Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8918 Page 1 of 122
`
`PAUL J. ANDRE (State Bar No. 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (State Bar No. 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (State Bar No. 237978)
`jhannah@kramerlevin.com
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF CALIFORNIA
`SAN DIEGO DIVISION
`FINJAN, INC., a Delaware Corporation,
`Case No.: 3:17-cv-00183-CAB-BGS
`
`PLAINTIFF FINJAN, INC.’S
`SUPPLEMENTAL INFORMATION
`IN SUPPORT OF CLAIM
`CONSTRUCTION REGARDING THE
`TERM “ENGINE”
`
`Plaintiff,
`
`v.
`
`ESET, LLC, a California Limited
`Liability Corporation, and ESET SPOL.
`S.R.O., a Slovak Republic Corporation,
`
`Defendants.
`ESET, LLC, a California Limited
`Liability Corporation, and ESET SPOL.
`S.R.O., a Slovak Republic Corporation,
`
`Counterclaim-Plaintiffs,
`
`v.
`
`FINJAN, INC., a Delaware Corporation,
`
`Counterclaim-Defendant.
`
`FINJAN’S SUPP. INFORMATION
`RE: “ENGINE”
`
`CASE NO. 17-cv-00183-CAB-BGS
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8919 Page 2 of 122
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`Finjan, Inc. (“Finjan”) was not able to locate any case law where the claim term
`“engine” preceded by a descriptive modifier was determined to be a nonce term,1 and no
`decisions where “engine” was construed as a means-plus-function limitation when used
`in the claims. Instead, Finjan was able to locate hundreds of publications where those
`skilled in the art describe a variety of “engine” types demonstrating that “engine,” when
`used with a particular descriptive modifier (e.g., “antivirus engine,” “scanning engine,”
`“communication engine,” etc.) , is a term that is well understood by those of skill in the
`art and often used in software programming to describe the structure of a computer
`program.2 Submitted herewith is a sampling of those publications and references
`ranging from 1992 through the present. Upon request, Finjan is able to provide
`numerous additional publications and references discussing other types of engines.
`
`1.
`
`2.
`
`3.
`
`Attached as Exhibit 1 is an excerpt from the prosecution history of U.S.
`Patent No. 9,189,621. Exhibit 1 describes a “mutation engine” and shows
`the reference “Dark Avenger Mutation Engine No Threat to Protected
`PCs,” dated May 11, 1992.
`
`Attached as Exhibit 2 is U.S. Patent No. 5,680,547, entitled “Method and
`Apparatus for Controlling Network and Workstation Access Prior to
`Workstation Boot,” which was filed on August 8, 1995. Exhibit 2
`describes an “executable services engine.”
`
`Attached as Exhibit 3 is Finjan’s U.S. Patent No. 6,154,844, which was
`filed on December 22, 1997. Exhibit 3 describes a “protection engine,” a
`“content inspection engine,” a “security policy analysis engine,” a
`“Downloadable ID verification engine,” “Downloadable development
`engine,” a “network protection engine,” a “communications engine,” and a
`“web server engine.” Further, Claim 15, an asserted claim in this case,
`describes “content inspection engine.”
`
`1 The only case Eset submitted that mentions an “engine” is a PTAB case (Ex parte
`Smith) where “engine” was not even a claim term.
`2 By providing these references to the Court, Finjan is in no way admitting that the
`attached are relevant as prior art.
`
`FINJAN’S SUPP. INFORMATION
`RE: “ENGINE”
`
`1
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`CASE NO. 17-cv-00183-CAB-BGS
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8920 Page 3 of 122
