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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`Palo Alto Networks, Inc. and
`Blue Coat Systems, Inc.,
`Petitioners
`
`v.
`
`Finjan, Inc.
`Patent Owner
`
`Case IPR2016-001591
`Patent No. 8,677,494
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`
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`PETITIONER’S RESPONSE TO PATENT OWNER’S
`IDENTIFICATION OF ARGUMENTS
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`1 Case IPR2016-01174 has been joined with the instant proceeding.
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`Petitioner’s Response to Patent Owner’s
`Identification of Arguments
`IPR2016-00159
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`Pursuant to the Board’s December 13, 2016 Order (Paper 29), Petitioner
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`identifies the following portions of (1) Patent Owner’s Response (Paper 17), to
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`which Petitioner’s Reply arguments (Paper 26 or “Reply”) respond; and/or (2) the
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`Petition (Paper 2), which support Petitioner’s Reply arguments:
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`
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`PAPER 32
`1. Reply at pg. 3,
`line 17 – pg. 4,
`line 9, and
`Exs. 1095-1097
`2. Reply at pg. 9,
`lines 14-20, and
`Exs. 1093-10942
`
`3. Reply at pg.
`10, lines 1-9 and
`Ex. 1091
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`4. Reply at pg. 10,
`lines 15-19
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`5. Reply at pg. 11,
`lines 6-13
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`PETITIONER’S RESPONSE
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`Responsive to: Paper 17 (“PO Response”) at 12:19 – 14:8.
`Supported by: Paper 2 (“Petition”) at 6:11 – 7:1 (citing ex. 1088).
`
`Responsive to: PO Response at 22:2-11.
`Supported by: Petition at 44:18 – 46:7.
`Responsive to: PO Response at 19:7 – 20:5; 21:5 – 22:12; 23:8-21.
`Supported by: Petition at 45:14 – 46:7; Exhibit 1091 corresponds to
`a document cited in Patent Owner’s Exhibit 2027 at pg. 2 (citing
`“New Toy in the Avast Research Lab (2012)
`
`<http://blog.avast.com/2012/12/03/new‐toy‐research‐lab/>”) and in
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`PO Response at pgs. 56, 57, 60 (citing Exhibit 2027).
`Responsive to: PO Response at 18:7 – 21:4; 22:7-11; 23:16-21;
`24:8-13.
`Supported by: Petition at 53:9-12; 44:18 – 46:7.
`Responsive to: PO Response at 18:7 – 21:4; 22:7-11; 23:16-21;
`24:8-13.
`Supported by: Petition at 53:9-12; 44:18 – 46:7.
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`2 Patent Owner identified Exhibit 1095 at #2 (Paper 32); however, Petitioner
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`believes this was in error and that Patent Owner meant to identify Exhibit 1094 at
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`#2. Exhibits 1094 and 1095 are both addressed by Petitioner at #1 and #2.
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`1
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`Petitioner’s Response to Patent Owner’s
`Identification of Arguments
`IPR2016-00159
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`PAPER 32
`6. Reply at pg. 11,
`line 14 – pg. 12,
`line 13
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`7. Reply at pg. 15,
`lines 6-12
`
`8. Reply at pg. 17,
`lines 9-15
`9. Reply at pg. 22,
`line 9 – pg. 25,
`line 20
`10a. Ex. 1089
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`10b. Ex. 1090
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`10c. Ex. 1091
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`PETITIONER’S RESPONSE
`Responsive to: PO Response at 18:7 – 21:4; 22:7-11; 23:16-21;
`24:8-13.
`Supported by: Petition at 53:9-12; 44:18 – 46:7.
`Responsive to: PO Response at 40:3 – 41:3.
`Supported by: Petition at 26:8-14; pg. 42, right column, ¶ 4; 44:15-
`17; 47:8-11; 48:19-20.
`Responsive to: PO Response at 16:15 – 17:14.
`
`Responsive to: PO Response, Section VII (pages 54-63).
`Supported by: Petition at pgs. 54-55.
`Responsive to: Paper 17 (“PO Response”) at 8:3-11.
`Supported by: Petition at 6:11-20; Ex. 1099 at ¶¶ 3-4.
`Responsive to: PO Response at 14:15-17.
`Supported by: Petition at 7:7-17; Ex. 1002 at ¶ 58.
`See #3, supra.
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`10d. Ex. 1092
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`Responsive to: PO Response at 18:10 – 21:4; 24:1 – 26:7.
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`10e. Ex. 1093
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`See #2, supra.
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`10f. Ex. 1094
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`See #2, supra.
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`10g. Ex. 1095
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`See #1 and #2, supra.
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`10h. Ex. 1096
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`See #1, supra.
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`10i. Ex. 1097
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`See #1, supra.
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`2
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`Petitioner’s Response to Patent Owner’s
`Identification of Arguments
`IPR2016-00159
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`Dated: January 24, 2017
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`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave., NW, Suite 700
`Washington, DC 20004
`Tel: (703) 456-8000
`Fax: (202) 842-7899
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`
`
`
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`Respectfully submitted,
`COOLEY LLP
`
`/Orion Armon/
`Orion Armon
`Reg. No. 65,421
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`
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`By:
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`3
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`Petitioner’s Response to Patent Owner’s
`Identification of Arguments
`IPR2016-00159
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on January 24,
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`2017, a complete and entire copy of this PETITIONER’S RESPONSE TO
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`PATENT OWNER’S IDENTIFICATION OF ARGUMENTS was served by
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`filing this document through the E2E System and via electronic mail upon the
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`Jeffrey H. Price
`KRAMER LEVIN NAFTALIS &
`FRANKEL LLP
`1177 Avenue of the Americas
`New York, NY 10036
`Phone: (212) 715-7502
`Fax: (212) 715-8302
`jprice@kramerlevin.com
`
`Michael T. Rosato
`Andrew S. Brown
`WILSON SONSINI GOODRICH
` & ROSATI
`701 Fifth Avenue, Suite 5100
`Seattle, WA 98104-7036
`Phone: (206) 883-2925
`Fax: (206) 883-2699
`mrosato@wsgr.com
`asbrown@wsgr.com
`
`By:
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`
`
`/Orion Armon/
`Orion Armon
`Reg. No. 65,421
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`following counsel of record:
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`
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`James Hannah
`KRAMER LEVIN NAFTALIS &
`FRANKEL LLP
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`
`
`990 Marsh Road
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`
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`Menlo Park, CA 94025
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`Phone: (650) 752-1712
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`Fax: (650) 752-1812
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`jhannah@kramerlevin.com
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`Michael Kim
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`
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`Finjan, Inc.
`2000 University Ave., Ste. 600
`E. Palo Alto, CA 94303
`
`Phone: 650.397.9567
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`mkim@finjan.com
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`USPTO Reg. No. 40,450
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