UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`PALO ALTO NETWORKS, INC.
`Petitioner
`
`v.
`
`JUNIPER NETWORKS, INC.
`Patent Owner
`___________________
`
`CASE IPR2013-00369
`Patent 7,107,612
`
`___________________
`
`JUNIPER’S CONTINGENT MOTION TO AMEND
`UNDER 37 C.F.R. § 42.121
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
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`EX 1109 Page 1
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`

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`TABLE OF CONTENTS
`
`Page
`
`I.
`
`II.
`
`STATEMENT OF RELIEF REQUESTED .................................................................... 1 
`
`JUNIPER'S PROPOSED SUBSTITUTE CLAIMS ....................................................... 1 
`
`A.
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`G.
`
`Substitute claim listing ....................................................................... 1
`
`Correspondence to original claims ..................................................... 1
`
`Patentable distinction between substitute claims ............................... 1
`
`The substitute claims are narrower than the original claims as
`discussed by the Board in its Institution Decision applying
`the “broadest reasonable” standard .................................................... 1
`
`The substitute claims respond to each ground of
`unpatentability raised in the IPR ........................................................ 1
`
`The substitute claims do not broaden the original claims .................. 1
`
`Claim construction ............................................................................. 1
`
`III.
`
`THE PROPOSED SUBSTITUTE CLAIMS ARE PATENTABLE OVER THE
`CLOSEST KNOWN PRIOR ART .................................................................................. 1 
`
`A.
`
`B.
`
`Juniper has considered the closest known prior art. ........................... 1
`
`Patentable differences between the closest known prior art
`and the substitute claims .................................................................... 1
`
`IV.
`
`V.
`
`VI.
`
`THIS AMENDMENT IS CONTINGENT ON THE ORIGINAL CLAIMS
`BEING CANCELLED .................................................................................................... 1 
`
`THE SUBSTITUTE CLAIMS ARE SUPPORTED BY THE ORIGINALLY
`FILED APPLICATION AND DO NOT INTRODUCE NEW MATTER ..................... 1 
`
`THE PROPOSED SUBSTITUTE CLAIMS ARE SUBSTANTIALLY
`IDENTICAL WITHIN THE MEANING OF 35 U.S.C. 252. ........................................ 1 
`
`VII.
`
`CONCLUSION ............................................................................................................... 1 
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`TABLE OF AUTHORITIES
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`Page(s)
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`Cases 
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`Toyota Motor Corp. v. American Vehicular Sciences LLC,
`IPR2013-00423, Paper 27 (March 7, 2014) ................................................................. 1
`
`Statutes 
`
`35 U.S.C. § 102 ........................................................................................................................ 5
`
`35 U.S.C. § 252...................................................................................................................... 15
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`37 C.F.R. § 42.121(3) .............................................................................................................. 3
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`Other Authorities 
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`Trial Practice Guide, 77 Fed. Reg. 48756 at 48766 ............................................................... 15
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`Case IPR2013-00369
`Patent 7,107,612
`
`I.
`
`STATEMENT OF RELIEF REQUESTED
`In this contingent motion to amend, Juniper respectfully requests that the
`
`following substitute claims be entered if the original claims of the ‘612 patent are
`
`cancelled. The claims as amended further establish that the ‘612 patent approach of
`
`dynamically adding and modifying rules that exist across multiple sessions is
`
`fundamentally different from the prior art approaches at the time of invention.
`
`II.
`
`JUNIPER’S PROPOSED SUBSTITUTE CLAIMS
`A listing and short discussion of the form of the substitute claims is included
`
`below. The form of the substitute claims complies with the Board’s requirements,
`
`as specified, for example, in Toyota Motor Corp. v. American Vehicular Sciences
`
`LLC, IPR2013-00423, Paper 27 (March 7, 2014).
`
`A.
`Substitute claim listing
` [1] 29. A method, comprising:
`
`establishing a set of rules for controlling access to and from a network
`
`device for incoming and outgoing data units;
`
`receiving, at the network device, a first sequence of data units; and
`
`adding one or more first rules to the set of rules based on data extracted from
`
`the received first sequence of data units, wherein said first rules exist across
`
`multiple sessions.
`
`[2] 30. The method of claim [1] 29, further comprising:
`
`filtering other data units received at the network device based on the set of
`
`rules comprising;
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`determining whether the other data units match one of the rules of the set of
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`Case IPR2013-00369
`Patent 7,107,612
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`
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`rules;
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`denying access to any of the other data units that match one of the rules of
`
`the set of rules; and
`
`permitting access to any of the other data units that do not match one of the
`
`rules of the set of rules.
