`
`1:2 BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` _________________________________________
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`1:3
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` PALO ALTO NETWORKS, INC.,
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`1:4
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` Petitioner,
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`1:5
`
` -against-
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`1:6
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` FINJAN, INC.,
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`1:7
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` Patent Owner.
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`1:8
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` Patent No. 8,141,154
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`1:9
`
` Inter Partes Review No. IPR2016-00151
`
`1:10 _________________________________________
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`1:11
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` November 10, 2016
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`1:12 7:59 a.m.
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`1:13
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`1:14 *** HIGHLY CONFIDENTIAL ***
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`1:15
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`1:16 DEPOSITION of YUVAL
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`1:17 BEN-ITZHAK, taken by Petitioner,
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`1:18 pursuant to Notice, held at the offices
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`1:19 of KRAMER, LEVIN, NAFTALIS & FRANKEL
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`1:20 LLP, 1177 Avenue of the Americas, New
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`1:21 York, New York before Wayne Hock, a
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`1:22 Notary Public of the State of New York.
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`1:23
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`1:24
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`1:25
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`Palo Alto Networks, Inc. Exhibit 1009 Page 1
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`2:1 A P P E A R A N C E S:
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`2:2
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` MORRISON & FOERSTER LLP
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`2:3 Attorneys for Petitioner
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` 1650 Tysons Boulevard
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`2:4 McLean, Virginia 22102
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`2:5
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` BY: SHOUVIK BISWAS, ESQ.
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`2:6 sbiswas@mofo.com
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`2:7
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`2:8 KRAMER, LEVIN, NAFTALIS & FRANKEL LLP
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` Attorneys for Patent Owner
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`2:9 1177 Avenue of the Americas
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` New York, New York 10036
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`2:10
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` BY: AARON FRANKEL, ESQ.
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`2:11 afrankel@kramerlevin.com
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`2:12
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` ALSO PRESENT:
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`2:13
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`2:14 MICHAEL KIM
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` (via teleconference)
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`2:15
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` * * *
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`2:16
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`2:17
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`2:18
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`2:19
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`2:20
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`2:21
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`2:22
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`2:23
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`2:24
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`2:25
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`Palo Alto Networks, Inc. Exhibit 1009 Page 2
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`3:1
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`3:2 * * *
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`3:3
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`3:4 I N D E X
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`3:5 WITNESS EXAMINED BY PAGE
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`3:6 Y. Ben-Itzhak Mr. Biswas 4
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`3:7 Mr. Frankel 21
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`3:8
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`3:9 E X H I B I T S
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`3:10 FOR ID DESCRIPTION PAGE
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`3:11 Exhibit 1 Document entitled
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`3:12 Declaration of Yuval
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`3:13 Ben-Itzhak 9
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`3:14 Exhibit 2 E-mail dated
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`3:15 December 6, 2005 11
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`3:16
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`3:17
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`3:18 * * *
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`3:19
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`3:20
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`3:21
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`3:22
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`3:23
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`3:24
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`3:25
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`Palo Alto Networks, Inc. Exhibit 1009 Page 3
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`4:1 Y U V A L B E N - I T Z H A K, having
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`4:2 been first duly sworn by a
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`4:3 Notary Public of the State of
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`4:4 New York, upon being examined,
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`4:5 testified as follows:
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`4:6 EXAMINATION BY
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`4:7 MR. BISWAS:
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`4:8 Q. What is your current address?
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`4:9 A. Malydvur 820, Nebusice,
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`4:10 Prague, Czech Republic.
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`4:11 Q. Mr. Ben-Itzhak, could you
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`4:12 please state your full name for the
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`4:13 record.
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`4:14 A. My name is Yuval Ben-Itzhak.
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`4:15 Q. And do you understand why you
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`4:16 are here today?
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`4:17 A. You can explain to me and
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`4:18 I'll tell you if that's my
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`4:19 understanding.
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`4:20 Q. Sure.
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`4:21 You are here in reference to
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`4:22 your deposition that you provided in
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`4:23 IPR 2016-00151.
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`4:24 Is that your understanding?
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`4:25 A. My understanding I'm here for
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`Palo Alto Networks, Inc. Exhibit 1009 Page 4
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`
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`5:1 deposition based on my statement that I
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`5:2 signed, yes.
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`5:3 Q. Sure, sure.
