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`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________
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`PALO ALTO NETWORKS, INC.,
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`Petitioner
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`v.
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`FINJAN, INC.,
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`Patent Owner
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`Patent No. 8,141,154
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`_______________
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`Inter Partes Review No. IPR2016-00151
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`____________________________________________________________
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`DECLARATION OF NATHAN HAMSTRA
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`Palo Alto Networks, Inc. Exhibit 1008 Page 1
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`1, Nathan Hamstra, declare as follows:
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`1.
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`My name is Nathan Hamstra.
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`I am an attorney at Quinn, Emanuel, Urquhart
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`& Sullivan LLP.
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`I am counsel of record for Symantec Corporation in Finjan, Inc.
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`v. Symantec C0rp., Case No. 14—cv—02998-HSG (N.D. Cal.) (the “Symantec
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`litigation”). I am also counsel of record for co—petitioner Symantec in this
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`proceeding.
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`2.
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`On December 4, 2014, Finjan served its OBJECTIONS AND RESPONSES
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`TO DEFENDANT SYMANTEC CORP.’S FIRST SET OF INTERROGATORIES
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`(NOS. 1-11) in the Symantec litigation. EX. 1006 is a true and correct excerpt of
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`that that document showing Finjan’s response to Symantec’s Interrogatory No. 1.
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`At page 8, it states “The date of conception for the asserted claims of U.S. Patent
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`No. 8,141,154 (‘the ‘l54 Patent’) is December 12, 2005.”
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`3.
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`On April 13, 2015, Finjan served its SUPPLEMENTAL RESPONSES TO
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`DEFENDANT SYMANTEC CORP.’S FIRST SET OF INTERROGATORIES
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`(NOS. 1, 5-11) in the Symantec litigation. EX. 1007 is a true and correct excerpt of
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`that document showing Finj an’s supplemental response to Symantec’s
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`Interrogatory No. 1. At page 4, it states “The date of conception for the asserted
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`claims of U.S. Patent No. 8,141,154 (‘the ‘l54 Patent’) is December 12, 2005.”
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`Palo Alto Networks, Inc.
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`Exhibit 1008
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`Page 2
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`Palo Alto Networks, Inc. Exhibit 1008 Page 2
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`4.
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`At the time both of the foregoing documents were served, Finj an’s then-
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`operative infringement contentions, served December 4, 2014, asserted
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`infringement of claims 1-12 of the ‘ 154 patent.
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`5.
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`Both of the foregoing documents were signed by Mr. James Hannah, who is
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`also Finjan’s counsel of record in this IPR2016—00151.
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`6.
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`Although Finjan served another supplemental response to Symantec’s
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`Interrogatory No. 1 on December 2, 2016, Finjan never corrected its earlier-served
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`responses to Symantec’s Interrogatory No. 1. See Fed. R. Civ. P. 26(e)(1) (“A
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`party who has made a disclosure under Rule 26(a)—or who has responded to an
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`interrogatory, request for production, or request for admission—must supplement
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`or correct its disclosure or response (emphasis added).)
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`7.
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`I declare under penalty of perjury under the laws of the United States of
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`America that the statements made herein are believed to be true based upon either
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`my personal knowledge or to the best of my knowledge, information, and belief.
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`Date: December 6, 2016
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`“lug
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`Nathan Hamstra
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`Palo Alto Networks, Inc.
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`Exhibit 1008
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`Page 3
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`Palo Alto Networks, Inc. Exhibit 1008 Page 3
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