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`4.
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`5.
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`6.
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`7.
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`8.
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`9.
`
`Attached as Exhibit 4 is a press release entitled “Symantec Announces
`Norton Antivirus for Firewalls for Maximum Protection from Internet-
`Borne Viruses,” dated May 6, 1997. Exhibit 4 describes the “Norton
`AntiVirus Engine.”
`
`Attached as Exhibit 5 is U.S. Patent No. 6,029,256, entitled “Method and
`System for Allowing Computer Programs Easy Access to Features of a
`Virus Scanning Engine,” which was filed on December 31, 1997. Exhibit
`5 describes a “virus scan engine.”
`
`Attached as Exhibit 6 is a true and correct copy of the abstract of an article
`entitled “Bugs in the Web,” dated in 1997. Exhibit 6 describes an “e-mail
`scanning engine” and “virus scanning engine.”
`
`Attached as Exhibit 7 is an article from the 7th USENIX Security
`Symposium entitled “Data Mining Approaches for Intrusion Detection,”
`dated January 1998. Exhibit 7 describes a “detection engine.”
`
`Attached as Exhibit 8 is the abstract for an article entitled “PicoJava: a
`direct execution engine for Java Bytecode,” dated October 1998. Exhibit 8
`describes an “execution engine.”
`
`Attached as Exhibit 9 is an excerpt from the prosecution history of the ‘621
`Patent. Exhibit 9 shows the reference, “Heuristic Engines,” dated
`September 2001.
`
`10. Attached as Exhibit 10 is an article from Symantec Community, entitled
`“Open AV: Developing Open Source AntiVirus Engines,” dated December
`16, 2002. Exhibit 10 describes an “antivirus engine” and “detection
`engine.”
`
`11. Attached as Exhibit 11 is an article from the SFGate entitled “Best
`antivirus software for 2005/Viruses and worms just keep getting smarter
`and more devious,” dated November 29, 2004. Exhibit 11 describes an
`“antivirus engine.”
`
`12. Attached as Exhibit 12 is an article from ESET entitled “ESET Update
`Boosts Engine Scanning Speed,” dated July 12, 2010. Exhibit 12 describes
`ESET’s “scanning engine.”
`
`FINJAN’S SUPP. INFORMATION
`RE: “ENGINE”
`
`2
`
`CASE NO. 17-cv-00183-CAB-BGS
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8921 Page 4 of 122
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`13. Attached as Exhibit 13 is ESET’s webpage entitled “ESET leading-edge
`technology,” as it exists today. Exhibit 13 describes ESET’s “scanning
`engine” and “detection engine.”
`
`14. Attached as Exhibit 14 is a true and correct copy of the Wikipedia.org
`webpage entitled “Comparison of antivirus software,” as it exists today.
`Exhibit 14 describes an “antivirus engine.”
`
`DATED: October 2, 2017
`
`Respectfully submitted,
`
`By: s/ James Hannah
`Paul J. Andre (State Bar. No. 196585)
`Lisa Kobialka (State Bar No. 191404)
`James Hannah (State Bar No. 237978)
`KRAMER LEVIN NAFTALIS
`& FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`pandre@kramerlevin.com
`lkobialka@kramerlevin.com
`jhannah@kramerlevin.com
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`FINJAN’S SUPP. INFORMATION
`RE: “ENGINE”
`
`3
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`CASE NO. 17-cv-00183-CAB-BGS
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8922 Page 5 of 122
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`Exhibit 1
`
`(cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3)
`
`