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`5:4 Now, Mr. Ben-Itzhak, could
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`5:5 you describe to me your role with
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`5:6 Finjan with reference to the time
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`5:7 period in question, which is 2005?
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`5:8 A. I was the chief technology
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`5:9 officer of Finjan in 2005.
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`5:10 Q. And as chief technology
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`5:11 officer, what were your duties?
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`5:12 A. As a chief technology
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`5:13 officer, I was responsible for the
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`5:14 research team. They were doing malware
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`5:15 research; used to call malicious code
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`5:16 research center. I was responsible for
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`5:17 the technology of the company, the
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`5:18 development of the technology of the
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`5:19 company. I was responsible for some of
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`5:20 the work with analysts and markets,
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`5:21 press, and stuff like that.
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`5:22 Q. Can you describe your role in
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`5:23 terms of Finjan's work in developing
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`5:24 its IP portfolio?
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`5:25 MR. FRANKEL: Objection to
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`Palo Alto Networks, Inc. Exhibit 1009 Page 5
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`
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`6:1 form.
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`6:2 THE WITNESS: So I'm not a
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`6:3 lawyer, I'm not dealing with the
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`6:4 legal aspect of that, I'm a
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`6:5 technology person. And as I
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`6:6 mentioned earlier, part of my
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`6:7 responsibility was to develop the
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`6:8 technologies, identify needs that
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`6:9 we have, and find solutions using
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`6:10 technology and that's what I did
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`6:11 with my group.
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`6:12 Q. And in your role as you
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`6:13 described, did you work with others to
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`6:14 develop and write patent applications?
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`6:15 A. So I work with my team to
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`6:16 develop technologies and then we work
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`6:17 with external resources to draft
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`6:18 documents and write documents, that's
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`6:19 the legal process of it, that's the
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`6:20 two.
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`6:21 MR. FRANKEL: It's been fine
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`6:22 so far, but sometimes you're
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`6:23 jumping in a little before the
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`6:24 witness is finished answering.
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`6:25 Give him a little more time.
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`Palo Alto Networks, Inc. Exhibit 1009 Page 6
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`7:1 MR. BISWAS: Sure, no problem.
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`7:2 Q. When you said people with
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`7:3 external roles, could you expound on
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`7:4 that a little more, describe that?
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`7:5 MR. FRANKEL: Objection to
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`7:6 form.
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`7:7 THE WITNESS: The company
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`7:8 worked with different legal teams.
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`7:9 When I joined, there were I think
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`7:10 two, one called Eitan group and the
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`7:11 other one was -- at least the
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`7:12 person I used to work more
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`7:13 frequently, his name is Marc
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`7:14 Berger. And every time we had some
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`7:15 enhancement in technology or new
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`7:16 ideas in technology, we used to
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`7:17 speak with them and share with them
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`7:18 and then they did the work and file
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`7:19 the patents. That's how Finjan
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`7:20 used to work for several years.
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`7:21 Q. And is Mr. Berger, does he
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`7:22 belong to the Eitan law group?
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`7:23 A. As far as I recall, he was an
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`7:24 independent person. Maybe they had
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`7:25 some -- I don't know. I mean, I know
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`Palo Alto Networks, Inc. Exhibit 1009 Page 7
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`
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`8:1 that I worked with him as part of
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`8:2 Finjan. I do not know or I do not
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`8:3 recall if he was an employee of the
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`8:4 Eitan group, if that's your question,
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`8:5 so I do not know.
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`8:6 Q. So my understanding then is
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`8:7 Finjan did not hire Mr. Berger itself?
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`8:8 MR. FRANKEL: Objection to
`
`8:9 form.
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`8:10 THE WITNESS: What do you
`
`8:11 mean by the word "hire?"
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`8:12 Q. Was Mr. Berger an employee of
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`8:13 Finjan?
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`8:14 A. I do not remember what was
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`8:15 the exact terms. He was working with
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`8:16 Finjan before I joined the company, so
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`8:17 I wasn't involved in whatever business
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`8:18 arrangement was between Mr. Berger and
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`8:19 Finjan. It wasn't my responsibility.
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`8:20 MR. FRANKEL: Once again, just
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`8:21 please give him a minute to
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`8:22 complete his answer. Thank you.
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`8:23 MR. BISWAS: Now I'm going to
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`8:24 go ahead and enter some documents
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`8:25 into the record.
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`Palo Alto Networks, Inc. Exhibit 1009 Page 8
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`
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`9:1 We'll start here with this.
