Transcript of John Black, Jr., Ph.D.
`(IPR2023-00458)
`
`Date: April 3, 2024
`Case: Netskope, Inc. -v- Fortinet, Inc. (PTAB)
`
`Planet Depos
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`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Netskope Exhibit 1025
`
`
`(IPR2023-00458)
`
`Date: April 3, 2024
`Case: Netskope, Inc. -v- Fortinet, Inc. (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
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`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Netskope Exhibit 1025
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`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` _________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` NETSKOPE, INC.,
` Petitioner,
` vs.
` FORTINET, INC.,
` Patent Owner.
` _________________________
` PTAB Case No. IPR2023-00458
` U.S. Patent No. 9,280,678
`
` DEPOSITION OF JOHN BLACK, JR., Ph.D.
` Wednesday, April 3, 2024
` 3:06 p.m. EST
`
`Job No.: 531921
`Pages: 1 - 97
`Stenographically Reported By:
`Alison C. Webster, CSR-6266, RPR, RMR, CRR, RDR
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
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`2
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` Deposition of JOHN BLACK, JR., Ph.D., produced as a
`witness at the instance of the Petitioner, and duly sworn,
`was taken in the above-styled and numbered cause on Friday,
`March 22, 2024, from 3:06 p.m. to 6:56 p.m. Eastern Time,
`before Alison C. Webster, RPR, CRR, RMR, RDR, CSR-6266
`(Michigan); License No. 14559 (California); License No.
`084.004953 (Illinois); License No. 23001848 (Washington),
`reported by stenographic method, via videoconference,
`pursuant to the Federal Rules of Civil Procedure and the
`provisions stated on the record or attached hereto.
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`3
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` A P P E A R A N C E S
`
`APPEARING ON BEHALF OF THE PETITIONER
` BABAK TEHRANCHI, ESQUIRE
` WEI YUAN, PH.D., ESQUIRE
` Perkins Coie LLP
` 11452 El Camino Real
` Suite 300
` San Diego, California 92130
` 858.720.5734
` btehranchi@perkinscoie.com
` wyuan@perkinscoie.com
`
`APPEARING ON BEHALF OF THE PATENT OWNER
` QUINCY LU, ESQUIRE
` Quinn Emanuel Urquhart & Sullivan, LLP
` 1109 First Avenue
` Suite 210
` Seattle, Washington 98101
` 206.905.7000
` quincylu@quinnemanuel.com
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
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`4
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` T A B L E OF C O N T E N T S
`
` Witness Page
` JOHN BLACK, JR., Ph.D.
`
` EXAMINATION
` BY MR. TEHRANCHI: 6
` EXAMINATION
` BY MR. LU: 94
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` E X H I B I T I N D E X
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` Exhibit Page
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`(Exhibits not offered.)
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
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`5
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` DEPOSITION OF JOHN BLACK, JR., Ph.D.
` Wednesday, April 3, 2024
`
` STENOGRAPHER: The attorneys participating
`in this deposition and the witness have verified that
`he is John Black, Jr., Ph.D. In lieu of an oath
`administered in person, the witness will visually
`affirm his testimony in this matter is under penalty
`of perjury.
` The parties and their counsel consent to
`this arrangement and waive any objections to this
`manner of reporting or admissibility of the
`transcript.
` Would counsel please state their appearance
`and any objections to proceeding in this manner,
`starting with scheduling counsel.
` MR. TEHRANCHI: Babak Tehranchi, counsel
`for petitioner Netskope, and I have no objections.
` MR. LU: Quincy Lu, counsel for patent
`owner Fortinet. I have no objection.
` STENOGRAPHER: Dr. Black, would you please
`raise your right hand.
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`6
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` Do you swear or affirm the testimony you
` are about to give in this matter will be the truth,
` the whole truth, and nothing but the truth?
` JOHN BLACK, JR., Ph.D.,
` was thereupon called as a witness herein, and after
` having first been duly sworn to testify to the truth,
` the whole truth and nothing but the truth, was
` examined and testified as follows:
` THE WITNESS: I do.
` STENOGRAPHER: Thank you.
` You may proceed.
` MR. TEHRANCHI: Thank you.