`
`Original claim 3 is cancelled.
`
`[6] 31. The method of claim [1] 29, wherein the network device is coupled
`
`to a private network and to a public network and the method further comprises:
`
`receiving data units from the public network, wherein headers associated
`
`with the data units include a network address and port number associated with a
`
`firewall implemented at the network device; and
`
`replacing, in the headers for each of the data units, the network address and
`
`port number associated with the firewall with network addresses and port number
`associated with corresponding destination nodes in the private network. 1
`[13] 32. A network device, comprising:
`
`an access control engine configured to establish a set of rules for controlling
`
`access to and from the network device for incoming and outgoing data units; and
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`a dynamic filter configured to add one or more first rules to the set of rules
`
`based on data extracted from a first sequence of data units received at the network
`
`1 Juniper presents this substitute dependent claim as an exemplar only. See
`Ex. 2042 (3/19/14 Hearing Transcript) at 10:5-9.
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`device, wherein said first rules exist across multiple sessions.
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`[22] 33. A method, comprising:
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`Case IPR2013-00369
`Patent 7,107,612
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`establishing a set of rules for controlling access to and from a network
`
`device for incoming and outgoing data units;
`
`dynamically modifying the set of rules based on data extracted from first
`
`data units received at the network device; and
`
`filtering second data units received at the network device based on the
`
`modified set of rules, wherein said rules exist across multiple sessions.
`
`B. Correspondence to original claims
`The proposed substitute claims represent a reasonable number of substitute
`
`claims, at least because no more than one substitute claim is presented to replace
`
`each corresponding challenged claim. 37 C.F.R. § 42.121(3).
`
`Substitute claim Corresponding original claim
`
`29
`
`30
`
`31
`
`32
`
`33
`
`1
`
`2 and 3 (modified)
`
`6
`
`13
`
`22
`
`Amended claim 30 is based on original claim 2 and also incorporates
`
`limitations similar to those of original claim 3, except that the actions to be applied
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`to packets that match or do not match a rule, respectively, are reversed. This
`
`proposed amendment provides a specific example of an advantage of having rules
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`that exist across multiple sessions. Single-session actions typically allow packets
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`Case IPR2013-00369
`Patent 7,107,612
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`(i.e., to open a “pinhole” for a particular session), whereas rules that exist across
`multiple sessions may allow or deny packets.
`
`C.
`Patentable distinction between substitute claims
`The substitute claims are patentably distinct from one another, as each
`
`includes the same distinct limitations of the original claims as they were allowed.
`
`D. The substitute claims are narrower than the original claims as
`discussed by the Board in its Institution Decision applying the
`“broadest reasonable” standard
`If the Board ultimately finds, contrary to the expressed position of Petitioner,
`
`Patent Owner, and their experts, that that claimed “rules” are not properly
`construed to “exist across multiple sessions,” then the substitute claims are
`
`narrower than the original claims so construed. Each substitute independent claim
`
`explicitly includes a limitation that the rules exist across multiple sessions. Thus,
`in the event the Board finds that “rules” in the ‘612 patent could be session-
`
`specific, necessarily follows that the substitute claims would be narrower. Indeed,
`
`the Board has already expressed that “the proposed amendment appears to narrow
`
`the scope of the claims.” Paper 42 at 2.
`
`E.
`
`The substitute claims respond to each ground of unpatentability
`raised in the IPR
`The substitute claims are specifically responsive to the grounds on which the
`
`IPR was instituted, as the references at issue for trial do not disclose or render
`
`obvious adding or modifying rules that exist across multiple sessions, and the
`
`substitute claims correspond only to claims on which trial was instituted.
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`F.
`The substitute claims do not broaden the original claims
`No substitute claim is broader than any of the original claims it would
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`Case IPR2013-00369
`Patent 7,107,612
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`replace in any respect, as no limitation or feature was removed.
`
`G. Claim construction
`Juniper does not believe that its proposed amendments present any issues of
`
`claim construction that reasonably can be anticipated as subject to dispute. Indeed,
`
`the phrase “exists across multiple sessions” was jointly proposed by the parties as a
`
`claim construction that would help explain the proper scope of “rules.” See also
`
`Ex. 2095 § V.A (Dr. Almeroth’s discussion of how the term is understood).