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`9:2 (Whereupon, a document entitled
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`9:3 Declaration of Yuval Ben-Itzhak
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`9:4 was marked Exhibit 1
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`9:5 for identification.)
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`9:6 Q. Mr. Ben-Itzhak, I've provided
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`9:7 you with a copy of your declaration
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`9:8 marked Exhibit 1, for the record.
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`9:9 Can you describe to me the
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`9:10 process that you undertook in writing
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`9:11 this declaration?
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`9:12 MR. FRANKEL: I'm going to
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`9:13 instruct the witness not to reveal
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`9:14 -- you can answer that question but
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`9:15 in doing so do not disclose
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`9:16 communications that you had with
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`9:17 counsel.
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`9:18 THE WITNESS: So I had
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`9:19 conversation with counsel and I
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`9:20 cannot answer it.
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`9:21 Q. Can you -- could you tell me
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`9:22 who you worked with in preparing this
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`9:23 declaration?
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`9:24 MR. FRANKEL: You can answer
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`9:25 that by giving names but not the
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`Palo Alto Networks, Inc. Exhibit 1009 Page 9
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`
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`10:1 substance of discussions.
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`10:2 THE WITNESS: I worked with a
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`10:3 Kramer Levin team about that.
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`10:4 Q. Do you know the names of the
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`10:5 individuals that you worked with from
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`10:6 the Kramer Levin team?
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`10:7 A. I believe it was James
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`10:8 Hannah. Maybe there were others. I
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`10:9 just don't recall.
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`10:10 Q. Can you describe how you
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`10:11 became involved with this particular
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`10:12 IPR?
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`10:13 MR. FRANKEL: Objection to
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`10:14 form. Same instruction regarding
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`10:15 attorney-client discussions.
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`10:16 THE WITNESS: I was contacted
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`10:17 regarding the patents I'm listed
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`10:18 inventor on and I was asked to
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`10:19 respond to questions and that's why
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`10:20 I'm here. It's not something I
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`10:21 initiated or pushed for. I was
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`10:22 asked to come. That's what I'm
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`10:23 doing.
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`10:24 Q. Does this declaration
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`10:25 represent the entirety of your opinion
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`Palo Alto Networks, Inc. Exhibit 1009 Page 10
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`
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`11:1 regarding the priority date of the '154
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`11:2 patent?
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`11:3 MR. FRANKEL: Objection to
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`11:4 form.
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`11:5 THE WITNESS: I do not know
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`11:6 what the terms priority dates and
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`11:7 all those legal terminology. This
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`11:8 is my statement. That's what I
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`11:9 signed. And the way you understand
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`11:10 it, that's how I wrote it.
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`11:11 MR. BISWAS: Also, I'd like to
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`11:12 enter one more document on the
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`11:13 record here. We'll call this
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`11:14 Exhibit Number 2.
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`11:15 (Whereupon, an e-mail dated
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`11:16 December 6, 2005 was marked Exhibit 2
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`11:17 for identification.)
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`11:18 Q. So Mr. Ben-Itzhak, I've
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`11:19 provided you now with two documents,
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`11:20 Exhibit 1 which is a copy of your
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`11:21 declaration and Exhibit 2 which in the
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`11:22 IPR is referred to as Exhibit 2007
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`11:23 which is a copy of an alleged e-mail
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`11:24 chain between yourself and Mr. Marc
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`11:25 Berger.
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`Palo Alto Networks, Inc. Exhibit 1009 Page 11
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`
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`12:1 Other than these two
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`12:2 documents, have you prepared for this
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`12:3 deposition using other resources?
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`12:4 MR. FRANKEL: Objection to
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`12:5 form.
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`12:6 You can answer that question
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`12:7 yes or no but do not disclose the
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`12:8 substance of discussions you've had
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`12:9 with counsel.
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`12:10 THE WITNESS: I reviewed the
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`12:11 documents. I had discussions with
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`12:12 counsel.
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`12:13 Q. And when you say you reviewed
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`12:14 the documents, are you referring to the
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`12:15 documents that you had before you,
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`12:16 Exhibits 1 and 2, or are you referring
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`12:17 to other documents as well?
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`12:18 MR. FRANKEL: Objection to
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`12:19 form. Same instruction.
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`12:20 THE WITNESS: As I recall,
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`12:21 these were the documents.
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`12:22 Q. Referring to Exhibit 2, as
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`12:23 you can see, large parts of the
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`12:24 document are blacked out.