` EXAMINATION
`BY MR. TEHRANCHI:
`Q. Dr. Black, today we are gonna walk through some
` sections of your declaration and some of the exhibits
` that are already part of the record. And just wanted
` to clarify that when I refer to your declaration, it
` is your supplemental declaration, Exhibit 2003.
` Because I understand you had an earlier declaration,
` but I'll just talk through with you with your -- with
` Exhibit 2003.
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`7
`
`A. Understood.
`Q. And, also, if anything is unclear, please make sure
` that you ask further questions. I hope, you know, we
` could have a conversation that everything's clear for
` the record. And if for any reason you need to take a
` break, please let me know.
`A. Sounds good.
`Q. All right. Thank you.
` With that, you do have a copy of your
` declaration, Exhibit 2003; is that right?
`A. I have that in front of me, yes.
`Q. Okay. Great. Do you have any corrections that you
` would like to make before we start this deposition;
` typos, substantive issues that you would like to
` correct?
`A. I didn't anticipate having an opportunity to make
` corrections so I didn't write them down. I have
` noticed a couple of typographical errors, or I think
` one part I said the wrong ciphertext corresponded to
` the wrong plaintext. And it was -- I used the
` wrong -- the wrong ciphertext out of the patent spec,
` or "Ronn," R-o-n-n. It should have been a different
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`8
`
` one.
` I don't think it is going to matter that
` much to fix those kinds of things but I did notice a
` few mistakes.
`Q. Okay. If you think it matters, it affects the
` substance of your declaration, you know, during the
` break, one of the breaks, you may want to find out
` where it is and let us know. If it's just typos and
` things that are not substantive then I don't think we
` need to correct it, but it's totally up to you.
`A. Okay. Thank you.
`Q. All right. So with that, let's go to paragraph 33 of
` your declaration.
`A. I'm there.
`Q. And this is a fairly long paragraph. You know, feel
` free to read all of it, but I'd like to focus on the
` last sentence that starts with, "As the '678 patent
` explains"...
` Could you read that, and then I'll have a
` follow-up question.
`A. Okay. I read that last sentence.
`Q. Okay. And that sentence says that the policy defines
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`9
`
` multiple things; is that correct?
`A. That's correct. That's in the sentence. I think
` it's also in the claim, first claim of the patent as
` well.
`Q. Okay. And in that -- in that sentence, again in your
` paragraph 33, I'm seeing six items, maybe five because
` one of them may be duplicative. It talks about
` accessing, processing the content, configuring the
` mode in which the data is encrypted, stored, searched,
` and again repeats access.
` So there are basically five or six separate
` items that are listed there; is that correct?
` MR. LU: Objection. Vague.
`A. Yeah, something like that. It's not clear exactly
` what the boundaries of each of these is. Like you
` said, there's maybe some overlap, but I think I
` counted five or six different things.
`BY MR. TEHRANCHI:
`Q. Okay. But is it clear that at least you have to
` access and process based on the policy. It defines --
` let me just read it so there is no ambiguity.
` So it says, "...the Gateway may assign
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`10
`
` users a policy that 'not only defines the manner in
` which the users can access and process content stored
` on the cloud, but can also configure...'" And then
` there are other things listed.
` So the policy needs to define the manner
` that the content is accessed and the manner in which
` the content is processed. Correct?
`A. Right. I think access rights are explicitly in the
` policy. And then process, you know, maybe it -- that
` could be almost anything. But, sure, it does say the
` word "process" there.
`Q. Okay. So by looking at that policy, how can you tell
` which section of the policy deals with accessing,
` which section of the policy deals with processing,
` which section deals with encryption, storing, and the
` other items that are described? So how do you know
` which -- how to -- which section of the policy defines
` which action?
` MR. LU: Objection. Vague. Incomplete
` hypothetical.
`A. So, for example, if you have a policy that says, here
` are the access rights. Right? So typical security
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
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`11
`
`systems will say things like, you're able to read
`these files right to those, perhaps execute under
`certain conditions. So the access rights are
`embodied in some standard encoding.
` And as you know as a security person,
`there's a whole bunch of different systems that do it
`in a whole bunch of different ways, but we have a
`general idea of what does it mean to give access
`rights to a user.
