Brian A. E. Smith (SBN 188147)
`Alden KW Lee (SBN 257973)
`Jeffrey D. Chen (SBN 267837)
`Joseph J. Fraresso (SBN 289228)
`BARTKO, ZANKEL, BUNZEL, & MILLER
`One Embarcadero Center
`San Francisco, CA 94111
`T: 415-956-1900
`Email: bsmith@bzbm.com
`Email: alee@bzbm.com
`Email: jchen@bzbm.com
`Email: jfraresso@bzbm.com
`
`Jonathan T. Suder (Pro Hac Vice)
`Corby R. Vowell (Pro Hac Vice)
`Dave R. Gunter (Pro Hac Vice)
`FRIEDMAN, SUDER & COOKE
`604 East 4th Street, Suite 200
`Fort Worth, TX 76102
`T: 817-334-0400
`F: 817-334-0401
`jts@fsclaw.com
`vowell@fsclaw.com
`gunter@fsclaw.com
`
`Michael F. Heim (Pro Hac Vice)
`R. Allan Bullwinkel (Pro Hac Vice)
`Christopher M. First (Pro Hac Vice)
`HEIM, PAYNE & CHORUSH, LLP
`1111 Bagby Street, Suite 2100
`Houston, Texas 77002
`T: 713-221-2000
`F: 713-221-2021
`mheim@hpcllp.com
`abullwinkel@hpcllp.com
`cfirst@hpcllp.com
`
`Counsel for Plaintiff, Packet Intelligence LLC
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`
`PACKET INTELLIGENCE LLC,
`
`Case No. 3:19-cv-04741-WHO
`
`Plaintiff,
`
`v.
`
`JUNIPER NETWORKS, INC.,
`
`Defendant.
`
`DISCLOSURE OF ASSERTED CLAIMS
`AND INFRINGEMENT CONTENTIONS
`TO JUNIPER NETWORKS, INC.
`
`2697.000/1432433 1
`
`Case No. 3:19-cv-04741-WHO
`DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
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`1 2 3 4 5 6 7 8 9
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`Juniper Exhibit 1087
`Juniper Networks, Inc. v. Packet Intelligence LLC
`Page 00001
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`

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`1
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`PACKET INTELLIGENCE LLC (“Packet Intelligence”) hereby provides its disclosure of
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`2
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`asserted claims and infringement contentions. Packet Intelligence expressly reserves the right to
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`3
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`supplement its contentions based on additional information obtained in discovery and/or the Court’s
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`claim construction.
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`5
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`1.
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`3-1 Disclosure of Asserted Claims and Infringement Contentions
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`6
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`7
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`(a)
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`Each claim of each patent in suit that is allegedly infringed by each opposing
`party, including for each claim the applicable statutory subsections of 35 U.S.C.
`§271 asserted;
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`8
`
`
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`Based on presently available information, Packet Intelligence contends that Juniper
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`9
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`Network, Inc. (“Juniper”) directly infringes under 35 U.S.C. §271(a) at least the following claims:
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`• Claims 1, 2, 4, and 5 of U.S. Patent No. 6,651,099.
`
`• Claims 10, 12, 13, 16, and 17 of U.S. Patent No. 6,665,725;
`
`• Claims 1, 2, 3, 7, 16, and 18 of U.S. Patent No. 6,771,646;
`
`• Claims 1, 2, 5, 10, 14, and 15 of U.S. Patent No. 6,839,751;
`
`• Claims 1, 2, 13, 14, 15, 16, 17, 19, 20, 31, 33, 34, 42, 44, 48, and 49 of U.S. Patent
`
`No. 6,954,789;
`
`Based on presently available information, Packet Intelligence contends that Juniper induces
`
`17
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`and/or has induced its customers to directly infringe under 35 U.S.C. §271(b) at least the following
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`claims:
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`
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`• Claims 1, 2, 4, and 5 of U.S. Patent No. 6,651,099.
