`Case 5:17-cv-04467-BLF Document 299-23 Filed 10/14/20 Page 1 of 3
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`EXHIBIT R
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`EXHIBIT R
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`Case 5:17-cv-04467-BLF Document 299-23 Filed 10/14/20 Page 2 of 3
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`From: Dotson, David C.
`Sent: Monday, July 13, 2020 10:08 AM
`To: Hannah, James ; McGrath, Robin ; Gunther, Jarrad M.
`Cc: Lee, Hannah
`Subject: RE: Revised Appendices H‐2 Through H‐4
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`James,
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`Also, on our call, we discussed the potential confusion surrounding SonicWall’s April 2 email stating its understanding
`that Finjan would withdraw Appendix H‐3, and we agreed to revisit our respective notes on that issue. Based on our
`notes, it appears to us that the reference to Finjan withdrawing Appendix H‐3 was correct because Appendix H‐3
`identifies the Stats server as the alleged “security computer,” which is in contravention of the Court’s November 20
`Order. See Revised Appx. H‐3 at 7, 9. The Court stated in its November 20 Order with respect to the ‘154 Patent that
`“Finjan’s reliance on the Stats server and the URL Thumbprint Database constitutes new theories of infringement not
`previously disclosed and not within the scope of the Court’s May 2019 order.” November 20, 2019 Order at 9.
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`So that we are all on the same page, please confirm that Finjan has withdrawn Appx. H‐1, H‐3, and H‐5.
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`Please also confirm that Finjan will revise Appendices H‐6 and H‐7 to address the “transmitting . . . when” limitation.
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`Thanks,
`David
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`From: Hannah, James <JHannah@KRAMERLEVIN.com>
`Sent: Thursday, July 2, 2020 6:29 PM
`To: McGrath, Robin <RLMcGrath@duanemorris.com>; Dotson, David C. <DCDotson@duanemorris.com>
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`Case 5:17-cv-04467-BLF Document 299-23 Filed 10/14/20 Page 3 of 3
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`Cc: Lee, Hannah <HLee@KRAMERLEVIN.com>
`Subject: Revised Appendices H‐2 Through H‐4
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`Robin, David, please see the attached revised appendices based on our discussion this afternoon. The changes can be
`found on Pg. 14 of H‐2; Pg. 11 of H‐3; and Pg. 14 of H‐4. Thanks.
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`James
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`James Hannah
`Partner
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`Kramer Levin Naftalis & Frankel LLP
`990 Marsh Road, Menlo Park, California 94025
`T 650.752.1712 F 650.752.1812
`jhannah@kramerlevin.com
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`Bio
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`This communication (including any attachments) is intended solely for the recipient(s) named above and may contain information that is
`confidential, privileged or legally protected. Any unauthorized use or dissemination of this communication is strictly prohibited. If you have received
`this communication in error, please immediately notify the sender by return e-mail message and delete all copies of the original communication.
`Thank you for your cooperation.
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