` And then separate from that, the matter in
`which data are encrypted, that could be the algorithm
`used for encryption, the key length restrictions, or
`maybe even the key itself or where to find it. So
`things related to how data are encrypted.
` How are data stored, that could be a list
`of cloud vendors or names of buckets in Amazon S3 or
`something like this, but, basically, what are the
`storage -- the cloud storage repositories that are
`going to be used for this user.
` Searching, that also could define the
`manner in which search was configured so that the user
`understands how to search and what to search, what can
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
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`12
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` be searched. So at least ideally, your policy would
` have distinct sections indicating each of these pieces
` of information.
`Q. Okay. And for someone, whether gateway device or
` another device or even a person, to be able to tell,
` okay, I need to control access rights, how would they
` know -- or I need to control where it's stored, how
` would they know where to look in that policy digest or
` that policy document or policy software or however
` it's stored?
` How do they know where to look for to get
` those particular access policies or storage policies?
`A. So the policy in this context is basically
` configuration information. It's saying how are
` things set up. And sometimes, in computer science,
` these configuration documents are just plaintext.
` They will literally say, access rights, and then give
` you RWX or something, you know, to tell you what your
` rights are.
` Other times, it won't be so human readable,
` it will be encoded in some sort of XML format or even
` in some head-scratching binary encoding that really is
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`Conducted on April 3, 2024
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`13
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` intended only for another computer to be able to
` digest and understand, and a human being looking at
` the configuration or the policy might really have no
` clue as to how to understand its contents.
`Q. And in case when something happens and that policy
` needs to be changed, how would somebody change --
` let's say -- let's give an example so we're more
` specific.
` Let's say the encryption is broken. You
` know, it's -- and it can be attacked, so you want to
` use a different encryption scheme. How would you
` reflect that change in the policy?
`A. So if I understand your question, you're saying that
` the algorithm itself is shown to be faulty and,
` therefore, the company desires to replace it with
` what they believe to be a better option.
` So let's say AES-128 is broken and the
` company says, Oh, my gosh, you know, all of our
` documents over here are being encrypted with this and
` we need to change that. You would have to undertake
` both the task of re-encrypting everything under, let's
` say, AES 256, and then you would have to update all of
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
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`14
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` the policy documents to say this user is now going to
` use AES 256 as their encryption algorithm to access
` those files over there because they've been
` re-encrypted under that new algorithm.
`Q. Okay. And I'm assuming a similar process would be
` needed if the storage policy has changed. So, for
` example, if Box is infiltrated and it's not safe
` anymore and you want to remove it from, you know, a
` remote server location to be -- for storing your data,
` then how would you reflect that change in your policy?
`A. You would have to move the files away from the
` compromised storage repository and then you would
` update the list of repositories in the policy to say
` that this user now no longer has access to Box, or
` whoever, but now has access to this new place where
` the file chunks reside.
`Q. Thank you. One other question about the policy. This
` is a user policy, and I think the claim also recites a
` user policy or a policy assigned to the user.
` We can go to the language of the claims to
` be exact. Let me go and actually make sure there is
` no ambiguity in my question.
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`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
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`15
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` So Claim 1 says, a policy for -- assigning
` to one or more users, by a gateway device, a policy
` for managing access and processing a file to be stored
` on one or more cloud platforms.
` So the question is, those policies assigned
` to a user. Correct?
`A. Right. I guess to one or more, but certainly to one
` user is included in that.
`Q. Okay. And can it be assigned to a group of users or
` class of users?
` MR. LU: Objection. Incomplete
` hypothetical.
`A. I don't know that any of the embodiments or examples
` include sort of a group management and then assigning
` to a single policy to a group. So the way that I
` read the claim, is that it's assigning to -- well, it
` says "one or more users," and so I am -- there's
` nothing that I recall from the specification about
` group management where you build groups of users and
` then assign policies to groups.
` I would have to think about whether --
` let's say you had a system where you had groups of
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Netskope Exhibit 1025
`
`
`
`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`16
`
` users and that system assigned a policy to a group
` which was comprised of users, would that satisfy the
` claim limitation to one or more users, like in a
` transitive way. Right? I assigned it to the group,
` but the group has users, and so I, therefore, have
` assigned that policy to the users belonging to the
` group. I don't think I've considered that and I would
` have to think about it.
