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`Exhibit 2
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`Case 3:18-cv-02621-WHO Document 266-3 Filed 04/03/20 Page 2 of 2
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Counsel:
`
`Joseph Gratz <JGratz@durietangri.com>
`Friday, March 15, 2019 8:12 AM
`Andre, Paul; Kobialka, Lisa; Hannah, James; Kastens, Kris; Manes, Austin
`Sonal Mehta; Andrew Perito; Josh Furman
`[EXTERNAL] Finjan v. Zscaler, Case No. 3:17-cv-06946-JST
`
`We have received your Second Amended Infringement Contentions.
`
`In its most recent Order regarding contentions , the Court held that Finjan’s identification of “a multiplicity of possible . .
`. internet applications . . . that could potentially meet the claim elements[] is not sufficiently specific to put Zscaler on
`notice of Finjan’s infringement contentions.” ECF No. 110 at 8.
`
`In its Second Amended Infringement Contentions, with respect to the “internet application” of the claims, Finjan states
`that:
`
`The Internet application is the SME proxy software application that processes the content to send the content to
`the user. The Internet application is also a web browser, email client, or FTP client application running on the
`client device.
`
`Appendix C‐1 at 2. Finjan’s other contentions with respect to the ’305 Patent contain similar language with respect to a
`piece of Zscaler software and a broad category of potential accused third‐party software.
`
`The Court ordered Finjan to do more than “identify only broad categories of potential accused components,” ECF No.
`110 at 9, and thus we understand Finjan not to be identifying any web browser, email client, or FTP client application as
`being the “internet application” of the claims, but instead understand Finjan to be identifying the combination of the
`identified Zscaler software and any web browser, email client, or FTP client application as being the “internet
`application” of the claims. Based on that understanding, Zscaler is not filing a further motion to enforce the Court’s
`order regarding this issue. However, if that understanding is incorrect, please let us know so that we can raise the issue
`with the Court.
`
`Joseph Gratz | Durie Tangri LLP | jgratz@durietangri.com | 415‐362‐6666 | vCard
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`1
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