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`12:25 A. I see that.
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`Palo Alto Networks, Inc. Exhibit 1009 Page 12
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`13:1 Q. Do you know why they've been
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`13:2 blacked out?
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`13:3 MR. FRANKEL: Objection to
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`13:4 form. Same caution regarding
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`13:5 attorney-client privilege.
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`13:6 You can answer that yes or
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`13:7 no.
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`13:8 THE WITNESS: I do not know.
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`13:9 Q. Do you know -- can you tell
`
`13:10 me what the contents under the
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`13:11 redaction are or what they state
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`13:12 generally?
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`13:13 A. No.
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`13:14 Q. So referring to page one of
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`13:15 the Exhibit 2, it appears to be an
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`13:16 e-mail that took place on December 6,
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`13:17 2005 between yourself and Marc Berger;
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`13:18 is that correct? Is that your
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`13:19 understanding as well?
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`13:20 A. Yeah, I see my name on the
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`13:21 top of the document and Marc Berger's
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`13:22 name and it looks like an e-mail.
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`13:23 Q. And underneath in the
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`13:24 beginning you see where it says
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`13:25 contents? Comments, I'm sorry.
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`Palo Alto Networks, Inc. Exhibit 1009 Page 13
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`
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`14:1 A. Yes, I see the word
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`14:2 "comments."
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`14:3 Q. Can you describe to me what
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`14:4 those comments were?
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`14:5 MR. FRANKEL: I'm sorry,
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`14:6 counsel, this is a document on its
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`14:7 face that says attorney-client
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`14:8 privilege and this material is
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`14:9 redacted. Finjan has asserted
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`14:10 privilege. On that basis, I'm
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`14:11 instructing the witness not to
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`14:12 answer that question.
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`14:13 Q. I'd like to now turn to
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`14:14 Exhibit 1 which is your declaration and
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`14:15 specifically I'd like to turn to
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`14:16 paragraph seven which appears on the
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`14:17 document page three.
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`14:18 A. Okay.
`
`14:19 Q. I want to point to the second
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`14:20 sentence, I want to draw your attention
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`14:21 to the second sentence which says, "for
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`14:22 example, on November 13, I e-mailed Dr.
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`14:23 Berger regarding the patent
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`14:24 application."
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`14:25 How were you able to
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`Palo Alto Networks, Inc. Exhibit 1009 Page 14
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`
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`15:1 determine that you e-mailed Dr. Berger
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`15:2 on November 13?
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`15:3 A. On Exhibit 2, page two at the
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`15:4 top you can see the date is Sunday,
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`15:5 November 13, 2005.
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`15:6 Q. So when you testified that
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`15:7 you e-mailed him on November 13, 2005,
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`15:8 you're relying on this chain of e-mails
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`15:9 provided in Exhibit 2?
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`15:10 MR. FRANKEL: Objection to
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`15:11 form.
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`15:12 THE WITNESS: I believe so.
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`15:13 Q. I'd like to point to the line
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`15:14 where you say, "Dr. Berger responded on
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`15:15 December 6, 2005 via e-mail regarding
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`15:16 the application."
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`15:17 Do you see what I'm speaking
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`15:18 about?
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`15:19 A. Yes, I do.
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`15:20 Q. And is your recollection of
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`15:21 when that e-mail took place based
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`15:22 entirely on Exhibit 2 and the e-mail
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`15:23 chain provided?
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`15:24 MR. FRANKEL: Objection to
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`15:25 form.
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`Palo Alto Networks, Inc. Exhibit 1009 Page 15
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`16:1 THE WITNESS: I can read on
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`16:2 Exhibit 2, page one the date
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`16:3 Tuesday, December 6, 2005, yes.
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`16:4 Q. But in testifying that he
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`16:5 responded on December 6, are you
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`16:6 relying on this exhibit, Exhibit 2?
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`16:7 A. Yes, I am relying on
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`16:8 Exhibit 2.
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`16:9 Q. I'd also like to draw your
`
`16:10 attention to the line where you state,
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`16:11 "we also had several phone
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`16:12 conversations between November 13, 2005
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`16:13 and December 12, 2005 regarding the
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`16:14 patent application."
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`16:15 Can you tell me precisely how
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`16:16 many phone conversations you had?
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`16:17 A. The way I worked with Mr.
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`16:18 Berger was having conversations,
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`16:19 multiple conversations. Exactly how
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`16:20 many I do not recall.