`
`• Claims 10, 12, 13, 16, and 17 of U.S. Patent No. 6,665,725;
`
`• Claims 1, 2, 3, 7, 16, and 18 of U.S. Patent No. 6,771,646;
`
`• Claims 1, 2, 5, 10, 14, and 15 of U.S. Patent No. 6,839,751;
`
`• Claims 1, 2, 13, 14, 15, 16, 17, 19, 20, 31, 33, 34, 42, 44, 48, and 49 of U.S. Patent
`
`No. 6,954,789;
`
`2697.000/1432433 1
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`Case No. 3:19-cv-04741-WHO
`2
`DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
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`Page 00002
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`(b)
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`Separately for each asserted claim, each accused apparatus, product, device,
`process, method, act, or other instrumentality (“Accused Instrumentality”) of
`each opposing party of which the party is aware. This identification shall be as
`specific as possible. Each product, device, and apparatus shall be identified by
`name or model number, if known. Each method or process shall be identified
`by name, if known, or by any product, device, or apparatus which, when used,
`allegedly results in the practice of the claimed method or process;
`
`Based on presently available information, Packet Intelligence accuses the following products
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`6
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`of infringing the Asserted Claims listed above:
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`7
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`8
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`9
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`The “Accused Products” include all Juniper products, such as firewall, router, and/or switch
`
`products, that include the Application Identification or Application Aware features, as well as any
`
`other Juniper products with the same or similar functionality. These products include the Juniper
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`10
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`NFX Series Network Services Platform (including but not limited to e.g., NFX150, NFX250,
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`11
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`NFX350), the Juniper SRX Series Next Generation Firewall (NGFW) (including but not limited
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`12
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`to e.g., vSRX, cSRX, SRX100, SRX110, SRX210, SRX220, SRX240, SRX300, SRX320,
`
`13
`
`SRX340, SRX345, SRX380, SRX550, SRX550 HM, SRX650, SRX1400, SRX1500, SRX3400,
`
`14
`
`SRX3600, SRX4100, SRX4200, SRX4600, SRX5400, SRX5600, SRX5800 and other SRX Series
`
`15
`
`products that provide similar functionality) including both physical and virtual/containerized
`
`16
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`platforms, the Juniper MX Series routers including both physical and virtual platforms (including
`
`17
`
`but not limited to e.g., vMX, MX5. MX10, MX40, MX80, MX104, MX150, MX204, MX240,
`
`18
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`MX480, MX960, MX2008, MX2010, MX2020, MX10003), the Juniper EX Ethernet Switches
`
`19
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`(including but not limited to e.g., EX9200, EX9200-VC, EX9251, EX9253), Juniper T Series
`
`20
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`products (including but not limited to e.g., T640, T1600, TX Matrix, TX Matrix Plus), Juniper M
`
`21
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`Series products (including but not limited to e.g., M120, M320), and any predecessor or successor
`
`22
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`models, all of which support or supported the Application Identification (APPID) and/or
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`Application Aware (AppAware) features, and any other Juniper products with similar packet-based
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`24
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`traffic classification and processing technology or other products classifying and relating packet-
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`25
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`based traffic flows with each other, including using information from one or more of layers 5-7
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`26
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`(session, presentation, and/or application layers) of the OSI model to do so.
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`27
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`28
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`
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`(c)
`
`A chart identifying specifically where and how each limitation of each asserted
`claim is found within each Accused Instrumentality, including for each
`limitation that such party contends is governed by 35 U.S.C. § 112(6), the
`
`2697.000/1432433 1
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`Case No. 3:19-cv-04741-WHO
`3
`DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
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`Page 00003
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`2
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`3
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`identity of the structure(s), act(s), or material(s) in the Accused Instrumentality
`that performs the claimed function.
`
`The Accused Products practice the Asserted Claims as shown in the claim charts attached
`
`hereto as Exhibits A-E. Any citations to publicly available documentation in the attached claim
`
`charts are exemplary and not exhaustive, as are the examples provided of the ways in which the
`
`Accused Products satisfy the elements of each of the Asserted Claims. Moreover, any and all
`
`citations or references to publicly available documentation should be understood to encompass any
`
`and all prior versions that incorporate the same or similar functionality, as well as any similar or
`
`derivative products which Packet Intelligence has been unable to discover from publicly available
`
`information to this point.
`
`(d)
`
`For each claim which is alleged to have been indirectly infringed, an
`identification of any direct infringement and a description of the acts of the
`alleged indirect infringer that contribute to or are inducing that direct
`infringement. Insofar as alleged direct infringement is based on joint acts of
`multiple parties, the role of each such party in the direct infringement must be
`described.
