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` 1 - ROUGH - JOHN HAWES -
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` 2 REALTIME AND ROUGH DRAFT DISCLAIMER
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` 3 ----------------------------------------------
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` 4 For the parties working with realtime and rough
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` 5 draft transcripts, understand that if you choose
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` 6 to use the realtime rough draft screen or the
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` 7 printout, that you are doing so with the
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` 8 understanding that the rough draft is a
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` 9 noncertified copy.
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` 10
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` 11 Case: Palo Alto Networks v Finjan, Inc.
` and Symantec Corp, Blue Coat
` 12 Systems, Inc. v Finjan, Inc.
`
` 13 Witness: John Hawes
`
` 14 Date: 11-30-16
`
` 15 REPORTER'S NOTE:
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` 16 The rough draft transcript should not be cited at
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` 17 any time since this deposition has been realtimed
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` 18 and is in rough draft form. There will be a
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` 19 discrepancy regarding page and line number when
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` 20 comparing the realtime screen, the rough draft,
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` 21 rough draft disk, and the final transcript.
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` 22
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` 23 Also please be aware that the realtime screen and
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` 24 the noncertified rough draft transcript may
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` 25 contain untranslated steno, reporter notes,
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`Patent Owner Finjan, Inc. - Ex. 2042, p. 1
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`Hawes ROUGH - 113016.txt
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` 2 misspelled proper names, incorrect or missing Q/A
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` 3 symbols or punctuation, and/or nonsensical English
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` 4 word combinations. All such entries will be
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` 5 correct on the final, certified transcript.
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` 1 - ROUGH - JOHN HAWES -
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` 2
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` 3 JOHN HAWES, called as a witness,
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` 4 having been duly sworn on November 30, 2016,
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` 5 by a Notary Public, was examined and
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`Hawes ROUGH - 113016.txt
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` 6 testified as follows:
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` 7 Virus Bulletin Limited
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` 8 The Pentagon
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` 9 Abingdon Science Park
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` 10 Abingdon Oxon UK
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` 11 (Business)
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` 12
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` 13 EXAMINATION BY MS. HEDVAT:
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` 14 Q. Good morning
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` 15 A. Hi.
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` 16 Q. May I ask you to state your name for
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` 17 the record, please.
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` 18 A. My name is John Hawes.
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` 19 Q. Thank you, Mr. Hawes.
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` 20 Do you understand why you're here
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` 21 today?
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` 22 A. I think so.
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` 23 Q. Have you been deposed before?
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` 24 A. I have.
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` 25 Q. And how many times?
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` 1 - ROUGH - JOHN HAWES -
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` 2 A. Once.
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` 3 Q. In what context?
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` 4 A. The first piece of evidence that I
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` 5 provided for this case, the scan of the paper, the
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` 6 Morton Swimmer's 1995 paper in the various
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` 7 bulletin conference.
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` 8 Q. So as you know from your first
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` 9 deposition, I'll be asking you some questions.
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` 10 If there's anything that you need
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` 11 clarity on, I ask that you ask for clarification
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` 12 and if not, I'll -- the mutual understanding would
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` 13 be that you have no questions about what my
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` 14 question is asking you.
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` 15 A. Okay.
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` 16 Q. Is there any reason you feel that you
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` 17 cannot give your best and most accurate testimony
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` 18 today?
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` 19 A. No.
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` 20 Q. When were you first contacted about
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` 21 having to give this deposition today?
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` 22 A. I guess it was mid-October I think.
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` 23 Q. Of this year?
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` 24 A. Yes.
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` 25 Q. Who contacted you?
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` 1 - ROUGH - JOHN HAWES -
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` 2 A. Brian.
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` 3 Q. What did he tell you about this
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` 4 deposition?
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` 5 A. That I might be required to give
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` 6 another deposition.
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` 7 Q. And when you were contacted initially
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` 8 to work on these cases, who contacted you?
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` 9 A. Brian.
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` 10 Q. And what did he tell you your
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` 11 assignment was?
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` 12 A. I was asked to provide a scan of the
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` 13 Morton Swimmer paper. That was the initial thing,
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` 14 the first thing I was asked to do.
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` 15 Q. When did he contact you about that?