`
`III. THE PROPOSED SUBSTITUTE CLAIMS ARE PATENTABLE
`OVER THE CLOSEST KNOWN PRIOR ART
`A.
`Juniper has considered the closest known prior art.2
`Juniper’s expert Dr. Almeroth has undertaken to identify and analyze the
`
`closest known prior art to the substitute claims—a detailed study that encompassed
`
`more than 30 references, including (1) the references on which IPR was instituted;
`
`(2) the other references PAN relied upon in its Petition; (3) the references cited by
`
`Dr. Mitchell in Ex. 1004; (4) the references PAN asserted against the ‘612 patent
`
`in the concurrent district court litigation; (5) the references cited by Dr. Mitchell in
`
`the concurrent district court litigation; (6) the references submitted to and cited by
`
`
`2 Nothing herein shall be construed as an admission that any of the
`references qualify as “prior art” based on the requirements of 35 U.S.C. § 102, e.g.,
`
`public accessibility of a printed publication.
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`the patent examiner during prosecution of the ‘612 patent, and (7) reference that
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`Case IPR2013-00369
`Patent 7,107,612
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`Dr. Almeroth himself identified. Ex. 2095 ¶ 334.
`
`In reviewing the universe of prior art, Dr. Almeroth specifically considered
`
`and sought to identify whether any references disclose or render obvious the
`
`elements of the amended claims, including dynamic addition or modification of
`
`rules that exist across multiple sessions. Ex. 2095 § X.B. Dr. Almeroth concluded
`
`that the closest known references do not disclose or render obvious the proposed
`
`amended claims, either alone or in combination with other prior art and/or the
`
`background knowledge of those of ordinary skill in the art. Ex. 2095 ¶¶ 336.
`
`For example, Dr. Almeroth considered the Schneider ‘505 patent, Ex. 1007,
`which was included in the Petition for Inter Partes Review.3 Like Julkunen, the
`Schneider ‘505 patent fails to disclose limitations of either the claims as currently
`
`written or the proposed amended claims. Ex. 2095 ¶¶ 338-339. Schneider refers to
`
`an “access filter” that is directed at controlling access to information sets by
`
`individual users and groups of users. Id. Based on trust relationships and policies
`
`established by, for example, an administrator, access attempts are either filtered or
`
`allowed. Id. As such, Schneider does not describe dynamic rules that last beyond a
`
`single session and are based on the inspection of a sequence of packets. Id.
`
`As another example, the Coss references (including both the ‘172 and ‘749
`
`patents, Exs. 2064 and 2064) are focused on an improved firewall that can operate
`
`on faster links without introducing additional delay. The focus is on caching rule
`
`3 The Board did not authorize review on Schneider, finding redundancy.
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`processing results, and therefore, it is ultimately directed to different subject matter
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`Case IPR2013-00369
`Patent 7,107,612
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`than the claims of the `612 patent. Ex. 2095 ¶ 341-345. Coss was cited in the
`
`concurrent litigation, wherein Dr. Mitchell admitted that the alleged dynamic rules
`
`he identified lasted only “for the life of the session.” Ex. 2094 ¶ 729. Coss also
`
`does not disclose receiving a sequence of packets. The one citation relied by Dr.
`
`Mitchell in the previous litigation (i.e., Ex. 2063 at 7:8-9) describes reception of
`
`only a single IP packet. Ex. 2095 ¶ 341-345.
`
`As another example, the focus of the Fink ‘935 patent, Ex. 2066, is on
`
`developing a pre-filtering module to reduce the processing burden of handling
`
`many packets per second. Ex. 2095 ¶ 347. Fink describes the use of something
`
`that it calls “rules,” but does not describe dynamic rules that last beyond a single
`
`session and are based on data extracted from a sequence of packets. Id.
`
`As another example, the Deng ‘432 patent, Ex. 2044, describes architecture
`
`that provides multiple bus interfaces and better memory management in order to
`
`reduce delays associated with handling large numbers of packets per second. Ex.
`
`2095 ¶ 349. Deng describes the use of something that it calls “rules,” but in fact
`
`does not describe the creation of dynamic rules that last beyond a single session
`
`and are based on data extracted from a sequence of packets. Id.
`
`As another example, the focus of the Nessett ‘176 patent, Ex. 2069, is on
`
`developing a coordinated security policy across a complex multi-layer
`
`organization. Ex. 2095 ¶ 351. One goal of Nessett is to develop a policy definition
`
`framework such that efforts across the organization are coordinated and holes in
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`the security apparatus are not created. Id. Nessett describes the use of what it calls
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`Patent 7,107,612
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`“rules,” but does not describe the creation of dynamic rules that last beyond a
`
`single session and are based on data extracted from multiple packets. Id.