`
`Packet Intelligence contends that Juniper has induced infringement of each of the Asserted
`
`15
`
`Claims by instructing, causing, urging, and/or encouraging its customers to make, use, sell, offer for
`
`16
`
`sale and/or import the Accused Products. For example, Juniper’s customers of the Accused Products
`
`17
`
`in the United States include at least:
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`
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`• Aston Martin
`
`• Gap Inc.
`
`• Dartmouth
`
`• The Ricoh Group
`
`• Rackspace
`
`•
`
`Iron Mountain
`
`• Dedicated.com
`
`• City of Fairlawn, Ohio
`
`• Linode
`
`• Gamesys Group
`
`•
`
`Intelsat
`
`2697.000/1432433 1
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`Case No. 3:19-cv-04741-WHO
`4
`DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
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`Page 00004
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`
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`• Blackberry
`
`• University of Louisiana, Monroe
`
`See also: https://www.juniper.net/us/en/company/case-studies-customer-success/#Sort=featured.
`
`Juniper has induced infringement by acts including but not limited to (1) selling such products
`
`including features that—when used or resold—infringe, either literally or under the doctrine of
`
`equivalents, the Patents-in-Suit; (2) marketing the infringing capabilities of such products; and (3)
`
`providing instructions, technical support, and other support and encouragement for the use of such
`
`1
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`2
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`3
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`4
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`5
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`products.
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`28
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`
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`Juniper provides documentation to its customers describing how to install, implement, and
`
`use the Junos operating system and Application Identification feature in an infringing manner on
`
`the Accused Products which is specific evidence of Juniper’s intent to encourage infringement of
`
`the Patents-in-Suit. For example, Juniper provides the following documents:
`
`• Junos OS Application Security User Guide for Security Devices
`
`See: https://www.juniper.net/documentation/en US/junos/information-
`
`products/pathway-pages/security/security-application-identification.pdf
`
`• Junos OS Application Aware Services Interfaces Features Guide for Routing
`
`Devices
`
`See: https://www.juniper.net/documentation/en_US/junos/information-
`
`products/pathway-pages/services-interfaces/application-aware-access-list.pdf
`
`• Junos OS Intrusion Detection and Prevention User Guide
`
`See: https://www.juniper.net/documentation/en US/junos/information-
`
`products/pathway-pages/security/security-idp-policy.pdf
`
`Additional Junos OS and Application Identification technical documentation that Juniper provides
`
`to its customers can be found at https://www.juniper.net/documentation/product/en US/junos-os
`
`Juniper has had knowledge of the Patents-in-Suit and Packet Intelligence’s infringement
`
`allegations related to the accused products since at least as early as January 18, 2019. As of the time
`
`Juniper first had notice of the Packet Intelligence’s infringement allegations, Juniper has continued
`
`with its infringement despite an objectively high likelihood that its actions constitute infringement
`
`2697.000/1432433 1
`
`Case No. 3:19-cv-04741-WHO
`5
`DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
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`Page 00005
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`
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`1
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`and Juniper’s subjective knowledge and willful blindness of this obvious risk.
`
`2
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`3
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`4
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`(e) Whether each limitation of each asserted claim is alleged to be literally present
`or present under the doctrine of equivalents in the Accused Instrumentality;
`
`At this time, and except as otherwise expressly noted in the claim chart, Packet Intelligence
`
`5
`
`contends and reasonably believes that all limitations of the Asserted Claims are present literally. To
`
`6
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`the extent that any specific limitation of the Asserted Claims is found to not be present literally, then
`
`7
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`Packet Intelligence contends that, if there are any differences between the claim elements and the
`
`8
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`Accused Products, the charts attached as Exhibits A-E identify illustrative support for where the
`
`9
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`equivalent feature is found under the doctrine of equivalents pursuant to the function-way-result
`
`10
`
`and/or insubstantial differences tests.
`
`11
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`12
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`13
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`(f)
`
`For any patent that claims priority to an earlier application, the priority date to
`which each asserted claim allegedly is entitled; and
`
`Each of the Asserted Claims is entitled to a filing date of June 30, 1999 because each is
`
`14
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`entitled to the benefit of the filing date of U.S. Provisional Patent Application No. 60/141,903.
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`(g)
`
`If a party claiming patent infringement wishes to preserve the right to rely, for
`any purpose, on the assertion that its own or its licensee’s apparatus, product,
`device, process, method, act, or other instrumentality practices the claimed
`invention, the party shall identify, separately for each asserted claim, each such
`apparatus, product, device, process, method, act, or other instrumentality that
`incorporates or reflects that particular claim.