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`16:21 Q. Do you recall precisely what
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`16:22 dates those phone calls took place?
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`16:23 A. Between Sunday to Thursday.
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`16:24 Q. November 13, 2005 to
`
`16:25 December 12, 2005 is a monthlong
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`Palo Alto Networks, Inc. Exhibit 1009 Page 16
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`
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`17:1 period.
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`17:2 Just to explain, you're
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`17:3 saying you only had conversations
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`17:4 between Monday and Thursday, but do you
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`17:5 know precisely what days?
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`17:6 A. Between Sunday and Thursday
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`17:7 because these are the working days in
`
`17:8 Israel. These are working days and
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`17:9 that's when I used to speak with Mr.
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`17:10 Berger.
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`17:11 Q. Did you speak with Mr. Berger
`
`17:12 on November 13 regarding -- on the
`
`17:13 phone regarding this application?
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`17:14 A. I'm using Exhibit 2 and the
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`17:15 e-mail -- and the information on the
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`17:16 e-mail chain. I don't have exact time
`
`17:17 of speaking over the phone with Mr.
`
`17:18 Berger. But our common work was we had
`
`17:19 conversations over the phone.
`
`17:20 Q. I understand that you
`
`17:21 e-mailed Mr. Berger on November 13, but
`
`17:22 do you recall if you spoke with him
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`17:23 over the phone regarding the patent
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`17:24 application on that day?
`
`17:25 MR. FRANKEL: Objection to
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`Palo Alto Networks, Inc. Exhibit 1009 Page 17
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`
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`18:1 form.
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`18:2 THE WITNESS: It is likely
`
`18:3 but I do not remember the exact
`
`18:4 time that I spoke to him.
`
`18:5 Q. Do you remember any exact
`
`18:6 dates on when you talked to Mr. Berger
`
`18:7 regarding this patent application?
`
`18:8 A. I do not recall exact time
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`18:9 and date. As I mentioned earlier, our
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`18:10 practice was that we exchanged some
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`18:11 information and had conversation over
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`18:12 the phone or sometimes we met in
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`18:13 person, so I don't remember the exact
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`18:14 interaction since this is like eleven
`
`18:15 years ago, but that's the way we used
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`18:16 to work.
`
`18:17 Q. When you say that you met in
`
`18:18 person with Mr. Berger, do you recall
`
`18:19 the dates of when you met him in person
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`18:20 regarding this patent application?
`
`18:21 A. I do not remember exact date.
`
`18:22 I repeat again, that was the common
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`18:23 practice, that we worked on multiple
`
`18:24 applications.
`
`18:25 Q. When you say that you worked
`
`Palo Alto Networks, Inc. Exhibit 1009 Page 18
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`
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`19:1 on multiple applications, are you
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`19:2 specifically referring to drafting
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`19:3 patent applications or did you also
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`19:4 work with him regarding office actions?
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`19:5 MR. FRANKEL: Objection to
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`19:6 form.
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`19:7 THE WITNESS: I do not recall
`
`19:8 what office action is.
`
`19:9 Q. Did you work with him on any
`
`19:10 responses to rejections by the U.S.
`
`19:11 patent office?
`
`19:12 MR. FRANKEL: I'm going to
`
`19:13 instruct the witness to answer that
`
`19:14 yes or no but not to disclose the
`
`19:15 substance of discussions with Dr.
`
`19:16 Berger.
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`19:17 THE WITNESS: So he used to
`
`19:18 contact me with different questions
`
`19:19 he received during the filing and
`
`19:20 we were having conversations about
`
`19:21 whatever was the question and how
`
`19:22 can we want to answer it. If it
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`19:23 was the result of something, I
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`19:24 don't recall exactly every question
`
`19:25 he asked, but that's the regular
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`Palo Alto Networks, Inc. Exhibit 1009 Page 19
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`
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`20:1 conversation we used to have.
`
`20:2 Q. Mr. Ben-Itzhak, is there any
`
`20:3 reason, either physical, mental, or
`
`20:4 emotional, that prevented you from
`
`20:5 giving your best and most accurate
`
`20:6 testimony today?
`
`20:7 A. Not that I know.
`
`20:8 Q. Are you on any type of
`
`20:9 medication or drugs that made it
`
`20:10 difficult for you to understand my
`
`20:11 questions and truthfully and accurately
`
`20:12 answer them?
`
`20:13 A. Not that I know.