`
`
`
`As another example, the focus of the Dietz ‘099 patent, Ex. 2043, is on
`
`network monitoring and deep packet inspection. Ex. 2095 ¶ 353. One goal of the
`
`reference is to describe the mechanism by which each packet is inspected and
`
`determined to be associated with a particular flow. Id. Dietz does not mention
`
`firewalls or prohibiting packets from entering a network, instead generally
`
`describing packet inspection processes. Id. Dietz does not describe the creation of
`
`dynamic rules that last beyond a single session and are based on date extracted
`
`from a sequence of packets. Id.
`
`As another example, the focus of the Decasper article, Ex. 2065, is on
`
`building an open-source, modular router such that existing components can be
`
`refined and enhanced by other researchers/developers and new modules can be
`
`incorporated into the routing architecture. Ex. 2095 ¶ 355. While one of the
`
`modules described is a firewall, there is little detail as to what functions the
`
`firewall will perform and how they are to be performed, much less any description
`
`of dynamically created rules that exist across multiple sessions. Id. One of skill in
`
`the art reading Decasper would understand that the firewall functionality disclosed
`
`was that of typical firewalls at the time the paper was published. As discussed,
`
`such firewalls did not dynamically add rules that existed across multiple sessions,
`
`based on information extracted from incoming packets Id.
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`As another example, there are three references that each relate to Check
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`Case IPR2013-00369
`Patent 7,107,612
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`
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`Point Firewall-1 products, including “Check Point FireWall-1 Quick Start Guide”
`
`(Version 4.0), Ex. 2061; “Check Point Firewall-1 Architecture and
`
`Administration” (Volume 4.0), Ex. 2062; and “Managing Check Point FireWall-1
`
`Using the OpenLook GUI” (Version 4.0), Ex. 2063. Together and individually,
`
`these references describe a traditional firewall, including a management module:
`
`
`See Ex. 2061 at PAN000526282; Ex. 2095 ¶ 358-359. The Check Point product
`
`refers to what it calls “rules,” but these are not rules that are dynamically generated
`
`in response to data extracted from a sequence of data units, nor are they rules that
`
`persist across multiple sessions. Ex. 2095 ¶ 372 And while there is a separate
`
`mechanism for dealing with TCP SYN attacks, this mechanism (i.e., SYNDefender
`
`Gateway or SYNDefender Passive Gateway) does not result in the creation of rules
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`used by the firewall. Id. Therefore, Check Point does not describe the creation of
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`dynamic rules that last beyond the confines of a session and are based on data
`
`extracted from multiple packets. Id.
`
`
`
`There are several additional references that Dr. Almeroth considered,
`
`including the FTP and NAT RFCs, RFC 959, RFC 1631, an IETF Internet Draft on
`
`“Protocol Complications,” and the references cited during the prosecution of the
`
`‘612 patent. Ex. 2095 ¶¶ 360 -384. Dr. Almeroth concluded that, as with the
`
`references above, none of these references anticipate or render obvious the
`
`limitations of the amended claims. Id. ¶¶ 360 –384.
`
`B.
`
`Patentable differences between the closest known prior art and
`the substitute claims
`As explained in Juniper’s Patent Owner Response and in Section IV.A,
`
`above, neither Julkunen, Brenton, nor any of the closest known prior art discloses
`
`or renders obvious the concept of adding or modifying rules that exist across
`
`multiple sessions based on data extracted from multiple incoming packets.
`
`In conducting his study of the closest known prior art, Dr. Almeroth
`
`considered the knowledge of those having ordinary skill in the art, specifically with
`
`respect to the features of the amended claims that provide the basis of patentable
`distinction.4 Such individuals had an understanding of the state of the art of
`network security, including knowledge of fundamental firewall technology that
`
`4 As explained by Dr. Almeroth, a person of ordinary skill in the art for each
`of the patents-in-suit would be a person with a Bachelor’s in Computer Science or
`
`its equivalent and two years of industry experience. Ex. 2095 ¶ 28
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`developed in response to the security concerns that arose in response to increasing
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`numbers of individuals connecting to the Internet. Ex. 2095 ¶ 392. It was well-
`
`understood that network security systems were generally managed by network
`
`administrators capable of configuring sets of rules in a firewall to guard against
`
`anticipated attacks. Id. These sets of rules would sometimes become quite
`
`complex, and required detailed knowledge of the network configuration. Id. After
`
`carefully configuring these rules, they would be implemented (or “committed”) in
`
`the firewall and fixed in place until the network administrator needed to make
`
`further adjustments. Id.
