[1}:F] heimpayne+chorushLLP
`
`January 18, 2019
`
`Intellectual Property Litigation
`www.heimpaynechorush.com
`
`Jeff True
`SVP & General Counsel
`Palo Alto Networks, Inc.
`3000 Tannery Way
`Santa Clara, CA 95054
`
`Re: Notice oflnfringement And Invitation to License Patents of Packet Intelligence LLC
`
`Dear Mr. True,
`
`I am writing to initiate a discussion regarding Palo Alto Networks, Inc.' s ("Palo Alto")
`infringement of Packet Intelligence LLC's ("Packet Intelligence") patented technology. Packet
`Intelligence is a Texas limited liability company that owns a family of early pioneer patents in
`the field of network traffic processing and monitoring. These patents evolved from research,
`technology, and development conducted by the named inventors while employed at Technically
`Elite, a pioneer in network traffic management and monitoring. The technology reflected within
`the patents enables detailed and efficient management of traffic within today's complex
`networks. The patents have been licensed by major corporations within the network traffic
`management sector, including for example, Cisco Systems and Huawei. The validity of the
`patents has been verified within multiple forums, including inter partes review before the United
`States Patent and Trademark Office (see, e.g., IPR2017-00450, -00451, -00629, -00630, -00769,
`-00862) as well as trial by jury (see, e.g., Packet Intelligence LLC v. NetScout Systems, Inc., et
`al., 2:16-cv-230 (E.D. Tex.); Packet Intelligence LLC v. Sandvine Corp., 2:16-cv-147 (E.D.
`Tex.)).
`
`Packet Intelligence's patents cover the network traffic management and monitoring
`technology that is ubiquitously used by network router sellers and manufacturers, such as Palo
`Alto. In fact, Packet Intelligence has analyzed some of Palo Alto's products and determined that
`Palo Alto infringes Packet Intelligence's patents. In particular, the following chart shows several
`examples of Palo Alto network devices that infringe specific claims of patents owned by Packet
`Intelligence:
`
`..
`
`J;> A TENT AND CLAIMS
`U.S. Patent No. 6,651,099 claim 1
`U.S. Patent No. 6,665,725 claim 10
`U.S. Patent No. 6,839,751 claim 1
`U.S. Patent No. 6,954,789 claim 1
`
`~NllfilNGING··pJloDUCT
`PA-7000 Series Firewall Appliances
`PA-7000 Series Firewall Appliances
`PA-7000 Series Firewall Appliances
`PA-7000 Series Firewall Appliances
`
`'
`
`Heim, Payne & Chorush, L.L.P.
`I 11 I Bagby, Suite 2100 Houston, Texas 77002
`Heritage Plaza
`[tel] 713.221.2000
`[fax] 713.221.2021
`
`Juniper Exhibit 1094
`Juniper Networks, Inc. v. Packet Intelligence LLC
`Page 00001
`
`

`

`To be very clear, the foregoing table only provides examples. Exhibit 1 to this letter provides a
`list of patents that are owned by Packet Intelligence and available for license to Palo Alto. In
`addition, Exhibit 2 to this letter lists several exemplary Palo Alto products that each infringe one
`or more patents listed in Exhibit 1. Packet Intelligence believes that similar products likely also
`infringe, such as older or newer models using similar network traffic processing technology.
`
`Packet Intelligence would like to schedule a meeting in the near future to discuss a patent
`licensing agreement with Palo Alto. After an appropriate confidentiality arrangement, Packet
`Intelligence would also be pleased to share some of its analysis with you to help you evaluate the
`value of Packet Intelligence's offering. Mr. Brad Brunell is Packet Intelligence's representative
`and can respond to your information requests as well as assist in arranging our meeting. Mr.
`Brunell's contact information is as follows:
`
`Brad Brunell
`Email: brad@packetintelligence.com
`
`Thank you for your time and attention to this important matter. Please contact Mr.
`Brunell or me to ask any questions or initiate our discussion. I look forward to speaking soon.
`
`Sincerely,
`
`Allan Bullwinkel
`
`2
`
`Page 00002
`
`

`

`Exhibit 1 - Patents
`
`U.S. Patent No. 6,651,099
`
`U.S. Patent No. 6,665,725
`
`U.S. Patent No. 6,771,646
`
`U.S. Patent No. 6,839,751
`
`U.S. Patent No. 6,954,789
`
`Xl.1
`
`Page 00003
`
`

`

`Exhibit 2 - Products
`Exhibit 2 — Products
`
`PA-200
`PA—ZOO
`
`PA—7000
`PA-7000
`
`PA—7050
`PA-7050
`
`PA-7080
`PA-7080
`
`VM-50
`VM—SO
`
`VM-100
`VM-lOO
`
`VM—3OO
`VM-300
`
`VM-500
`VM—SOO
`
`VM-700
`VM—7OO
`
`X2.1
`X2.1
`
`Page 00004
`
`Page 00004
`
`