`
`20:14 MR. BISWAS: I thank you for
`
`20:15 your time, sir. I have no further
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`20:16 questions.
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`20:17 THE WITNESS: Thank you very
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`20:18 much.
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`20:19 MR. FRANKEL: Let's take a
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`20:20 short break. I'm going to confer
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`20:21 with my colleague and we'll see if
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`20:22 we have some re-direct.
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`20:23 (Whereupon a break was taken)
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`20:24 (CONTINUED ON NEXT PAGE)
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`20:25
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`Palo Alto Networks, Inc. Exhibit 1009 Page 20
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`
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`21:1 EXAMINATION BY
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`21:2 MR. FRANKEL:
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`21:3 Q. Mr. Ben-Itzhak, I'd like to
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`21:4 direct your attention to Exhibit 2.
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`21:5 And there are some e-mails with dates
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`21:6 on it in Exhibit 2.
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`21:7 A. Right.
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`21:8 Q. Are the dates on those
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`21:9 e-mails consistent with your
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`21:10 recollection of the work you did with
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`21:11 Dr. Berger on the application that
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`21:12 eventually grew into the '154 patent?
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`21:13 MR. BISWAS: Objection. Out
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`21:14 of scope. Objection, leading the
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`21:15 witness.
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`21:16 THE WITNESS: The dates I'm
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`21:17 seeing on these e-mails are about
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`21:18 the time I used to work with Mr.
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`21:19 Berger before he filed the
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`21:20 application.
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`21:21 Q. And if you direct your
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`21:22 attention on the second page, there's
`
`21:23 an e-mail that says FYI which appears
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`21:24 to be -- is that consistent with you
`
`21:25 having a telephone conversation with
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`Palo Alto Networks, Inc. Exhibit 1009 Page 21
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`
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`22:1 Dr. Berger?
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`22:2 MR. BISWAS: Objection. Out
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`22:3 of the scope.
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`22:4 THE WITNESS: So usually I'm
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`22:5 sending e-mail with FYI, which
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`22:6 stands for for your information, if
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`22:7 there was a reminder or if we're
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`22:8 having a conversation and I want to
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`22:9 send -- someone missed something
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`22:10 and I want to bring it to the top
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`22:11 of their inbox.
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`22:12 Q. And based on your
`
`22:13 recollection from the time you sent
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`22:14 that first draft to Dr. Berger until
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`22:15 the patent application was filed, did
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`22:16 it require significant effort to
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`22:17 complete that application?
`
`22:18 MR. BISWAS: Objection. Out
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`22:19 of scope.
`
`22:20 THE WITNESS: Mr. Berger is a
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`22:21 very hardworking person and he
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`22:22 worked quite a lot to draft it
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`22:23 quickly and that was one of the
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`22:24 reasons I liked to work with him,
`
`22:25 because he was very eager to do
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`Palo Alto Networks, Inc. Exhibit 1009 Page 22
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`
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`23:1 things, do it fast, and do quite
`
`23:2 good work.
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`23:3 MR. FRANKEL: No further
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`23:4 questions.
`
`23:5 THE WITNESS: Thank you.
`
`23:6 MR. BISWAS: And I have no
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`23:7 further questions either.
`
`23:8 (Discussion held off the
`
`23:9 record)
`
`23:10 MR. FRANKEL: We're back on
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`23:11 the record.
`
`23:12 Just to note that Finjan is
`
`23:13 designating this transcript highly
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`23:14 confidential.
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`23:15 (TIME NOTED: 8:24 a.m.)
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`23:16
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`23:17
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`23:18
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`23:19
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`23:20
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`23:21
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`23:22
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`23:23
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`23:24
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`23:25
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`Palo Alto Networks, Inc. Exhibit 1009 Page 23
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`24:1 CERTIFICATION BY REPORTER
`
`24:2 I, Wayne Hock, a Notary Public of the
`
`24:3 State of New York, do hereby certify:
`
`24:4 That the testimony in the within
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`24:5 proceeding was held before me at the
`
`24:6 aforesaid time and place;
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`24:7 That said witness was duly sworn
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`24:8 before the commencement of the testimony,
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`24:9 and that the testimony was taken
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`24:10 stenographically by me, then transcribed
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`24:11 under my supervision, and that the within
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`24:12 transcript is a true record of the
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`24:13 testimony of said witness.