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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8924 Page 7 of 122
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`Exhibit 2
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`(cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3)
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`

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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8926 Page 9 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8929 Page 12 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8937 Page 20 of 122
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`Exhibit 3
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`(cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3)
`
`

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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8939 Page 22 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8940 Page 23 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8941 Page 24 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8942 Page 25 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8943 Page 26 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8944 Page 27 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8945 Page 28 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8946 Page 29 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8947 Page 30 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8950 Page 33 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8951 Page 34 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8952 Page 35 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8953 Page 36 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8954 Page 37 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8955 Page 38 of 122
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`Exhibit 4
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`(cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3)
`
`

`

`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8956 Page 39 of 122
`Symantec Announces Norton Antivirus For Firewalls For Maximum Protection From Internet-Borne Viruses | Symantec
`9/28/2017
`
`Press Releases
`
`SHARE:
`
`(cid:173) (cid:172) (cid:216)
`
`Symantec Announces Norton Antivirus For Firewalls For Maximum
`Protection From Internet-Borne Viruses
`Part of Symantec's Multi-Tier Security Solution (cid:1588) Norton AntiVirus for Firewalls
`Provides Maximum Anti-Virus Security for Corporate Firewalls
`CUPERTINO, Calif. —May 6, 1997— Symantec Corporation (Nasdaq: SYMC), the world's leading
`supplier of utilities and anti-virus software products today announced the introduction of Norton
`AntiVirus for Firewalls. As part of the Norton AntiVirus product line, this new product provides
`comprehensive anti-virus protection for corporations with compatible firewalls, by catching and
`destroying Internet-borne viruses before they invade corporate computer networks. Supported by
`industry-leading firewall vendors, Norton AntiVirus for Firewalls is used in conjunction with an
`existing firewall to provide an unparalleled corporate gateway security solution that provides
`maximum anti-virus protection from Internet-spread viruses, with an unrivaled degree of
`administrative flexibility and control at minimal expense to network throughput. Combined with the
`recently-released Norton AntiVirus Internet Email Gateways, Symantec delivers a complete solution
`of anti-virus protection for the corporate network gateways. administrative flexibility and control.
`
`"Norton AntiVirus for Firewalls addresses the growing need for a complete anti-virus solution at the
`corporate gateway level," said Enrique Salem, vice-president Symantec Security and Assistance
`Business Unit. "By detecting and destroying viruses in Internet, Web browsing, file transfer traffic,
`and Internet e-mail attachments, the corporate workplace is ensured of multi-level protection. Our
`development of robust anti-virus solutions such as Norton AntiVirus for Firewalls is a serious
`commitment towards providing Internet security and anti-virus protection to our corporate customers
`at all levels of their network infrastructure.".
`
`Defining AntiVirus Technology Standards for Firewall Integration
`
`NAV for Firewalls defines the standard for anti-virus technology integration with existing firewalls by
`minimizing network throughput degradation by intelligently scanning only suspicious traffic for
`
`https://www.symantec.com/about/newsroom/press-releases/1997/symantec_0506_01
`
`1/6
`
`

`

`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8957 Page 40 of 122
`Symantec Announces Norton Antivirus For Firewalls For Maximum Protection From Internet-Borne Viruses | Symantec
`9/28/2017
`viruses. An HTML user interface allows remote configuration. Supported by a consortium of
`industry-leading firewall vendors, NAV for Firewalls will be integrated seamlessly into existing
`corporate firewalls at virtually no degradation to overall network performance based on the
`revolutionary product architecture developed jointly by Symantec and Checkpoint Software
`Technologies. Symantec's partners include: Check Point Software Technologies, Trusted
`Information Systems (TIS), CyberGuard Corporation and Milkyway. In addition, Symantec plans to
`implement support for Microsoft's Proxy Server later this year. Together, these vendors hold
`approximately 50% market share of the firewall marketing according to market researcher
`International Data Corporation (IDC.)
`
`"Norton AntiVirus for Firewalls takes full advantage of the capabilities of the OPSEC Content
`Vectoring Protocol (CVP) to minimize performance impact and to provide and maximize anti-virus
`protection to Check Point FireWall-1 users," said Asheem Chandna, Director of Business
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`
`Product Features and Benefits
`
`This latest addition to the Norton AntiVirus product line is based on the award-winning Norton
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`AntiVirus engine. Norton AntiVirus for Firewalls is a Windows NT-based virus scanning server whichAntiVirus engine.
`utilizes Norton AntiVirus detection and removal technology. To be installed on a separate PC, NAV
`for Firewalls can be directly integrated into compatible firewalls, independent of operating systems.
`
`Another key benefit of NAV for Firewalls is that the administrator does not have to configure each of
`the client workstations individually to link up with a proxy, which prohibits any end-user by-pass
`possibilities. NAV for Firewalls is easy to configure through an HTML-based User Interface (UI),
`allowing multi-platform and remote configuration. NAV for Firewalls keeps track of detailed network
`security activities via a comprehensive activity log, and provides up-to-the-minute statistics of
`network activities in an HTML format to the network administrator.
`
`NAV for Firewalls scans and removes viruses found in Internet traffic, and is also capable of
`repairing infected files before forwarding to the end-user. In addition to anti-virus protection, NAV for
`Firewalls also has the capability of being configured to prevent certain types of files from entering
`the network, such as Java.CLASS files. NAV for Firewalls can be configured to scan three types of
`common Internet protocol files; HTTP, FTP, and SMTP; as well as an additional fourth protocol to be
`determined by the firewall.
`
`NAV for Firewalls incorporates an intelligent scanning architecture based on the Content Vectoring
`Protocol (CVP), whereby the firewall directs only suspicious traffic for a virus scan, which insures
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`integrated with compatible firewalls of any platform, Unix or NT. In summary, NAV for Firewalls
`offers these additional unparalleled features:
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`https://www.symantec.com/about/newsroom/press-releases/1997/symantec_0506_01
`
`2/6
`
`