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` 16 A. Early this year I think.
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` 17 Q. Did you meet with anyone to prepare
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` 18 for your deposition today?
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` 19 A. Not really. We had a brief
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` 20 conversation while we were waiting for you guys to
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` 21 arrive.
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` 22 Q. For clarification, who is "we"?
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` 23 A. Myself, Brian, and I'm sorry -- Alex.
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` 24 (Whereupon, Exhibit 1 was marked at
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` 25 this time.)
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` 1 - ROUGH - JOHN HAWES -
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` 2 Q. You have been handed what's been
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` 3 marked as Exhibit 1. Do you recognize this
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` 4 document?
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` 5 A. Yes.
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` 6 Q. And what is this document?
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` 7 A. I think this is the second -- yes,
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` 8 this is a piece of paper that I signed in Denver
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` 9 declaring that some of the documents that I
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` 10 provided were what they claim to be.
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` 11 Q. If I could direct your attention to
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` 12 the third page of this document. Is that your
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` 13 signature?
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` 14 A. Yes, it is.
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` 15 Q. So, if I could direct your attention
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` 16 to Paragraph 2 of this declaration, it states that
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` 17 you are the chief of operations of Virus Bulletin.
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` 18 Is that your current position?
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` 19 A. Yes.
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` 20 Q. What does your role entail that in
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` 21 position?
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` 22 A. I essentially run the company. I set
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` 23 budgets, I manage the team, I decide strategy and
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` 24 direction.
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` 25 Q. How long have you held that position?
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` 1 - ROUGH - JOHN HAWES -
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` 2 A. Since mid 2014.
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` 3 Q. Were you at Virus Bulletin before
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` 4 2014?
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` 5 A. Yes.
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` 6 Q. What positions did you hold?
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` 7 A. I was originally technical consultant
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` 8 and subsequently team director.
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` 9 Q. During what time frame did you hold
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` 10 those positions?
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` 11 A. I started with VB in 2006 and I think
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` 12 they made me test team director in around 2010.
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` 13 Q. What -- where did you work prior to
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` 14 2006?
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` 15 A. I worked at Sophos.
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` 16 Q. In what capacity?
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` 17 A. I was a test engineer.
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` 18 Q. What did that role entail?
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`Hawes ROUGH - 113016.txt
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` 19 A. Testing anti-virus products, QA.
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` 20 Q. So when you were contacted about this
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` 21 declaration in front of you, what specifically
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` 22 were you asked to do?
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` 23 A. I was asked -- I had previously been
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` 24 asked to provide scans of several documents and
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` 25 then I was asked to sign this piece of paper
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` 1 - ROUGH - JOHN HAWES -
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` 2 confirming that they were scans of those
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` 3 documents.
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` 4 Q. And that was with respect to your
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` 5 first declaration or second?
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` 6 A. The second one -- well, they're both
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` 7 pretty much the same process.
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` 8 Q. What did you understand the purpose
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` 9 was of scanning those documents?
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` 10 A. To provide supporting evidence that
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` 11 the original document, that the Morton Swimmer
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` 12 paper was published by us.
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` 13 Q. And the documents that you provide
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` 14 with this declaration here, those could have been
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` 15 located with your first declaration during that
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` 16 time frame?
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` 17 MR. EUTERMOSER: Object to the form.
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` 18 A. Sorry, could have been located?
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` 19 Q. They could have been -- let me
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` 20 retract.
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` 21 So you mentioned that you scanned in
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` 22 documents in connection with this declaration,
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` 23 correct?
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` 24 A. Yes.
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` 25 Q. And the scanning of those documents
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` 1 - ROUGH - JOHN HAWES -
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` 2 could have been performed for example at the time
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` 3 frame when you submitted your first declaration in
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` 4 these proceedings?
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` 5 A. Could have been.
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` 6 Q. Now could you direct your attention
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` 7 back to paragraph 2 in the declaration in front of
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` 8 you?
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` 9 A. Okay.
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` 10 Q. It states towards the end that Virus
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` 11 Bulletin has run an annual international
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` 12 conference on malware, antimalware and related
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` 13 subjects since 1999.
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` 14 A. 1991.