`Q. So let me ask you this: Does the claim prohibit
` assigning the policy to a group of users?
`A. I mean, it certainly doesn't say --
` MR. LU: Sorry, objection. Beyond the
` scope.
`A. The claim certainly doesn't say to one or more users
` unless they're in a group and then don't do it.
` Right? So it doesn't prohibit assigning to a group,
` but once again, I'm not sure if it covers assigning
` to a group.
`BY MR. TEHRANCHI:
`Q. Okay. And could the policy be assigned based on the
` class of the user, as I alluded to earlier? And by
` that I mean, mobile device users versus, you know,
`
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Netskope Exhibit 1025
`
`
`
`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`17
`
` P.C. users, as an example.
` MR. LU: Objection. Beyond the scope.
`A. I mean, certainly -- the claim just requires that the
` gateway device assigns policies to one or more users.
` And I suppose you can make up any practice that you
` like for how you do that, as long as you're assigning
` policies to users.
`BY MR. TEHRANCHI:
`Q. Okay. Let's switch gears just a little bit and just
` talk about some of the broader aspects of what's in
` this patent.
` Have you -- is -- have you heard of
` searchable encryption prior to reading this patent?
`A. Certainly, probably in the '90s.
`Q. Okay. So just having a searchable encryption
` methodology or scheme is not new; is that correct?
` MR. LU: Objection. Vague.
`A. The concept of just being able to search encrypted
` data is -- was known before the filing date of the
` patent.
`BY MR. TEHRANCHI:
`Q. Okay. And by that -- and let's be a little bit more
`
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Netskope Exhibit 1025
`
`
`
`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`18
`
` clear. By searchable encryption -- searchable
` encrypted data, what we mean is -- and correct me if
` I'm wrong, I'm just trying to get the understanding
` from your perspective.
` What searchable encrypted data means is,
` you can search the encrypted data without decrypting
` that content; is that correct?
` MR. LU: Objection. Vague.
`A. I have seen the term used in all kinds of different
` ways, but typically the good systems -- I've seen
` papers submitted to conferences where they kind of
` cheat and decrypt portions as they're searching, but
` the general notion is that you want to be able to
` perform a search on data that's encrypted without
` decrypting in order to search.
`BY MR. TEHRANCHI:
`Q. Okay. And in your view, what's disclosed in the '678
` patent goes beyond that basic scheme of providing
` searchable encrypted contents; is that correct?
`A. In the sense that it's narrower, right, that it
` actually requires that this searchable encryption
` scheme be implemented according to certain parameters
`
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Netskope Exhibit 1025
`
`
`
`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`19
`
` or limitations.
`Q. Okay. So let's go to paragraphs 37 and 38 of your
` declaration. And please let me know when you're
` there.
`A. I just arrived. I am there.
`Q. Okay. Paragraph 37 is fairly short, and could you
` read that, just so that we're all on the same page,
` when I refer to that paragraph, there is no confusion.
`A. Okay.
`Q. So the last sentence or the last part of the sentence
` in the -- in paragraph 37 says that, "indices, also
` referred to as keywords hereinafter, which would
` typically be used as search terms in the form of
` search queries are stored as filenames of the chunks."
` Do you see that?
`A. I do.
`Q. Does '678 patent say that you always have to use that
` scheme to use the search terms and store them as
` filenames of the chunks?
`A. No. This is -- this is describing one way of doing
` it. It's an embodiment. The claim, I think, is
` broader than that.
`
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Netskope Exhibit 1025
`
`
`
`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`20
`
`Q. Okay. Fair enough.
` And when you're actually implementing the
` scheme of putting search queries as filenames, how are
` you actually doing that?
` Let me -- let me rephrase.
` Does the '678 patent describe the specific
` details of how you would use these search terms as
` part of filenames?
` MR. LU: Objection. Vague.
`A. They do a fair job. Of course, there's not code in
` the patent. There is a paper that also gives further
` details that's attached as Appendix A to the patent,
` but it -- you know, it gives enough information, I
` think, that if you asked me to code it up and you
` gave me a week, I could implement at least one way of
` implementing the specific system that's described in
` the Dragonfruit paper.