`

`(cid:111)
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`(cid:111)
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`(cid:111)
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`(cid:111)
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8958 Page 41 of 122
`Symantec Announces Norton Antivirus For Firewalls For Maximum Protection From Internet-Borne Viruses | Symantec
`9/28/2017
`Comprehensive protection scans incoming and outgoing traffic types - including HTTP,
`FTP, SMTP, and has a reserved slot for a fourth Internet protocol type (to be determined by the
`firewalls) for viruses. NAV for Firewalls also scans virtually unlimited numbers of file extensions.
`
`Uses the award-winning, patent-pending Norton Anti-Virus Striker technology - an anti-anti-
`virus engine
`virus engine capable of detecting and removing even the dreaded Polymorphic viruses. Striker
`technology employs a revolutionary approach to the chameleon-like polymorphics. Each time
`NAV for Firewalls scans the gateway, it sets up a "virtual PC." This becomes a "clean room" in
`which NAV for Firewalls safely executes the potentially infected file without endangering other
`files.Separate and configurable scanning policies - for scanning inbound and outbound traffic,
`and uses a multi-thread scanning system to handle multiple simultaneous requests and scans.
`Provides maximum administrative flexibility - allowing administrators options for treating
`infected files including withhold (quarantine) and repair/remove.
`Minimal performance impact - provides users with minimal throughput degradation.
`Provides automatic and up-to-date virus definition updates, free via automatic and
`scheduleable LiveUpdate - provided from the Symantec AntiVirus Research Center (SARC)
`without any significant interruption of the daily network activities.
`Supported by an industry-leading consortium of firewall companies, NAV for Firewalls
`defines the standard of anti-virus for corporate firewalls. Compatible firewalls include:
`Checkpoint Firewall - Version 3.0 for UNIX, NT
`(cid:111)
`Trusted Information Systems (TIS) Gauntlet Firewall for UNIX 4.0 and NT
`CyberGuard Firewall
`Milkyway Blackhole Firewall (future release)(version 1.5, to be released Q2)
`Microsoft Proxy Server 1.0 (future release2)
`
`(cid:111)
`
`(cid:111)
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`(cid:111)
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`(cid:111)
`
`At the server level, NAV provides centralized control and customization, scheduled and on-demand
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`and use via an HTML user interface, NAV-IEG provides minimal performance impact as it
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`For large corporations equipped with firewalls who are concerned with Internet security threats such
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`Another key benefit of the entire NAV multi-tier product line up includes consistent and current one-
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`
`https://www.symantec.com/about/newsroom/press-releases/1997/symantec_0506_01
`
`3/6
`
`

`

`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8959 Page 42 of 122
`Symantec Announces Norton Antivirus For Firewalls For Maximum Protection From Internet-Borne Viruses | Symantec
`9/28/2017
`Bloodhound to prevent viruses from entering the corporate workplace. In addition, according to
`Secure Computing Best of Breed Solution Summary, January 1997, SARC leads the industry with a
`99.5% overall detection rate of "in the wild" viruses, using technologies such Seeker and SARA,
`next generation Polymorphic virus detection, and Macro Virus Protection (MVP) which uses access
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`(cid:111)
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`(cid:111)
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`(cid:111)
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`(cid:111)
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`Norton AntiVirus (NAV) 3.0 for DOS Windows 3.1
`Norton AntiVirus (NAV) 2.0 for Windows 95
`Norton AntiVirus (NAV) NT 2.0 for Windows NT
`Norton AntiVirus (NAV) Internet for Netscape
`Norton AntiVirus (NAV) 2.0 NetWare for Novell
`Symantec AntiVirus (SAM) 4.5 for Macintosh
`Norton AntiVirus (NAV) for Internet Email Gateways - NAV-IEG
`Norton AntiVirus (NAV) for Firewalls
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`About Symantec AntiVirus Research Center (SARC)
`
`NAV for Firewalls is backed by the Symantec AntiVirus Research Center (SARC). SARC is
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`
`Pricing, Availability and System Requirements
`
`NAV for Firewalls is expected to ship in mid-June, 1997. Pricing for corporate customers will be
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`Firewalls starts at $1,999, Estimated Retail Price (ERP); for 501-1000 users per firewall, the price is
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`Minimum recommended system requirements include Pentium 133 MHz or above CPU, Windows
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`Symantec Corporation develops, markets, and supports a complete line of application and system
`software products designed to enhance individual and workgroup productivity as well as manage
`networked computing environments. Platforms supported include IBM personal computers and
`compatibles, Apple Macintosh computers as well as all major network operating systems. Founded
`in 1982, the company's global operations span North America, Europe, Japan and several fast
`growing markets throughout Asia Pacific and Latin America. Information on the company and its
`products can be obtained by calling (800) 441-7234 toll free or (541) 334-6054.
`
`https://www.symantec.com/about/newsroom/press-releases/1997/symantec_0506_01
`
`4/6
`
`

