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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Cisco Systems, Inc.,
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`Petitioner,
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`FINJAN, Inc.,
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`Patent Owner.
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`DECLARATION OF JUSTUS L. GETTY, ES! 2.
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`CS-1028
`Cisco Systems, Inc. v. Finjan, Inc.
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`I, Justus L. Getty, declare as follows:
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`1.
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`I am an attorney with Duane Morris LLP and admitted to the bars of
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`Maryland and Washington, DC. I have personal knowledge of the facts stated
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`below.
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`I am over the age of eighteen (18) and otherwise competent to make this
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`declaration.
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`2.
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`Exhibit CS-lOlO is a true and correct copy of User Guide: WebScanX
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`for Windows 3. Ix, Windows 95, and Windows NT, by McAfee Associates, Inc.
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`(1997). Exhibit CS—lOlO was prepared and filed under my direction.
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`3.
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`Exhibit CS-1013 is a true and correct copy of Dynamic Detection and
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`Classification of Computer Viruses Using General Behavior Patterns, by Morton
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`Swimmer, which corresponds to the declaration of John Hawes at Exhibit CS—
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`1038. Exhibits CS-1013 and CS—1038 were prepared and filed under my direction.
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`Exhibit CS-1038 is the declaration of John Hawes and a copy of the article as
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`admitted into evidence in IPR2016—01444. The declaration of John Hawes states a
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`publication date of September 1995. ,
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`4.
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`Exhibit CS—lOlS is a true and correct copy of “Microsoft and
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`VeriSign Provide First Technology for Secure Downloading of Software Over the
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`Internet,” Microsoft PressPass, dated August 7, 1996. Exhibit CS—lOlS was
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`prepared and filed under my direction. Exhibit CS-lO l 5 was retrieved from the
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`Microsoft News Center on June 8, 2017 at
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`https ://news.microsoft.com/ 1 996/0 8/07/microsoft—and—verisign-provide-first-
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`technology—for—secure—downloading-of—software-over-the—internet/.
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`5.
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`Pursuant to 15 U.S.C § 1151 et seq. and § 3704b, the National
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`Technical Information Service (NTIS) was established within the Department of
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`Commerce as “a clearinghouse for the collection and dissemination of scientific,
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`technical, and engineering information” and to take steps “to search, collect,
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`classify coordinate, integrate, record, and catalog such information from whatever
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`sources” and “to make such information available to industry and business, to State _
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`and local governments, to other agencies of the federal Government, and to the
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`general public.”
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`6.
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`On August 30, 2017, l accessed the online records of the NTIS
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`through the National Technical Reports Library (NTRL) website located at
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`https://ntrl.ntis.gov/NTRL/ and downloaded Exhibit CS-1017. The last three pages
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`of Exhibit CS—1017 are a true and accurate screenshot from the Government
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`Printing Office and a true and accurate screenshot of a search record from the
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`NTRL website identifying the publication entitled Automated Assistance for
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`Detecting Malicious Code showing a publication year of 1993.
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`7.
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`On August 31, 2017, l accessed the online records of the NIST
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`through the NTST website located at http://csrc.nist.gov/publications/history/nissc/
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`and downloaded Exhibit CS—1020. The last four pages of Exhibit CS-1020 are a
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`true and accurate screenshot of a search record from the NIST website identifying
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`a publication date of October 1, 1991 for Volume I ofthe Proceedings ofthe Mth
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`National Computer Security Conference (October 1-4, 1991), which includes
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`Identz'jying and Controlling Undesirahle Programs Behaviors.
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`8.
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`On August 30, 2017, I accessed the online records of the NTIS
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`through the National Technical Reports Library NTRL website located at
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`https://ntrl.ntis.gov/NTRL/ and downloaded Exhibit CS—1023. The last page of
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`Exhibit CS—1023 is a true and accurate screenshot of a search record from the
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`NTRL website identifying a publication year of 1990 for the publication entitled
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`National Computer Security Conference (13th) Held in Washington, DC on 1—4
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`October, 1990. Proceedings. Volume 1: Information Systems Security: Standards -
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`The Key to the Future, which contains the article PA CL ’s An Access Control List
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`Approach to Anti— Virus Security (Exhibit CS—1023).
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`9.
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`On August 31, 2017, I accessed the online records of the IEEE
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`through the IEEE Xplore Digital Library website located at
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`http://ieeexp_lore.ieee.orgldocurnent/S02681/ and coordinated the download of
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`Exhibit CS—1024. The last three pages of Exhibit CS—1024 are a true and accurate
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`screenshot of a search record from the IEEE website identifying a publication year
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`of 1996 for the publication entitled Java security: from HotJava to Netscape and
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`beyond.
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`10.
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`On September 15, 2017, I accessed the online records of the NTIS
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`through the National Technical Reports Library NTRL website located at
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`https://ntrl.ntis.gov/NTRL/ and downloaded Exhibit CS—1025. The last page of
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`Exhibit CS-1025 is a true and accurate screenshot of a search record from the
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`NTRL website identifying a publication year of 1995 for the publication entitled
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`National Information Systems Security Conference Proceedings (18”) Held at
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`Baltimore Maryland on 10-13 October 1995. Volume I .' Making Security Real,
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`which contains the article Software Architecture To Support Misuse Intrusion
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`Detection (Exhibit CS—1025).
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`11.
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`Exhibit CS—1026 is a true and correct copy of 1996 CERT Advisories.
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`Exhibit CS-1026 was prepared and filed under my direction. CS-1026 was
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`downloaded on September 15, 2017 from
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`http://resources.sei.cmu.edu/library/asset—View.cfm?assetID=496170. On page 38
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`of CS—1026, advisory CA—1996-08: Vulnerabilities in PCNFSD is shown to have
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`been originally issued April 18, 1996.
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`12.
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`On September 1, 2017, I accessed the online records of the IEEE
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`through the IEEE Xplore Digital Library website located at
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`http://ieeexplore.ieee.orgzdocument/ 1702202/ and coordinated the download of
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`Exhibit CS—103l. The last three pages of Exhibit CS-1031 are a true and accurate
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`screenshot of a search record from the IEEE website identifying a publication date
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`of February 1987 for the publication entitled An Intrusion-Detection Model.
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`13.
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`I declare that all statements made herein on my own knowledge are
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`true and that all statements made on information and belief are believed to be true,
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`and further, that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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