HTML,
`scripts, applets, ActiveX and drive-by downloads. As part of this analysis, Sky
`ATP includes components which fetch the software components identified in
`references in the Downloadable such as potential dropper infections, dropped
`files, multiple infected files, and object streams within PDF’s.
`
`
`
`4
`
`

`

`Case 3:17-cv-05659-WHA Document 96-8 Filed 06/07/18 Page 6 of 10
`
`As shown below, Sky ATP analyzes a Downloadable and fetches the software
`components identified by the one or more references (e.g., “Drop PE”) within to
`determine whether it is suspicious or not. Sky ATP also performs dynamic
`analysis on the Downloadable and allows it to download additional referenced
`components.
`
`
`
`Sky ATP includes components which fetch software components identified by the
`one or more references (e.g., dropped files). Dropped files are captured by Sky
`ATP during sandboxing analysis as well as identified during static analysis. As
`shown below, static analysis will break down code and look for suspicious code
`and/or operations that include dropping files. Sky ATP includes components
`which fetch software components identified by the one or more references. SHA-
`256 hashes are generated together for the parent (dropper) and target (dropped)
`files.
`
`
`
`
`To the extent Juniper argues that Sky ATP do not literally satisfy this element,
`Juniper meets this element under the doctrine of equivalents.
`
`
`
`
`5
`
`

`

`Case 3:17-cv-05659-WHA Document 96-8 Filed 06/07/18 Page 7 of 10
`
`As described below, Sky ATP will detonate downloadable files using dynamic
`analysis, which requires fetching referenced components.
`
` Juniper Sky Advanced Threat Prevention .pdf at page 2.
`
`Sky ATP perform the same function as this claim element because they receive
`downloaded content, such as HTML or JavaScript, that have referenced
`components that are also downloaded by Sky ATP, and create an identity for
`downloaded content. This is the same function as this element because this an
`identification of a downloaded content, including referenced components that are
`downloaded. Sky ATP perform this function in the same way as this claim
`element because they download components that are used to create an identity for
`downloaded content such as HTML or JavaScript. Sky ATP perform this element
`the same way because the identity created can be used to identify downloaded
`content that reference multiple components that are used by the downloaded
`content. Sky ATP achieve the same result as this claim element because they
`have components that result in the creation of an identification in downloaded
`content, such as HTML or JavaScript, and downloads multiple components
`referenced. This is the same result as this claim element because Sky ATP use
`this identity to identify the downloaded content and its referenced components for
`security decisions.
`
`
`Sky ATP meet the recited claim language because they perform a hashing
`function on the Downloadable and the fetched software components to generate a
`Downloadable ID.
`
`
`6
`
`1d. performing a hashing
`function on the Downloadable
`and the fetched software
`components to generate a
`Downloadable ID.
`
`

`

`Case 3:17-cv-05659-WHA Document 96-8 Filed 06/07/18 Page 8 of 10
`
`Sky ATP meet the recited claim language because Sky ATP include components
`which create a dynamically generated signature and/or a malware attack profile
`for the Downloadable by performing a hashing function using SHA256, MD5,
`and/or SHA-1 on Downloadables (e.g., HTML, JavaScript, and/or email) together
`with other web-based files/executables fetched (e.g., potential dropper infections,
`multiple infected files, and object streams within PDF’s).
`
`Sky ATP obtains a Downloadable then generates a profile that includes
`generating a Downloadable ID (e.g., the SHA-256 hash) to identify a
`Downloadable. As shown below, the profile is then stored in Juniper’s cloud for
`further identification of Downloadables, including whether it is malicious and to
`create a risk score.
`
`
`
`
`7
`
`

`

`Case 3:17-cv-05659-WHA Document 96-8 Filed 06/07/18 Page 9 of 10
`
`See https://www.juniper.net/documentation/en_US/release-independent/sky-
`atp/information-products/topic-collections/sky-atp-open-apis.html
`
`Sky ATP obtains a Downloadable then generates a Downloadable ID (e.g., the
`SHA-256, SHA-1, and/or MD5 hashes) to identify a Downloadable (e.g., the exe
`file) together with the fetched software components using hashes for both the file
`and the “parent” file.
`
`
`
`
`
`8
`
`
`
`

`

`Case 3:17-cv-05659-WHA Document 96-8 Filed 06/07/18 Page 10 of 10
`
`See https://www.juniper.net/documentation/en_US/release-independent/sky-
`atp/topics/reference/general/sky-atp-filescan-overview.html (showing a SHA256
`and MD5 hash of a downloadable).
`
`See
`https://www.juniper.net/documentation/en_US/junos/topics/reference/command-
`summary/security-file-checksum-sha1.html (showing a SHA-1 hash of a
`downloadable).
`
`
`
`
`9
`
`