`

`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8960 Page 43 of 122
`Symantec Announces Norton Antivirus For Firewalls For Maximum Protection From Internet-Borne Viruses | Symantec
`9/28/2017
`NOTE TO EDITORS: If you would like additional information on Symantec Corporation and its
`products, please view the Symantec Press Center at http://www.symantec.com/PressCenter/ on
`Symantec's website.
`
`Brands and products referenced herein are the trademarks or registered trademarks of their
`respective holders. All prices noted are in US. Microsoft, Windows NT, MS-DOS and windows are
`either registered trademarks or trademarks of Microsoft Corporation in the United States and/or
`other countries.
`
`Quotes
`Check Point Software Technologies, Inc.
`Asheem Chandna, Director of Business Development
`(415) 562-0410
`
`"We're pleased that Symantec has developed the Norton AntiVirus for Firewalls product based on
`the Content Vectoring Protocol (CVP), jointly developed between Symantec and Check Point" said
`Asheem Chandna, director of business development for Check Point Software Technologies, Inc.
`"Giving customers the ability to create a cohesive network security solution by integrating solid anti-
`virus protection with FireWall-1 is the driving force behind the commitment to CVP and Check
`Point's Open Platform for Secure Enterprise Connectivity strategy."
`
`Milkyway
`Cuong Nguyen, Vice President of Research and Development
`
`"The tight integration of Symantec's selective anti-viral client with our "no-compromise" Black Hole
`firewall provides our users with a faster throughput and greater performance efficiencies, particularly
`in heterogeneous environments." Nguyen continued to say; "Integrating Symantecs' anti-viral
`solution with our "hardened kernel" security architecture further supports Milkyway's focus of
`partnering with technology leaders to meet the requirements of our growing global customer base."
`
`Trusted Information Systems (TIS)
`Steven Lipner, Executive Vice President and General Manager, Network Security Products
`301-947-7299
`
`"We are happy to be working with a leader like Symantec to bring the latest in firewall-based
`scanning products to our customers. We've been very pleased with both the speed and quality of
`our joint engineering efforts."
`
`Trusted Information Systems (TIS)
`Jim Ishikawa, Director of Product Management,
`(301) 527-9500
`
`"With its unique management and control interface integrated with Gauntlet Firewall products,
`Norton AntiVirus for Firewalls is a very solid solution for Gauntlet customers. We are pleased to be
`adding this product to the TIS suite of Open Content Security solutions."
`
`https://www.symantec.com/about/newsroom/press-releases/1997/symantec_0506_01
`
`5/6
`
`

`

`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8961 Page 44 of 122
`Symantec Announces Norton Antivirus For Firewalls For Maximum Protection From Internet-Borne Viruses | Symantec
`9/28/2017
`CyberGuard Corporation
`Robert L. Carberry, president and CEO
`(954) 973-5290
`"CyberGuard believes that anti-virus is a critical part of a complete Internet/Intranet security
`solution. We are pleased to work with one of the leaders in anti-virus, Symantec, and its Norton
`AntiVirus for Firewalls product, to help provide superior solutions and services to our corporate
`customers."
`
`NOTE TO EDITORS: If you would like additional information on Symantec Corporation and its
`products, please view the Symantec Press Center at http://www.symantec.com/PressCenter/ on
`Symantec's website.
`
`
`
`Brands and products referenced herein are the trademarks or registered trademarks of their
`respective holders. All prices noted are in US dollars and are valid only in the United States.
`
`
`
`
`
`(cid:172) (cid:173) (cid:227) (cid:406) (cid:356)
`
`© 1995–2017 Symantec Corporation
`
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`https://www.symantec.com/about/newsroom/press-releases/1997/symantec_0506_01
`
`6/6
`
`