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` 15 Q. Sorry.
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` 16 A. 1991.
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` 17 Q. Oh 1991, excuse me. Thank you.
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` 18 Have you ever attended any of these
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` 19 annual conferences?
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` 20 A. Yes I've attended every one since
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` 21 2005.
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` 22 Q. In what capacity have you attended
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` 23 those conferences?
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` 24 A. In 2005 in Dublin I was an employee
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` 25 of Sophos so I was a delegate at the conference
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` 1 - ROUGH - JOHN HAWES -
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` 2 and at the subsequent, 11 I think, I've been an
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` 3 employee of Virus Bulletin so I have been helping
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` 4 to run the conference.
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` 5 Q. Then in Paragraph 2 you also mention
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` 6 that Virus Bulletin is an online magazine. When
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` 7 did it first become an online magazine?
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` 8 A. Currently we are entirely online.
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` 9 Previously we had published paper editions. I
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` 10 think we stopped publishing the paper editions in
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` 11 2006 --
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` 12 Q. When did you -- sorry.
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` 13 A. By that point we were already
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` 14 publishing everything online as well so there was
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` 15 a period of overlap.
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` 16 Q. When did you first -- when did Virus
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` 17 Bulletin start publishing the magazine in general,
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` 18 not online just in paper?
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` 19 MR. EUTERMOSER: Object to the form.
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` 20 A. Off the top of my head I'm not sure
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` 21 but it was the first thing we did so it was before
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` 22 the conference started, so before 1991.
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` 23 Q. The online magazine today, who has
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` 24 access to it?
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` 25 A. It's freely available to anybody on
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` 2 the Internet.
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` 3 Q. Prior to the magazine being online,
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` 4 who had access to it when it was in print?
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` 5 A. We had areas of the website which
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` 6 were available only to paying subscribers and
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` 7 likewise the print edition was only available to
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` 8 paying subscribers.
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` 9 Q. What's the basis of your knowledge
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` 10 for this?
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` 11 A. My working for the company.
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` 12 (Whereupon, Exhibit 2 was marked at
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` 13 this time.)
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` 14 Q. You have been handed what's marked as
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` 15 Exhibit 2. Do you recognize this document?
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` 16 A. Yes.
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` 17 Is this not the same one?
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` 18 Q. What is this document?
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` 19 It's not a trick. I just want to
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` 20 confirm unless would you like to state on the
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` 21 record that the same was submitted in both
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` 22 proceedings, whatever.
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` 23 A. The piece of paper that I signed in
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` 24 Denver.
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` 25 Q. Okay. Is this -- again, Mr. Hawes,
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` 2 this is not a matter of trickery. This is just a
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` 3 matter of course to confirm that it's the same
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` 4 declaration.
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` 5 Can you confirm that the Exhibit 2
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` 6 that's been handed to you is the same as the first
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` 7 three pages of Exhibit 1 that's been handed to
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` 8 you?
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` 9 A. It certainly looks to be, yes.
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` 10 Q. So if I could direct your attention
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` 11 back to Exhibit 1, in particular Paragraph 3.
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` 12 A. Yes.
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` 13 Q. Where you reference Exhibit A, which
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` 14 is I believe Page 4 or 5.
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` 15 A. Uh-huh.
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` 16 Q. What is Exhibit A?
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` 17 A. That's the first declaration that I'd
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` 18 signed previously.
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` 19 Q. And then in Paragraph 4 of Exhibit A,
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` 20 your most recent declaration, you state that in
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` 21 your October 15th, 2015 declaration the paper
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` 22 entitled "Dynamic Detection and Classification of
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` 23 Computer Viruses Using General Behavior Patterns"
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` 24 was published and couple of lines down it says,
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` 25 "September 1995."
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` 2 What is the basis for your knowledge
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` 3 of this statement?
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` 4 A. The records of my company.
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` 5 Q. What are those records?
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` 6 A. We keep copies of all the conference
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` 7 books that we have produced for each conference
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` 8 going back to the very beginning in 1991.
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` 9 They're stored in an archive which we
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` 10 reference quite regularly.