`
`Over time, those of skill in the art incorporated optimizations to these
`
`firewalls. For example, engineers in the field realized that all packets in a single
`
`session can often be treated in the same way. Ex. 2095 ¶ 393 Thus, many firewalls
`
`became “flow-based” (or “session-based”) and incorporated session-specific data
`
`in a flow table or session table. Id.; see also Ex. 2065. Notwithstanding that these
`
`flow-based firewalls had some ability to actively respond to new sessions, the
`
`firewall rules remained fixed across multiple sessions. Id.
`
`Thus, at the time of the ‘612 patent invention (and as demonstrated in the
`
`closest known prior art), the virtually ubiquitous network security paradigm was
`
`one in which firewalls had fixed rules that persisted across multiple sessions,
`
`alongside a session table to which session-specific entries could be added and
`
`deleted as sessions were initiated and terminated. Ex. 2095 ¶ 394. Those of skill in
`
`the art saw this architecture as a way of balancing competing needs of flexibility,
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`speed, and security. Id. Network security engineers also tried to improve upon
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`these various trade-offs in existing systems. For example, as shown above, the
`
`prior art disclosed methods for facilitating rule updates by network administrators,
`
`introduced approaches for efficient handling of session-based data, and attempted
`
`to optimize aspects of the hardware and software in existing firewall
`
`implementations to increase processing speed. Id.
`
`One of the insights of the ‘612 patent—not disclosed in or rendered obvious
`by any of the preexisting art—was that dynamic capabilities could be built into
`the rule set itself, as opposed to a session table or similar functionality limited to a
`
`single session. This contravened the standard approach where it was seen as
`
`important to have rules fixed and unchanging. Indeed, those skilled in the art
`
`generally believed that, due to complexity of existing rule bases, “committing”
`
`rules was something that a human administrator had to oversee. Ex. 2095 ¶ 395.
`
`As set forth in greater detail in the Patent Owner Response, the ‘612 patent’s
`
`approach of adding rules dynamically without user intervention proved to be very
`
`successful. Ex. 2095 ¶ 384. The feature was incorporated into many successful
`
`NetScreen and Juniper products. Id. Moreover, competitors such as PAN took note
`
`of this success, and PAN customers expressly asked that the Juniper embodying
`
`functionality be added to PAN’s products. Id. PAN subsequently copied the ‘612
`
`patent features by specifically referring to Juniper embodying products. Id. These
`
`facts further demonstrate the novelty and non-obviousness of the ‘612 patent
`
`claims as amended, as Dr. Almeroth confirmed in his detailed study.
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`IV. THIS AMENDMENT IS CONTINGENT ON THE ORIGINAL
`CLAIMS BEING CANCELLED
`This motion to amend is contingent on the challenged original claims being
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`Case IPR2013-00369
`Patent 7,107,612
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`canceled. Specifically, each substitute claim should be entered only if the claim to
`
`which it corresponds, as identified in Section II.B above, is cancelled. For
`
`example, claim 29 should be entered only if claim 1 is cancelled, claim 30 should
`
`be entered only if claim 2 is cancelled, etc. As discussed above and elsewhere in
`
`this proceeding, Juniper’s position (as agreed by Petitioner and their experts in the
`
`co-pending litigation and in the Petition) is that the original claims, as properly
`
`construed by a court, are limited to rules that “exist across multiple sessions.”
`
`V. THE SUBSTITUTE CLAIMS ARE SUPPORTED BY THE
`ORIGINALLY FILED APPLICATION AND DO NOT INTRODUCE
`NEW MATTER
`All elements of the proposed substitute claims are supported by the written
`
`description of the originally filed application, and no new matter is added.
`
`The elements regarding establishing a set of rules for controlling access to
`
`and from a network device for incoming and outgoing data units are supported, for
`
`example, by the originally filed application’s description of a firewall with “a set
`
`of rules” with “matching criteria.” Ex. 1005 at 14. The originally filed application
`
`further describes that rules may be used for both “incoming and outgoing packets,”
`
`id. at 13, and that rules may be implemented in an access control engine. Id. at 14.
