`
`I, John Hawes, declare as follows:
`
`1.
`
`I am over the age of majority and make this declaration based on the business
`
`records of my employer, Virus Bulletin.
`
`2.
`
`I ain the Chief of Operations at Virus Bulletin, running the business side of the
`
`company since 2014 and managing all aspects of product testing and reviews since 2006. Virus
`
`Bulletin is an online magazine about the prevention, detection, and removal of malware and
`
`spam. It regularly features analyses of the latest virus threats, articles exploring new
`
`developments in the fight against viruses, interviews with anti-virus experts, and evaluations of
`
`current anti-malware products. Virus Bulletin has run an annual international conference on
`
`malware, anti-malware, and related subjects since 1991. Virus Bulletin is headquartered at The
`
`Pentagon, Abingdon Science Park, Abingdon, OX14 3YP, United Kingdom.
`
`3.
`
`Attached as Exhibit A is a true and correct copy of a declaration I signed on or
`
`about October 15, 2015. Exhibit A includes a true and correct copy of the paper entitled
`
`"Dynamic Detection and Classification of Computer Viruses Using General Behaviour Patterns,"
`
`by Morton Swimmer, which Virus Bulletin published in 1995 and which is attached to my
`
`October 15, 2015 declaration.
`
`4.
`
`As I stated in my October 15, 2015 declaration, the paper entitled "Dynamic
`
`Detection and Classification of Computer Viruses Using General Behaviour Patterns" was
`
`published to all 163 attendees of the Virus Bulletin International Conference at the Boston Park
`
`Plaza Hotel and Towers in September• 1995. The paper was included in the conference
`
`proceedings book that was distributed to all conference attendees and subsequently made
`
`available for purchase by Virus Bulletin.
`
`Symantec 1045
`Symantec v. Finjan
`IPR2015-01892
`
`000001
`
`
`
`The copy of the Swimmer paper included with Exhibit A is part of the conference
`
`proceedings book that was prepared by Virus Bulletin employees in 1995 and that has been kept
`
`at Virus Bulletin's offices ever since. Virus Bulletin prepares and publishes a conference
`
`proceedings book for each of its annual conferences, which date back to 1991. Each conference
`
`proceedings book is prepared and maintained by Virus Bulletin employees in the course of Virus
`
`Bulletin's regularly conducted business activity.
`
`6.
`
`Attached as Exhibit B is a true and correct copy of a list of 163 delegates, or
`
`attendees, who registered to attend the 1995 Virus Bulletin International Conference. The list
`
`was created by Virus Bulletin employees in 1995 and has been stored along with other
`
`conference materials, including the conference proceedings book, at Virus Bulletin's offices ever
`
`since. Virus Bulletin creates and maintains delegate lists for its annual conferences in the course
`
`of its regularly conducted business activity.
`
`7.
`
`Attached as Exhibit C is a true and correct copy of a brochure for the 1995 Virus
`
`Bulletin International Conference that was created by Virus Bulletin employees in 1995 and that
`
`has been. stored along with other conference materials, including the conference proceedings
`
`book, at Virus Bulletin's offices ever since. Virus Bulletin distributes brochures for its annual
`
`conferences as an insert in various industry publications. Virus Bulletin creates and maintains
`
`these brochures in the course of its regularly conducted business activity.
`
`8.
`
`Attached as Exhibit D is a true and correct copy of the November 1995 issue of
`
`Virus Bulletin magazine, which was distributed by mail to all Virus Bulletin subscribers. The
`
`November 1995 issue of Virus Bulletin magazine was published and maintained in the course of
`
`Vitus Bulletin's regularly conducted business activity.
`
`000002
`
`
`
`9.
`
`I hereby declare that all statements made herein of my own knowledge are true
`
`and that all statements made on information and belief are believed to be true, and further that
`
`these statements were made with the knowledge that willful false statements and the like are
`
`punishable by fine or imprisonment, or both, under• 18 U.S.C. § 1001.
`
`Executed in Denver, Colorado, U.S.A., on October 7, 2016.
`
`..~.
`~f
`_.~
`
`fj`"
`
`~~
`
`John Hawes
`
`000003
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