`

`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8962 Page 45 of 122
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`Exhibit 5
`
`(cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3)
`
`

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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8964 Page 47 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8966 Page 49 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8967 Page 50 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8968 Page 51 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8969 Page 52 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8970 Page 53 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8971 Page 54 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8972 Page 55 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8973 Page 56 of 122
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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8974 Page 57 of 122
`
`Exhibit 6
`
`(cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3)
`
`

`

`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8975 Page 58 of 122
`Bugs in the Web
`10/2/2017
`
`Polski English
`
`remember me
`
`Login or register account
`password recovery
`
`Bugs in the Web
`Jonathan Richardson
`
`Details Contributors
`
`Fields of science Bibliography Quotations Similar Collections
`
`Source
`
`Computers & Security > 1997 > 16 > 4 > 332-333
`
`Abstract
`There is no doubt that over the past couple of years users' awareness of the risk of virus infection has increased. To
`understand the issues at stake it is first important to understand the nature if virus attacks. There are three main types
`of virus, these are: boot sector, executable and data-borne viruses. Boot sector viruses are the easiest to trap since
`they spread by infecting the boot sector of floppy disks. Executable viruses are harder to trap but it is still possible.
`Data-borne viruses are epitomized by the Word macro virus. Data-borne viruses are very hard to locate since they
`operate within host programs such as Excel and Word. By far the best virus protection policy on networks is to
`provide full virus scanning at the point of entry of files. Scanning files as they are accessed will always slow down the
`user's workstation however well the scanning works. A better option is to only scan the files as they enter the PC.
`SWEEP uses Sophos' InterCheck Technology to eliminate the need to scan each file for all known viruses every time
`it is accessed. There have for some years been NLM-based server virus protection modules. These can either scan
`files as they are accessed or be set to run at scheduled intervals to scan all files. Products such as Norton Anti Virus
`for NetWare run as server-based processes to ensure that the server remains clean at all times. Internet-borne
`viruses are not intercepted by server-based anti-virus software because the connection to the Internet typically
`bypasses the network server. The InterScan VirusWall product removes the need to have client-based scanners
`looking at the Internet content as it arrives at the user's workstation. Instead, a real-time E-mail scanning engine is
`E-mail scanning engine
`placed on the Internet Gateway. InterScan VirusWall is composed of a virus scanning engine and a Simple Mail
` virus scanning engine
`Transfer Protocol proxy server. The Integralis MIMEsweeper scans incoming E-mail to detect viruses, allowing control
`of full E-mail content. Both Java and ActiveX pose security problems since they are Internet-borne applications. The
`only safeguard at present is via certification schemes where safe controls are independently validated. With a proper
`set of security products ranging from packet level firewalls to Web content and E-mail scanners, plus correct
`configuration of your network, there is no reason why connecting to the Internet should pose a security threat.
`
`less
`
`Identifiers
`journal ISSN : 0167-4048
`
`Authors
`
`Jonathan Richardson
`
`Additional information
`Publication
`English
`languages:
`
`Data set:
`
`Elsevier
`
`https://www.infona.pl/resource/bwmeta1.element.elsevier-8a2dc931-1653-3b83-8207-56d66ab3ad4a
`
`1/2
`
`

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`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8976 Page 59 of 122
`Bugs in the Web
`10/2/2017
`Publisher
`
`Elsevier Science
`
`Fields of science
`No field of science has been suggested yet.
`
`© 2015 Interdisciplinary Centre for Mathematical and Computational Modelling
`
`https://www.infona.pl/resource/bwmeta1.element.elsevier-8a2dc931-1653-3b83-8207-56d66ab3ad4a
`
`2/2
`
`

`

`Case 3:17-cv-00183-CAB-BGS Document 191 Filed 10/25/17 PageID.8977