`
`The elements regarding receiving a sequence of data units, and dynamically
`
`generating rules or adding one or more first rules to the set of rules based on data
`
`extracted from the received first sequence of data units are supported, for example,
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`by the application’s description of “adding rules to the rule set . . . dynamically,”
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`generating the additional rules “based on information extracted from incoming
`
`packets.” Ex. 1005 at 14.; see also id. (“Therefore, it is desirable to provide a
`
`system and method capable of adding rules to the rule set of the firewall engine
`
`dynamically – that is, to extract from a sequence of packets information”).
`
`The elements regarding determining whether data units match one of the
`
`rules of the set of rules, denying access to data units that match one of the rules of
`
`the set of rules, and permitting access to other data units that do not match one of
`
`the rules of the set of rules are supported, for example, by the application’s
`description of “matching criteria” that either allow or deny packets. Ex. 1005 at 14.
`
`Additionally, the elements regarding a network device coupled to a private
`
`network and to a public network and replacing, in the headers for each of the data
`
`units, the network addresses and port numbers associated with the firewall and
`
`with corresponding destination nodes in the private network, are supported, for
`
`example, by the application’s disclosure of a “public network link,” “private
`
`network link,” and network address translation. E.g., id. at 19.
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`Additionally, Dr. Almeroth explains at length in the concurrently filed patent
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`owner opposition, and in ¶¶ 44-50 of his declaration that the ‘612 patent
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`specification discloses rules spanning multiple sessions, as distinguished from
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`session-specific data. Page 16-18 and 30 of the specification as originally filed (Ex.
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`1005) include the exact material that Dr. Almeroth cites from the ‘612 issued
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`specification, so the application as originally filed also disclosed rules that exists
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`across multiple sessions. Ex. 2095 ¶ 341.
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`VI. THE PROPOSED SUBSTITUTE CLAIMS ARE SUBSTANTIALLY
`IDENTICAL WITHIN THE MEANING OF 35 U.S.C. 252.
`The Board’s Trial Practice Guide provides that, “[w]hen filing a motion to
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`amend, a patent owner may demonstrate that the scope of the amended claim is
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`substantially identical to that of the original patent claim, as the original patent
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`claim would have been interpreted by a district court. In such cases, a patent owner
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`may request that the Board determine that the amended claim and original patent
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`claim are substantially identical within the meaning of 35 U.S.C. 252.” Trial
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`Practice Guide, 77 Fed. Reg. 48756 at 48766.
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`In this case, the scope of the substitute claim is substantially identical to that
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`of the original claims as the original claims actually have been construed by the
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`district court. See Ex. 2083 (Markman Order) at 23 (adopting aspect of parties’
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`agreed construction that rules “exist across multiple sessions”). Accordingly,
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`Juniper respectfully requests that the Board rule that the amended claims and
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`original patent claims as interpreted by the court are substantially identical in scope
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`within the meaning of 35 U.S.C. 252.
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`VII. CONCLUSION
`For the reasons noted above, Juniper respectfully requests that the substitute
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`claims be entered if the original claims of the ‘612 patent are held to be
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`unpatentable.
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`Dated: March 28, 2014
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`Respectfully submitted,
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`/David McPhie/
`David McPhie
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`David McPhie, Esq., Reg. 56,412
`Benjamin Haber, Esq., Reg. 67,129
`Lisa Glasser, Esq., pro hac vice
`Irell & Manella LLP
`840 Newport Center Drive, Suite 400
`Newport Beach, CA 92660
`Telephone: (949) 760-0991
`Fax: (949) 760-5200
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`Attorneys for Patent Owner
`Juniper Networks, Inc.
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`CERTIFICATE OF SERVICE
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`Case IPR2013-00369
`Patent 7,107,612
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`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on March 28,
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`2014, a copy of the foregoing document "JUNIPER’S MOTION TO AMEND
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`UNDER 37 C.F.R. §42.121" was served by electronic mail, as agreed to by the
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`parties, upon the following:
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`Matthew I. Kreeger
`Morrison & Foerster LLP
`425 Market Street
`San Francisco CA 94105-2482
`(415) 268-7000
`mkreeger@mofo.com
`lyadao@mofo.com
`bho@mofo.com
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`and
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`Michael J. Schallop
`Van Pelt, Yi & James LLP
`10050 N. Foothill Blvd., Ste. 200
`Cupertino, CA 95014
`(408) 207-4762
`michael.schallop@ip-patent.com
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`/Susan M. Langworthy/
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