`Case 4:18-cv-07229—YGR Document 44-6 Filed 02/28/20 Page 1 of 74
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`EXHIBIT E
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`EXHIBIT E
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`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 2 of 74
`Case 4:18-cv-07229—YGR Document 44-6 Filed 02/28/20 Page 2 of 74
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`APPENDIX B
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`APPENDIX B
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`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 3 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`The Qualys Accused Products perform computer security functionality when implemented
`on either the Qualys Cloud, Appliance Scanners, Virtual Scanners or client computing
`devices. Devices implementing each Accused Product, either alone or in combination, can
`be used by turning on their functionality without needing additional software to protect
`against malicious content downloaded through a network. Each Accused Product described
`herein includes a policy‐based cache manager.
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`1
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 4 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`2
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`1b. Contention 1 – Cache of digital content in Malware Detection
`
`Malware Detection includes memory for a cache for storing files that have been or will be scanned by
`the Malware Detection scanner. As shown below, these cached files are downloaded and stored
`during “antivirus” operations use (e.g. accessed via the claimed memory) and attached to a content
`profile that corresponds to the cached file. The memory can store the cache of digital content and
`policies during the performance of scanning operations.
`
`https://www.qualys.com/support/faq/mds/
`
`2
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 5 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`3
`
`1b. Contention 1 – Cache of digital content in Malware Detection (continued)
`
`Malware Detection’s use of memory that stores digital content, policies and a policy index is demonstrated by
`its use of policy compliance controls, as shown below.
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`https://www.qualys.com/videos/2013/qualysguard/malware‐detection/overview/
`
`3
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 6 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`4
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`1b. Contention 2 – Cache of digital content in Vulnerability Management
`
`Vulnerability Management includes memory for a cache for storing files that have been or will be scanned by
`the Web Application scanner. As shown below, these cached files can be stored for “remediation” and
`attached to a content profile that corresponds to the cached file. Vulnerability Management’s use of memory
`that stores digital content, policies and a policy index is demonstrated by its ability to retrieve cached files
`“without having to rescan.” The memory can store the cache of digital content and policies during the
`performance of scanning operations.
`
`https://www.qualys.com/docs/vulnerability‐management‐datasheet.pdf at 3.
`
`4
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 7 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`Claim 1
`
`5
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. Contention 3 – Cache of digital content using combined technologies of Web Application Scanning and
`Policy Compliance Technology
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`Web Application Scanning includes memory for a cache for storing files that have been or will be scanned by
`the Web Application scanner. As shown below, these cached files can be stored for “remediation” and
`attached to a content profile that corresponds to the cached file. The memory can store the cache of digital
`content and policies during the performance of scanning operations.
`
`https://www.qualys.com/docs/web‐application‐scanning‐datasheet.pdf at 2.
`
`5
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 8 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`Claim 1
`
`6
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. Contention 3 – Cache of digital content using combined technologies of Web Application Scanning and
`Policy Compliance Technology (continued)
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`Web Application Scanning, in combination with Policy Compliance, includes memory for storing policies and a
`policy index for the cached contents, including the cached files described above.
`
`https://www.qualys.com/apps/policy‐compliance/
`
`6
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 9 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`Claim 1
`
`7
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. Contention 3 – Cache of digital content using combined technologies of Web Application Scanning and
`Policy Compliance Technology (continued)
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`Web Application Scanning, in combination with technology provided by Policy Compliance, includes memory
`for storing policies and a policy index for the cached contents, including the cached files described above.
`
`https://www.qualys.com/docs/qualys‐policy‐compliance‐guide.pdf at 19.
`
`https://www.qualys.com/docs/qualys‐policy‐compliance‐guide.pdf at 29.
`
`7
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 10 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`8
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`1b. Contention 4 – Cache of digital content using Web Application Firewall
`
`Web Application Firewall includes memory for a cache for storing files that have been or will be
`scanned by the Web Application scanner. As shown below, these cached files are stored as scan data
`that corresponds to the cached file. As shown below, Web Application Firewall store policies and a
`policy index for the cached contents, including the cached file (i.e., scan data) described above. The
`memory can store the cache of digital content and policies during the performance of scanning
`operations.
