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