`BY MR. TEHRANCHI:
`Q. Okay. Yeah, no, we don't want you to code it up for
` us right now, but let's just -- just in words.
` And I'm not looking for -- you know, you
` could go into details if you like, but you have search
`
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Netskope Exhibit 1025
`
`
`
`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`21
`
` terms and then you have the file. How would you --
` would you just take the search terms and make them
` part of the file name?
` MR. LU: Objection. Vague. The document
` speaks for itself.
`A. You break the file into chunks, but then those chunks
` are encrypted and you distribute them to various
` cloud repositories and you create these namespaces on
` the various cloud repositories that hold the chunks,
` and then the file names are the encrypted keywords
` that you -- you indicated them in your question, you
` encrypt them and put one or more of them as file
` names of the various chunks.
`BY MR. TEHRANCHI:
`Q. So the file name could have multiple search terms in
` it. Correct?
` MR. LU: Objection. Vague.
` Mischaracterizes testimony.
`A. I'm pretty sure. I'd have to check, but I think one
` of the embodiments says that you could actually have
` multiple search terms concatenated or included in a
` single file name.
`
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Netskope Exhibit 1025
`
`
`
`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`22
`
`BY MR. TEHRANCHI:
`Q. And what happens -- okay. Scratch that.
` Can you have -- is there any limits on the
` number of search terms that you can have in this
` scheme?
` MR. LU: Objection. Vague.
`A. When you create the name space, you are going to have
` some kind of limits on what can be contained as
` values. Now, in the terms of the specific
` implementation we're talking about, virtually every
` file system has a length limit on file names, so that
` would be a constraint. You couldn't put so many
` keywords in a file name that you would then exceed
` the file name limit of the file system.
` There might also be certain forbidden
` characters that could limit, you know, what you could
` do in a file name as well.
`BY MR. TEHRANCHI:
`Q. Can that file name have other fields or other
` information other than the search keywords?
` MR. LU: Objection. Vague. Beyond the
` scope.
`
`15:28:19
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Netskope Exhibit 1025
`
`
`
`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`23
`
`A. I don't think in the embodiment it does. I don't
` think that the claims require that when you configure
` the name space to be searchable, that you're not
` allowed to add other things, you know, to the name
` spaces, if you like; it just needs to be configured
` to be searchable. So I don't see an explicit
` proscription against other data in the file name.
`BY MR. TEHRANCHI:
`Q. How do you know -- how do you know how the search
` terms are delineated in that file name?
` And let me give you a particular example.
` So let's say you have three search terms that you are
` making those search terms, you put it in the file
` name. How do you know where each search term in that
` file name begins and where it ends?
` MR. LU: Objection. Vague.
`A. So the way that we normally do this in a computer
` implementation is we either use a separator between
` terms, and that can be a character that's forbidden
` from being included in the term itself, like a
` vertical bar, let's say, or a comma or something that
` you can't have in the search term, and that's used as
`
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Netskope Exhibit 1025
`
`
`
`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted on April 3, 2024
`
`24
`
` a separator.
` You could also insist that the search term,
` when its encrypted, have a fixed length. So even if
` it's a short word, it's 20 characters long or
` something like this, and so now I know where every
` term begins and ends because they all have the same
` length. There are various techniques like this.
`BY MR. TEHRANCHI:
`Q. Okay. But when somebody is searching that file name,
` they are able to search based on individual file names
` so they're able to somehow parse that file name and be
` able to match or obtain that search term. Correct?
` MR. LU: Objection. Vague.
`A. That's right. So if, let's say -- I mean, the idea
` in this embodiment is that we're going to leverage
` the cloud's built-in ability to look through file
` names quickly, so I don't have to build a separate
` piece of software that parses file names. I just ask
` the cloud service to use its built-in ability to look
` through its file system.
` So let's say I'm looking for -- let's say
` I'm using vertical bars to separate my search term,
`
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Netskope Exhibit 1025
`
`
`
`Transcript of John Black, Jr., Ph.D. (IPR2023-00458)
`Conducted
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