`
`https://www.qualys.com/apps/web‐app‐firewall/
`
`8
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 11 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`9
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`1b. Contention 5 – Cache of digital content in ThreatPROTECT
`
`ThreatPROTECT includes memory for a cache for storing files that have been or will be scanned by the Web
`Application scanner. As shown below, these cached files that are “actively attacked in the wild” can be stored
`for “remediation” (e.g. through use of an “exploit kit) and attached to a content profile that corresponds to the
`cached file. The memory can store the cache of digital content and policies during the performance of scanning
`operations.
`
`https://www.qualys.com/apps/threat‐protection/
`
`9
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 12 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`10
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`1b. Contention 6 – Cache of digital content in Continuous Monitoring
`
`Continuous Monitoring includes memory for a cache for storing files that have been or will be scanned by the
`Continuous Monitoring scanner. As shown below, these cached files can be stored for “remediation” (e.g.
`through use of an “remediation tickets”) and attached to a content profile that corresponds to the cached file.
`Continuous Monitoring’s use of memory that stores digital content, policies and a policy index is demonstrated
`by its use of a “policy engine.” The memory can store the cache of digital content and policies during the
`performance of scanning operations.
`
`https://www.qualys.com/apps/continuous‐monitoring/#/index/4
`
`10
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 13 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`11
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`1b. Contention 7 – Cache of digital content in Indication of Compromise
`
`Indication of Compromise includes memory for a cache (corresponding to the “quarantine folder”
`below) for storing files that have been or will be scanned by the Indication of Compromise scanner.
`As shown below, these cached files can be stored for “offline” use (e.g. accessed via the claimed
`memory) and attached to a content profile that corresponds to the cached file. The memory can
`store the cache of digital content and policies during the performance of scanning operations.
`
`https://www.qualys.com/apps/indication‐of‐compromise/#/index/7
`
`11
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 14 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`12
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`1b. Contention 7 – Cache of digital content in Indication of Compromise (continued)
`
`Indication of Compromise’s use of memory that stores digital content, policies and a policy index is
`demonstrated by its use of “policy compliance controls.” The memory can store the cache of digital
`content and policies during the performance of scanning operations.
`
`https://www.qualys.com/apps/indication‐of‐compromise/#/index/7
`
`12
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 15 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`13
`
`1b. Contention 8 – Cache of digital content in Secure Seal
`
`Secure Seal includes memory for a cache for storing files that have been or will be scanned by the
`Secure Seal scanner. As shown below, these cached files are downloaded and stored during
`“malware detection” operations use (e.g. accessed via the claimed memory) and attached to a
`content profile that corresponds to the cached file. The memory can store the cache of digital
`content and policies during the performance of scanning operations.
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`13
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 16 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`14
`
`1b. Contention 8 – Cache of digital content in Secure Seal (continued)
`
`Secure Seal’s use of memory that stores digital content, policies and a policy index is demonstrated by its use
`of policy compliance controls during malware detection procedures, as shown below.
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`https://www.qualys.com/videos/2013/qualysguard/malware‐detection/overview/
`
`14
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 17 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`15
`
`1b. Contention 9 – Cache of digital content in Cloud Agent Technology
`
`Cloud Agent Technology includes memory for a cache for storing files that have been or will be scanned by the
`Cloud Agent scanner. As shown below, these cached files can be stored and attached to a content profile that
`corresponds to the cached file during the performance of static, dynamic, behavior analysis. The memory can
`store the cache of digital content and policies during the performance of scanning operations.
`
`https://www.qualys.com/docs/qualys‐cloud‐agent‐getting‐started‐guide.pdf at 17.
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`15
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 18 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`16
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`1b. Contention 10 – Cache of digital content using the technologies of Cloud Agents, Vulnerability
`Management, Web Application Firewall, ThreatPROTECT, Continuous Monitoring, Indication of
`Compromise, Secure Seal, or Malware Detection combined with Policy Compliance Technology
`
`Cloud Agents, Vulnerability Management, Web Application Firewall, ThreatPROTECT, Continuous
`Monitoring, Indication of Compromise, Secure Seal, or Malware Detection, in combination with
`Policy Compliance technology, include memory for a cache for storing files that have been or will be
`scanned by the respective scanner of each of the Accused Products.
`
`https://www.qualys.com/apps/policy‐compliance/. See also: https://www.qualys.com/apps/policy‐
`compliance/ (e.g., “Create custom policies…”); https://www.qualys.com/docs/qualys‐policy‐compliance‐
`guide.pdf at 19 (e.g., “specify the scan parameters…to be performed by the scanning engine…”); see also
`https://www.qualys.com/docs/qualys‐policy‐compliance‐guide.pdf at 29.
