[~] heimpayne+chorushLLP
`
`Intellectual Property Litigation
`www.heimpaynechorush.com
`
`January 18, 2019
`
`Brian M. Martin
`SVP, General Counsel and Secretary
`Juniper Networks, Inc.
`1133 Innovation Way
`Sunnyvale, CA 94089
`
`Re: Notice of Infringement And Invitation to License Patents of Packet intell igence LLC
`
`Dear Mr. Martin,
`
`I am writing to initiate a discussion regarding Juniper Network, Inc. 's ("Juniper")
`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 LLCv. 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
`Juniper. In fact, Packet Intelligence has analyzed some of Juniper's products and determined that
`Juniper infringes Packet Intelligence's patents. In particular, the following chart shows several
`examples of Juniper network devices that infringe specific claims of patents owned by Packet
`Intelligence:
`
`INFRINGING PRODUCT
`PATENT AND CLAIMS
`SRX Services Gateways with Application Identification
`U.S. Patent No. 6,651,099 claim 1
`U.S. Patent No. 6,665,725 claim 10 SRX Services Gateways with Application Identification
`U.S. Patent No. 6,839,751 claim 1
`SRX Services Gateways with Application Identification
`SRX Services Gateways with Application Identification
`U.S. Patent No. 6,954,789 claim 1
`
`Heim, Payne & Chorush, L.L.P.
`Heritage Plaza 1111 Bagby, Suite 2100 Houston, Texas 77002
`[tel] 713.221.2000
`[fax] 713.221.2021
`
`Packet Intelligence Ex. 2042 Page 1 of 4
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`

`

`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 Juniper. In
`addition, Exhibit 2 to this letter lists several exemplary Juniper 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 Juniper. 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
`
`Packet Intelligence Ex. 2042 Page 2 of 4
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`

`

`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
`
`Packet Intelligence Ex. 2042 Page 3 of 4
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`Exhibit 2 - Products
`
`SRXl 00 Services Gateway
`
`SRXl 10 Services Gateway
`
`SRX210 Services Gateway
`
`SRX220 Services Gateway
`
`SRX240 Services Gateway
`
`SRX550 Services Gateway
`
`SRX650 Services Gateway
`
`vSRX Virtual Firewall
`
`X2.1
`
`Packet Intelligence Ex. 2042 Page 4 of 4
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`