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` 11 Q. How do you known, as you state in
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` 12 Paragraph 4 of your declaration, that the paper
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` 13 you reference was "published to all 163 attendees
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` 14 of the conference in September 1995?"
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` 15 A. It's our standard business practice
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` 16 that we produce a book of the proceedings that's
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` 17 provided to everybody that attends the conference.
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` 18 Q. Did you attend that conference in
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` 19 September 1995?
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` 20 A. I did not.
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` 21 Q. Did you speak with anyone who did
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` 22 attend that conference?
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` 23 A. I spoke to many people who attended
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` 24 that conference.
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` 25 Q. Specifically about that conference?
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` 2 A. I -- yes, I would say it's very
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` 3 likely that I've spoken to people who attended
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` 4 that particular conference.
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` 5 Q. Did you speak with any of them in
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` 6 preparing this declaration?
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` 7 MR. EUTERMOSER: Object to the form.
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` 8 A. I wasn't really -- in preparing this
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` 9 declaration I mentioned to some of them that I had
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` 10 been asked to give a declaration about that
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` 11 particular conference.
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` 12 Q. The last sentence of Paragraph 4 of
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` 13 your declaration you state that "The paper was
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` 14 subsequently made available for purchase by Virus
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` 15 Bulletin."
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` 16 A. Yes.
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` 17 Q. What does that mean for a paper to be
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` 18 available for purchase?
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` 19 A. So after the conference is over, we
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` 20 keep several copies of the book because people who
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` 21 were unable to attend or for whatever reason,
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` 22 quite often want copies of it so we make it
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` 23 available for people to purchase separate from
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` 24 attending the conference.
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` 25 It's also considered to be cheaper
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` 1 - ROUGH - JOHN HAWES -
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` 2 than attending the conference just to buy the
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` 3 book.
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` 4 Q. Do you know anyone who purchased the
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` 5 proceedings book that you referenced in your
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` 6 Paragraph 4 of your declaration?
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` 7 A. No, I don't.
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` 8 Q. What exactly is a proceedings book?
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` 9 A. So, the conference mainly consists of
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` 10 a number of presentations, somewhere around 50 at
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` 11 the moment.
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` 12 It varies from year to year depending
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` 13 on the setup and each of those the main
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` 14 presentations accompanied by a paper and those are
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` 15 all collected in book form which may be a ring
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` 16 bound or fully bound book.
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` 17 It also contains other information
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` 18 about the conference, location and so on.
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` 19 Q. Who prepares the proceedings book?
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` 20 A. The Virus Bulletin team.
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` 21 Q. Do you know who prepared the
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` 22 proceedings book for the specific conference in
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` 23 September 1995 that you reference?
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` 24 A. I do not. I know within three or
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` 25 four people but I could not say which one in
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` 2 particular did all the work.
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` 3 Q. You didn't speak with anyone in
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` 4 particular about the preparation of the
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` 5 proceedings book in connection with this
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` 6 declaration?
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` 7 A. No.
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` 8 (Whereupon, Exhibit 3 was marked at
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` 9 this time.)
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` 10 Q. You've been handed what's marked as
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` 11 Exhibit 3.
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` 12 A. Uh huh.
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` 13 Q. Do you recognize this document?
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` 14 A. Yes.
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` 15 Q. What is it?
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` 16 A. It's the first declaration that I
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` 17 signed relating to the Morton Swimmer paper.
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` 18 Q. The second page of that document, is
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` 19 that your signature?
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` 20 A. Yes, it is.
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` 21 Q. And is that the same declaration
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` 22 that's included as Exhibit A to Exhibit 1 of this
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` 23 deposition?
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` 24 A. Yes, it is.
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` 25 Q. Okay. Thank you. I'm still going to
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` 1 - ROUGH - JOHN HAWES -
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` 2 direct your attention back to Exhibit 1, then in
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` 3 particular Paragraph 5?
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` 4 A. Okay.
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` 5 Q. You state in the first sentence that
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` 6 "A copy of the Swimmer paper including this
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` 7 Exhibit A is part of the conference proceedings
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` 8 book that was prepared by Virus Bulletin employees
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` 9 in 1995."
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` 10 Again, you did not attend the
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` 11 conference in 1995, correct?
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` 12 A. Correct.