`
`Packet Intelligence is not currently relying on any such apparatus, product, or device.
`
`(h)
`
`Identify the timing of the point of first infringement, the start of claimed
`damages, and the end of claimed damages; and
`
`The time of first infringement is the date that Juniper first made, used, sold, offered for sale,
`
`23
`
`or imported any of the Accused Products in the United States since the issuance of the ‘725 patent
`
`24
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`on December 16, 2003. Packet Intelligence is not currently aware of the specific date of first
`
`25
`
`infringement but expects to receive this information from Juniper in discovery. The start of the
`
`26
`
`claimed damages period is the date that Juniper first made, used, sold, offered for sale, or imported
`
`27
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`any of the Accused Products in the United States since August 13, 2013 and will end at the time the
`
`28
`
`last of the asserted patents (the ‘751 patent) expires on June 28, 2022.
`
`
`
`2697.000/1432433 1
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`Case No. 3:19-cv-04741-WHO
`6
`DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
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`Page 00006
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`1
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`2
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`3
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`(i)
`
`If a party claiming patent infringement alleges willful infringement, the basis
`for such allegation.
`
`On January 18, 2019, Packet Intelligence sent a letter to Juniper notifying it of Packet
`
`4
`
`Intelligence’s allegation that Juniper’s Accused Products infringe the Patents-in-Suit. Accordingly,
`
`5
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`Juniper has had knowledge of the Patents-in-Suit and Packet Intelligence’s infringement allegations
`
`6
`
`since at least January 18, 2019. Despite such knowledge, Juniper has proceeded to infringe the
`
`7
`
`Patents-in-Suit with full and complete knowledge of its applicability to its products without taking
`
`8
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`a license to the Patents-in-Suit and without a good faith belief that the Asserted Claims are invalid
`
`9
`
`and not infringed. Thus, Juniper’s infringement of the Patents-in-Suit is willful and deliberate,
`
`10
`
`entitling Packet Intelligence to increased damages under 35 U.S.C. § 284.
`
`11
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`1.
`
`3-2 Document Production Accompanying Disclosure
`
`12
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`13
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`14
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`15
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`16
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`17
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`(a)
`
`invoices, advertisements,
`Documents (e.g., contracts, purchase orders,
`marketing materials, offer letters, beta site testing agreements, and third party
`or joint development agreements) sufficient to evidence each discussion with,
`disclosure to, or other manner of providing to a third party, or sale of or offer
`to sell, or any public use of, the claimed invention prior to the date of application
`for the patent in suit. A party’s production of a document as required herein
`shall not constitute an admission that such document evidences or is prior art
`under 35 U.S.C. § 102;
`
`Packet Intelligence identifies the following documents related to this category: PI-
`
`18
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`TORG_000734-91 and PI_015048-76.
`
`19
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`20
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`21
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`22
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`(b)
`
`All documents evidencing the conception, reduction to practice, design, and
`development of each claimed invention, which were created on or before the
`date of application for the patent in suit or the priority date identified pursuant
`to Patent L.R. 3-1(f), whichever is earlier;
`
`Packet Intelligence identifies the following documents related to this category: PI
`
`23
`
`TORG_0000001-733; PI_000002-9, PI_000011-256; PI_000272-601; PI_000712-985; PI_005058-
`
`24
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`59; PI_005061-86; PI_005090-97; PI_005099-106; PI_005111-17; PI_005119-84; PI_005186-94;
`
`25
`
`PI_005198-204; PI_005207-15; PI_005217, PI_005223-35; PI_005237-48; PI_005251-54;
`
`26
`
`PI_005256-59; PI_005265-505; PI_005510; PI_005512; PI_005514; PI_005517; PI_005519;
`
`27
`
`PI_005521; PI_005795-99; PI_005802-04; PI_005807-09; PI_005811-13; PI_006229-31;
`
`28
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`PI_006237-40; PI_006243-76; PI_006757-931; PI_007272-446; PI_007448-70; PI_007614-46;
`
`
`
`2697.000/1432433 1
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`7
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`Page 00007
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`
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`1
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`PI_007651-56; PI_007922-26; PI_007928-29; PI_007931-35; PI_007937-52; PI_007954-83;
`
`2
`
`PI_007985-8015; PI_008018-22; PI_008031-37; PI_008039-55; PI_008058-120; PI_008122-35;
`
`3
`
`PI_008171-89; PI_008194-200; PI_008205-11; PI_008216-18; PI_008223-26; PI_008242-11472;
`
`4
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`PI_011479-642; PI_011673-12128; PI_013000-319; and PI_014652-894.
