SYMANTEC CONFIDENTIAL INFORMATION REDACTED
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`RICHMOND DIVISION
`
`THE TRUSTEES OF COLUMBIA
`UNIVERSITY IN THE CITY OF NEW
`YORK,
`
`Plaintiff
`
`v.
`
`SYMANTEC CORPORATION,
`
`Defendant
`
`Civil Action No. 3:13-cv-00808-JRS
`
`EXPERT REPORT OF DR. RICHARD FORD REGARDING INVALIDITY OF
`U.S. PATENT NOS. 7,448,084, 7,913,306, 8,074,115 & 8,601,322
`
`
`Exhibit Page 1
`
`Columbia Ex. 2003
`Symantec v. Columbia
`IPR2015-00375
`
`

`
`SYMANTEC CONFIDENTIAL INFORMATION REDACTED
`
`III. BASIS FOR OPINIONS
`
`A. (cid:9)
`
`Qualifications
`
`13. My experience and education are detailed in my curriculum vita, which is
`
`attached as Appendix 1 to this report.
`
`14.
`
`I am currently the Head of the Computer Sciences & Cybersecurity Department at
`
`the Florida Institute of Technology. I am a full Professor, and hold the endowed Harris Professor
`
`of Computer science chair. Prior to my position at the Florida Institute of Technology, I held
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`positions in industry including positions at IBM Research, working on anti-malware software,
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`and Command Software Systems, where I was responsible for testing and research on
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`Command’s anti-malware product line throughout the United States. I have published over 90
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`papers in workshops, conferences, and journals in the areas of computer security, malicious code
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`detection, and other areas of computer science. A copy of my publication list is attached within
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`Appendix 1 of this report. During my employment at Florida Institute of Technology, I have
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`taught both undergraduate and graduate courses in subjects ranging such as Malicious Code,
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`C++ Programming, Secure Operating Systems, Assembly Language and Host and Application
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`Security.
`
`15.
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`I hold a D.Phil in Semiconductor Physics from the University of Oxford, in
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`addition to an MA and BA in Physics from the University of Oxford.
`
`16.
`
`After graduation from Oxford, I joined Virus Bulletin, and was made Editor in
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`1992. Virus Bulletin is the world’s foremost publication on Computer Viruses and Malware. In
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`this position, I was engaged with almost every industry expert in malware. I also was
`
`instrumental in organizing a yearly conference attended by most industry experts in the anti-
`
`malware field. Papers presented at the conference are compiled into a publication
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`entitled Proceedings of the Virus Bulletin Conference for the given year. I have maintained
`
`3
`
`
`Exhibit Page 2
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`Columbia Ex. 2003
`Symantec v. Columbia
`IPR2015-00375
`
`

`
`SYMANTEC CONFIDENTIAL INFORMATION REDACTED
`
`copies of these Proceedings, including the 1995, 1998, and 2000 Proceedings.
`
`17.
`
`Since then, my research has continued in the field of computer security, viruses
`
`and malware, and I have received support from various government and industry leaders,
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`including the U.S. Department of Defense, Microsoft, Symantec, Cisco and Harris Corporation.
`
`I have been a Principal Investigator or co-Principal Investigator on research grants and contracts
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`totaling over $6 million in research funding.
`
`18.
`
`In 2012, I was recognized by the Computer Antivirus Research Organization
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`(CARO) and invited to membership in this group of the leading technical anti-malware
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`researchers in the world. Comprising approximately 30 members, CARO represents the most
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`active and technical anti-malware researchers in the world, and is an invitation-only
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`organization.
`
`19.
`
`In 2012, I was made President and CEO of the Anti-Malware Testing Standards
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`Organization. This organization has approximately 35 members, including McAfee, AVG,
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`Symantec, and Webroot. The mission of AMTSO is to improve the scientific validity of tests of
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`endpoint security software.
`
`B. (cid:9)
`
`Materials Considered
`
`20.
`
`In reaching the conclusions described herein, I have considered the documents
`
`and materials referenced in this report and identified in Appendix 2. My opinions are also based
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`upon my education, training, research, knowledge and personal and professional experience.
`
`IV. (cid:9)
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`LEGAL STANDARDS
`
`21.
`
`In this section I describe my understanding of certain legal standards. I have been
`
`informed of these legal standards by Symantec’s attorneys. I am not an attorney and I am relying
`
`only on instructions from Symantec’s attorneys for these legal standards.
`
`4
`
`
`Exhibit Page 3
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`Columbia Ex. 2003
`Symantec v. Columbia
`IPR2015-00375
`
`

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`SYMANTEC CONFIDENTIAL INFORMATION REDACTED
`
`V. (cid:9)
`
`LEVEL OF ORDINARY SKILL IN THE ART
`
`94.
`
`In reaching the opinions set forth in this report, I have analyzed the asserted
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`patents and prior art from the perspective of a person of ordinary skill in the art at the time of the
`
`invention. For the ‘084 and ‘306 patents, it is my opinion that a person of ordinary skill in the art
`
`at the time of the invention would have had a Master’s degree in computer science, computer
`
`engineering, or a similar field, or a Bachelor’s degree in computer science, computer
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`engineering, or a similar field, with approximately two years of industry experience relating to
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`computer security. Additional graduate education might substitute for experience, while
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`significant experience in the field of computer programming and malicious code might substitute
`
`for formal education. For the ‘115 and ‘322 patents, it is my opinion that a person of ordinary
`
`skill in the art at the time of the invention would have similar credentials to those identified for
`
`the ‘084 and ‘306 patents.
`
`95.
`
`I understand that Columbia’s has previously asserted that a person of ordinary
`
`skill in the art for all three asserted patent families, including the ‘084, ‘306, ‘115, and ‘322
`
`patents, would have had an undergraduate degree in computer science or mathematics, and one
`
`to two years of experience in the field of computer security. See August 15, 2014 Declaration of
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`Professor Douglas C. Szajda, 8-9.
`
`96.
`
`The level of ordinary skill identified by Dr. Szajda above is sufficiently close to
`
`my understanding and would not change the conclusions of my analysis.
`
`97.
`
`I meet the criteria I describe above, as well as the criteria proposed by Columbia,
`
`and consider myself to be a person with, at a minimum, ordinary skill in the art pertaining to the
`
`‘084, ‘306, ‘115, and ‘322 patents, as well as at the time of the alleged invention(s) for those
`
`patents.
`
`VI. (cid:9)
`
`U.S. PATENT NOS. 7,448,084 AND 7,913,306
`
`20
`
`
`Exhibit Page 4
`
`Columbia Ex. 2003
`Symantec v. Columbia
`IPR2015-00375
`
`

`
`HIGHLY CONFIDENTIAL — OUTSIDE COUNSEL ONLY
`
`Date: October 17, 2014
`
`/ Ford
`
`
`Exhibit Page 5
`
`Columbia Ex. 2003
`Symantec v. Columbia
`IPR2015-00375