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` 13 Q. You testified earlier that you have
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` 14 -- you did not speak with any of the employees
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` 15 that prepared the proceedings book for that 1995
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` 16 conference, correct?
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` 17 MR. EUTERMOSER: Objection
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` 18 mischaracterizes his testimony.
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` 19 A. I spoke to them. I did not question
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` 20 them about the preparation of the book.
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` 21 Q. So you testified earlier you did not
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` 22 speak with them in connection with your
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` 23 preparation of this declaration?
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` 24 MR. EUTERMOSER: Object to the form.
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` 25 A. I spoke to them in connection with
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` 1 - ROUGH - JOHN HAWES -
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` 2 the declaration because, as I said, I mentioned to
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` 3 them that I was being -- I had been asked to give
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` 4 a declaration.
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` 5 Q. Okay. But do you know exactly who
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` 6 the employees are who prepared the proceedings
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` 7 book for the 1995 conference?
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` 8 MR. EUTERMOSER: Object to the form.
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` 9 A. I know who the employees were at that
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` 10 time. I don't know which of them were involved in
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` 11 that particular. I can -- I would assume it would
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` 12 be the editor who did most of the work which is
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` 13 how it has been for at least for the last twelve
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` 14 years.
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` 15 Q. Then you also state at the end of the
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` 16 first sentence in Paragraph 5 of your declaration
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` 17 that "The proceedings book has been kept at Virus
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`Hawes ROUGH - 113016.txt
` 18 Bulletin's offices ever since."
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` 19 What do you mean by it's been kept at
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` 20 the offices?
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` 21 A. So after the conference is over, we
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` 22 bring home any spare copies of the book.
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` 23 We actually -- we tend to print 10 to
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` 24 20 percent over what we expect we will need
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` 25 because we want to have some available to -- for
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` 1 - ROUGH - JOHN HAWES -
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` 2 people that want them later. We take those copies
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` 3 home.
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` 4 We have a couple of master copies
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` 5 that we keep in our main office for reference and
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` 6 we keep the spares in storage in the same
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` 7 building.
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` 8 Q. Who monitors the storage, if anyone?
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` 9 MR. EUTERMOSER: Object to form.
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` 10 A. At the moment it would be my
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` 11 colleague, Allison Sketchly who who maintains all
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` 12 our archives.
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` 13 Q. How long has she been in that
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` 14 position?
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` 15 A. Around 10 years.
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` 16 Q. Do you know who held that position
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` 17 prior to her?
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` 18 A. Yes. Her name is Bernadette.
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` 19 Q. Did Bernadette oversee the storage of
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` 20 the records and the proceedings book during that
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` 21 time?
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` 22 A. Yes.
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`Hawes ROUGH - 113016.txt
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` 23 Q. Then at the end of the paragraph 5 of
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` 24 your declaration you reference "Virus Bulletin's
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` 25 regularly conducted business activity."
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` 20
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` 1 - ROUGH - JOHN HAWES -
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` 2 What do you mean?
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` 3 A. Well, we hold a conference every year
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` 4 and that produces the proceedings book every year
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` 5 so every year we take those books and we look
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` 6 after them.
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` 7 Q. Direct your attention to Paragraph 6
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` 8 of your declaration. You reference an Exhibit B?
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` 9 A. Uh-huh.
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` 10 Q. What is Exhibit B? It starts on Page
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` 11 21.
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` 12 A. Yes, it's a list of the attendees of
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` 13 the conference.
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` 14 Q. When did you retrieve this document?
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` 15 A. Shortly after the previous
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` 16 declaration.
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` 17 I was asked during the declaration
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` 18 who had attended the conference and I said I
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` 19 didn't know but I could find out and I was
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` 20 interested so I went and found out.
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` 21 Q. You stated you were asked during the
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` 22 declaration, did you mean you were asked during
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` 23 your deposition?
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`Page 18
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`Patent Owner Finjan, Inc. - Ex. 2042, p. 18
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`Hawes ROUGH - 113016.txt
` 24 A. Yes.
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` 25 Q. Were you directed later to then
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` 21
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` 1 - ROUGH - JOHN HAWES -
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` 2 retrieve th