`
`16
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 19 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`17
`
`1b. Contention 10 – Cache of digital content using the technologies of Cloud Agents, Vulnerability
`Management, Web Application Firewall, ThreatPROTECT, Continuous Monitoring, Indication of Compromise,
`Secure Seal, or Malware Detection combined with Policy Compliance Technology (continued)
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`17
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 20 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`Doctrine of Equivalents
`
`18
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`To the extent that the Qualys Accused Products do not literally infringe this claim element, Qualys
`infringes under the doctrine of equivalents. The above described functionality of the Qualys Accused
`Products is at most insubstantially different from the claimed functionality and performs substantially
`the same function in substantially the same way to achieve substantially the same result.
`
`The Accused Products perform the same function because they store data to subject digital content to
`a set of tests including static, dynamic, behavioral analyses on the content and where the policy index
`is associated with a “verdict table” that indicates policy or rule match or fail for detecting the malware
`and have a “verdict table” correlates the policy result to a specific digital content (e.g., identified by
`hash value). The Accused Products store data about files an policies to reduce the need to rescan.
`
`The Accused Products perform the same way because they use computer memory to subject digital
`content to a set of tests including static, dynamic, behavioral analyses on the content and where the
`policy index is associated with a “verdict table” that indicates policy or rule match or fail for detecting
`the malware and have a “verdict table” correlates the policy result to a specific digital content (e.g.,
`identified by hash value). The Accused Products store data about files an policies to reduce the need
`to rescan.
`
`The Accused Products achieve the same result as this element of entries in a database that contain the
`“verdicts” for digital content for a specific set of policies that can be used to reduce the need to rescan
`known files.
`
`18
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 21 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`19
`
`Claim 1
`
`1a. A policy‐based cache manager,
`comprising:
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`1c. Contention 1 – Tbe Accused Products scan digital content to derive content profiles at Qualys Cloud
`
`Web Application Scanning, Web Application Firewall, Vulnerability Management, ThreatPROTECT, Continuous
`Monitoring, Indication of Compromise, Malware Detection, Secure Seal, and Cloud Agent Technology,
`executed on a computer that is part of the Qualys Cloud computing environment, each scan digital content to
`derive a corresponding content profile because, as shown below, each generates reports that identify
`“vulnerabilities” (computer exploits) based on malicious content downloaded from a source computer such as
`Content Profile
`the Internet.
`
`Digital
`Content
`
`Qualys FreeScan - Free Vulnerability Scanner _ Qualys, Inc_.pdf
`
`19
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 22 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`Claim 1
`
`20
`
`1a. A policy‐based cache manager,
`comprising:
`
`1c. Contention 1 – The Accused Products scan digital content to derive content profiles at Qualys Cloud
`(continued)
`
`Each Accused Product above communicates with the memory described above in 1(b) and derives content
`profiles using emulation and virtual machines to perform static, dynamic, and behavior analysis, as depicted
`below.
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by indicating
`cache content that is known to be
`allowable relative to a given policy, for
`each of a plurality of policies;
`
`1c. a content scanner, communicatively
`coupled with said memory, for scanning
`a digital content received, to derive a
`corresponding content profile; and
`
`1d. a content evaluator,
`communicatively coupled with said
`memory, for determining whether a
`given digital content is allowable relative
`to a given policy, based on the content
`profile, the results of which are saved as
`entries in the policy index.
`
`Dissectpeproject‐gabriel‐110816130546‐phpapp01.pdf
`
`20
`
`© 2018 Finjan, Inc. ALL RIGHTS RESERVED
`Subject to FRE 408
`
`
`
`Case 4:18-cv-07229-YGR Document 44-6 Filed 02/28/20 Page 23 of 74
`
`US Patent No. 6,965,968
`Policy-Based Caching
`
`Claim 1
`
`21
`
`1a. A policy‐based cache manager,
`comprising:
`
`1c. Contention 1 – The Accused Products scan digital content to derive content profiles at Qualys
`Cloud (continued)
`
`Each Accused Product above communicates with the memory described above in 1(b) and derives
`content profiles using emulation and virtual machines to perform static, dynamic, and behavior
`analysis, as depicted below.
`
`1b. a memory storing a cache of digital
`content, a plurality of policies, and a
`policy index to the cache contents, the
`policy index including entries that relate
`cache content and policies by