`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In the Inter Partes Review of:
`
`Trial Number: To Be Assigned
`
`
`
`U.S. Patent No. 6,715,084
`
`Filed: March 26, 2002
`
`Issued: March 30, 2004
`
`Inventor(s): Jeffrey A. Aaron, Thomas
`Anschutz
`
`Assignee: Intellectual Ventures II LLC
`
`Title: Firewall System and Method via
`Feedback from Broad-Scope
`Monitoring for Intrusion Detection
`
`
`
`
`
`
`
`
`
`
`
`Panel: To Be Assigned
`
`Mail Stop Inter Partes Review
`Commissions for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`DECLARATION OF EUGENE GORYUNOV
`
`
`
`IBM Ex. 1004
`
`
`
`
`
`I, Eugene Goryunov, do hereby declare as follows:
`
`1.
`
`I am an attorney at the law firm of Kirkland & Ellis LLP, 300 N. LaSalle,
`
`Chicago, Illinois 60654, and serve as counsel for Petitioner International
`
`Business Machines, Corp. (“IBM”). I submit this declaration in support of
`
`IBM’s Petition for Inter Partes Review Under 37 C.F.R. § 42.100 of U.S.
`
`Patent No. 6,715,084 (“Petition”). I am over twenty-one years of age and
`
`not under any legal disability. I have personal knowledge of the following
`
`facts and, if called as a witness, could and would testify competently thereto.
`
`2.
`
`Attached hereto as Exhibit 1005 is a true and correct copy of U.S. Pat. No.
`
`6,715,084 to Aaron, et al. (“the ’084 Patent”).
`
`3.
`
`Attached hereto as Exhibit 1006 is a true and correct copy of Porras, et al.,
`
`Live Traffic Analysis of TCP/IP Gateways.
`
`4.
`
`Attached hereto as Exhibit 1007 is a true and correct copy of U.S. Pat. No.
`
`7,237,264, to Graham, et al.
`
`5.
`
`Attached hereto as Exhibit 1008 is a true and correct copy of NetRanger
`
`User’s Guide, Version 1.3.1.
`
`6.
`
`Attached hereto as Exhibit 1009 is a true and correct copy of Snapp, et al., A
`
`System for Distributed Intrusion Detection.
`
`a
`
`
`
`
`
`7.
`
`Attached hereto as Exhibit 1010 is a true and correct copy of excerpts from
`
`the file history of U.S. Patent Application No. 10/108,078 (“the ’078
`
`Application”): September 22, 2003, Reply.
`
`8.
`
`Attached hereto as Exhibit 1011 is a true and correct copy of the Claim
`
`Construction Order (D. 82), Intellectual Ventures II LLC v. JP Morgan
`
`Chase & Co., et al., No. 1:13–cv–03777 (S.D.N.Y.).
`
`9.
`
`Attached hereto as Exhibit 1012 is a true and correct copy of the Second
`
`Letter to Judge Hellerstein re Revised Claim Construction Chart (D. 76),
`
`Intellectual Ventures II LLC v. JP Morgan Chase & Co., et al., No. 1:13–
`
`cv–03777 (S.D.N.Y.).
`
`10. Attached hereto as Exhibit 1013 is a true and correct copy of the Transcript
`
`of the March 5, 2014, Claim Construction Hearing, Intellectual Ventures II
`
`LLC v. JP Morgan Chase & Co., et al., No. 1:13–cv–03777 (S.D.N.Y.).
`
`11. Attached hereto as Exhibit 1014 is a true and correct copy of the ’078
`
`Application.
`
`12. Attached hereto as Exhibit 1015 is a true and correct copy of excerpts from
`
`the file history of the ’078 Application: June 23, 2003, Office Action.
`
`13. Attached hereto as Exhibit 1016 is a true and correct copy of USPTO
`
`Assignments on the Web for the ’084 Patent.
`
`
`
`b
`
`
`
`
`
`14. Attached hereto as Exhibit 1017 is a true and correct copy of the CERT
`
`Advisory, CA-2001-19.
`
`15. Attached hereto as Exhibit 1018 is a true and correct copy of Bellovin, There
`
`Be Dragons.
`
`16. Attached hereto as Exhibit 1019 is a true and correct copy of excerpts from
`
`William R. Cheswick, et al., Firewalls and Internet Security: Repelling the
`
`Wily Hacker.
`
`17.
`
`I hereby declare under penalty of perjury under the laws of the United States
`
`of America that the foregoing is true and correct, and that all statements
`
`made of my own knowledge are true and that all statements made on
`
`information and belief are believed to be true. I understand that willful false
`
`statements are punishable by fine or imprisonment or both. See 18 U.S.C.
`
`§ 1001.
`
`Date: April 23, 2014
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Eugene Goryunov
`Eugene Goryunov
`
`c
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Declaration of
`
`Eugene Goryunov was served on April 23, 2014, via FedEx Express delivery
`
`directed to the attorney of record for the patent at the following address:
`
`Turocy & Watson LLP
`127 Public Square
`57th Floor, Key Tower
`Cleveland, OH 44114
`
` A
`
` copy was also served via FedEx Express delivery on:
`
`Ian N. Feinberg
`Feinberg, Day Law Firm
`1600 El Camino Real, Suite 280
`Menlo Park, CA 94025
`David J. Koukol
`Koukol, Johnson Law Firm
`12020 Shamrock Plaza, Suite 333
`Omaha, NE 68154
`
`William Irvin Dunnegan
`Dunnegan LLC
`350 Fifth Avenue
`New York, NY 10118
`A H Gaede , Jr
`Bainbridge Mims Rogers & Smith LLP
`600 Luckie Drive
`P O Box 530886
`Birmingham, AL 35223
`
`
`Norman Eli Siegel
`Stueve Siegel Hanson, LLP
`460 Nichols Road, Suite 200
`Kansas City, MO 64112
`Zahra S. Karinshak
`Krevolin & Horst LLC
`One Atlantic Center
`1201 West Peachtree Street, Suite 3250
`Atlanta, GA 30309
`Edwin E Voigt, II
`Vidas Arrett & Steinkraus
`6640 Shady Oak Rd, Suite 400
`Eden Prairie, MN 55344
`Charles Joseph Faruki
`Faruki Ireland & Cox PLL - 3
`500 Courthouse Plaza, SW
`10 N Ludlow Street
`Dayton, OH 45402-1818
`
` /s/ Eugene Goryunov
`Eugene Goryunov
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