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`24:14 I further certify that I am not
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`24:15 related to any of the parties to this
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`24:16 action by blood or marriage, that I am not
`
`24:17 interested directly or indirectly in the
`
`24:18 matter in controversy, nor am I in the
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`24:19 employ of any of the counsel.
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`24:20 IN WITNESS WHEREOF, I have hereunto
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`24:21 set my hand this 10th day of
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`24:22 November, 2016.
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`24:23
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`24:24 <%signature%>
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`24:25
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`Palo Alto Networks, Inc. Exhibit 1009 Page 24
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`[& - conversation]
`
`&
`& 1:19 2:2,8
`1
`1 3:11 9:4,8 11:20
`12:16 14:14
`10 1:11
`10036 2:9
`10th 24:21
`11 3:15
`1177 1:20 2:9
`12 16:13,25
`13 14:22 15:2,5,7
`16:12,24 17:12,21
`154 11:1 21:12
`1650 2:3
`2
`2 3:14 11:14,16,21
`12:16,22 13:15
`15:3,9,22 16:2,6,8
`17:14 21:4,6
`2005 3:15 5:7,9
`11:16 13:17 15:5
`15:7,15 16:3,12,13
`16:24,25
`2007 11:22
`2016 1:11 24:22
`2016-00151 4:23
`21 3:7
`22102 2:4
`4
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`4 3:6
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`6
`6 3:15 11:16 13:16
`15:15 16:3,5
`7
`7:59 1:12
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`8
`8,141,154 1:8
`820 4:9
`8:24 23:15
`9
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`9 3:13
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`a
`a.m. 1:12 23:15
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`20:12
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`14:16 21:23
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`19:25
`
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`16:10 21:4,22
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`13:5 14:7
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`b 3:9 4:1
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`22:12
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`11:18 20:2 21:3
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`8:12,18 11:25
`13:17 14:23 15:1
`15:14 16:18 17:10
`17:11,18,21 18:6
`18:18 19:16 21:11
`21:19 22:1,14,20
`berger's 13:21
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`7:1 8:23 11:11
`20:14 21:13 22:2
`22:18 23:6
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`13:2
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`
`business 8:17
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`
`c 2:1
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`15:23 17:16
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`14:7
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`24:8
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`9:16
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`22:17
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`23:14
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`contents 13:10,25
`continued 20:24
`controversy 24:18
`conversation 9:19
`18:11 20:1 21:25
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`Page 1
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`Palo Alto Networks, Inc. Exhibit 1009 Page 25
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`
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`[conversation - hannah]
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`22:8
`conversations
`16:12,16,18,19
`17:3,19 19:20
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`counsel 9:17,19
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`24:19
`current 4:8
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`d
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`d 3:4
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`12:21
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`22:22
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`e
`e 2:1,1 3:4,9,14 4:1
`11:15,23 13:16,22
`14:22 15:1,7,8,15
`15:21,22 17:15,16
`17:21 21:5,9,17,23
`22:5
`eager 22:25
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`19:24
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`21:1
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`9:8 11:14,16,20,21
`11:22 12:22 13:15
`14:14 15:3,9,22
`16:2,6,6,8 17:14
`21:4,6
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`f
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`finjan 1:6 5:6,9
`7:19 8:2,7,13,16
`8:19 14:9 23:12
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`10:14 11:4 12:5
`12:19 13:4 15:11
`15:25 18:1 19:6
`frankel 1:19 2:8
`2:10 3:7 5:25 6:21
`7:5 8:8,20 9:12,24
`10:13 11:3 12:4
`12:18 13:3 14:5
`15:10,24 17:25
`19:5,12 20:19
`21:2 23:3,10
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`23:7 24:14
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`g
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`group 6:11 7:10
`7:22 8:4
`h
`h 3:9 4:1
`hand 24:21
`hannah 10:8
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`Page 2
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`Palo Alto Networks, Inc. Exhibit 1009 Page 26
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`
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`[hardworking - patent]
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`hardworking
`22:21
`held 1:18 23:8
`24:5
`hereunto 24:20
`highly 1:14 23:13
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`i
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`10:11
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`11:22
`ipr2016-00151 1:9
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`4:11,14 5:4 9:3,6
`11:18 20:2 21:3
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`j
`james 10:7
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`k
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`k 4:1
`kim 2:14
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`8:5 10:4 11:5 13:1
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`kramer 1:19 2:8
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`kramerlevin.com
`2:11
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`l
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`p 2:1,1
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