`
`5
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`6
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`(c)
`
`A copy of the file history for each patent in suit;
`
`Packet Intelligence identifies the following documents related to this category: PI_012129-
`
`7
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`30; PI_012132; and PI_013320-15047.
`
`8
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`9
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`10
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`(d)
`
`All documents evidencing ownership of the patent rights by the party asserting
`patent infringement;
`
`Packet Intelligence identifies the following documents related to this category: PCKTINT-
`
`11
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`00033739-33745, PCKTINT-0003356-33838, PCKTINT-00033839-33844, PCKTINT-00040006-
`
`12
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`40027.
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`13
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`14
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`15
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`16
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`(e)
`
`If a party identifies instrumentalities pursuant to Patent L.R. 3-1(g), documents
`sufficient to show the operation of any aspects or elements of such
`instrumentalities the patent claimant relies upon as embodying any asserted
`claims;
`
`Packet Intelligence has not identified any instrumentalities pursuant to 3-1(g), and
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`17
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`therefore has no documents related to this category.
`
`18
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`19
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`(f)
`
`All agreements, including licenses, transferring an interest in any patent-in-suit;
`
`Packet Intelligence identifies the following documents related to this category: PCKTINT-
`
`20
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`00033739-33745, PCKTINT-0003356-33838, PCKTINT-00033839-33844, PCKTINT-00040006-
`
`21
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`40027.
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`22
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`Packet Intelligence is seeking approval from third parties for the production of additional
`
`23
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`documents related to this category.
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`24
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`25
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`26
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`(g)
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`All agreements that the party asserting infringement contends are comparable
`to a license that would result from a hypothetical reasonable royalty
`negotiation;
`
`Packet Intelligence is seeking approval from third parties for the production of additional
`
`27
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`documents related to this category.
`
`28
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`
`
`(h)
`
`All agreements that otherwise may be used to support the party asserting
`
`2697.000/1432433 1
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`Page 00008
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`
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`infringement’s damages case;
`
`Packet Intelligence identifies the following documents related to this category: PCKTINT-
`
`00033739-33745, PCKTINT-0003356-33838, PCKTINT-00033839-33844, PCKTINT-00040006-
`
`40027.
`
`Packet Intelligence is seeking approval from third parties for the production of additional
`
`documents related to this category.
`
`(i)
`
`If a party identifies instrumentalities pursuant to Patent L.R. 3-1(g), documents
`sufficient to show marking of such embodying accused instrumentalities and if
`it wants to preserve the right to recover lost profits based on such products,
`sales, revenues, costs and profits of such embodying accused instrumentalities;
`and
`
`Packet Intelligence has not identified any instrumentalities pursuant to 3-1(g), and
`
`therefore has no documents related to this category.
`
`(j)
`
`All documents comprising or reflecting a F/RAND commitment or agreement
`with respect to the asserted patent(s).
`
`Packet Intelligence has no documents related to this category.
`
`
`
`DATED: January 23, 2020
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`
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`By:
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`R. Allan Bullwinkel
`R. Allan Bullwinkel
`Counsel for Plaintiff,
`PACKET INTELLIGENCE LLC
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`2697.000/1432433 1
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`Case No. 3:19-cv-04741-WHO
`9
`DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
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`Page 00009
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`CERTIFICATE OF SERVICE
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`I hereby certify that on the 23rd day of January, 2020, a true and correct copy of the above
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`and foregoing document has been provided, via electronic mail, to all counsel of record as follows:
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`Alan M. Fisch – alan.fisch@fischllp.com
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`R. William Sigler – bill.sigler@fischllp.com
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`Jeffrey M. Saltman – Jeffrey.saltman@fischllp.com
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`Adam A. Allgood – adam.allgood@fischllp.com
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`Ken K. Fung – ken.fung@fischllp.com
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`R. Allan Bullwinkel
`R. Allan Bullwinkel
`Counsel for Plaintiff,
`PACKET INTELLIGENCE LLC
`
`2697.000/1432433 1
`
`Case No. 3:19-cv-04741-WHO
`10
`DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`
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`Page 00010
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