UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEX AS
`MARSHALL DIVISION
`
`LIONRA TECHNOLOGIES LIMITED,
`
`Plaintiff,
`
`Case No. 2:22-cv-305
`
`v.
`
`CISCO SYSTEMS, INC.,
`
`Defendant.
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Lionra Technologies Limited (“Lionra”) files this complaint against Cisco Systems,
`
`Inc. (“Cisco” or “Defendant”), alleging infringement of U.S. Patent Nos. 7,916,630, 8,566,612,
`
`7,921,323, 7,302,708, and 7,685,436 (“Patents-in-Suit”). The Accused Products are computer
`
`networking and security products made, used, offered for sale, sold, imported by Defendant in the
`
`United States and supplied by Defendant to its customers and integrated into electronic devices
`
`sold in the United States.
`
`Plaintiff Lionra and th e Patents-in-Suit
`
`1.
`
`Plaintiff Lionra is a technology licensing company organized under the laws of Ireland,
`
`with its headquarters at The Hyde Building, Suite 23, The Park, Carrickmines, Dublin 18, Ireland.
`
`2.
`
`Lionra is the owner of U.S. Patent No. 7,916,630, entitled “Monitoring Condition of
`
`Network with Distributed Components,” which issued March 29, 2011 (the “’630 patent”). A copy
`
`of the ’630 patent is attached to this complaint as Exhibit 1.
`
`1
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 1 of 26
`
`
`FOR THE EASTERN DISTRICT OF TEX AS
`MARSHALL DIVISION
`
`LIONRA TECHNOLOGIES LIMITED,
`
`Plaintiff,
`
`Case No. 2:22-cv-305
`
`v.
`
`CISCO SYSTEMS, INC.,
`
`Defendant.
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Lionra Technologies Limited (“Lionra”) files this complaint against Cisco Systems,
`
`Inc. (“Cisco” or “Defendant”), alleging infringement of U.S. Patent Nos. 7,916,630, 8,566,612,
`
`7,921,323, 7,302,708, and 7,685,436 (“Patents-in-Suit”). The Accused Products are computer
`
`networking and security products made, used, offered for sale, sold, imported by Defendant in the
`
`United States and supplied by Defendant to its customers and integrated into electronic devices
`
`sold in the United States.
`
`Plaintiff Lionra and th e Patents-in-Suit
`
`1.
`
`Plaintiff Lionra is a technology licensing company organized under the laws of Ireland,
`
`with its headquarters at The Hyde Building, Suite 23, The Park, Carrickmines, Dublin 18, Ireland.
`
`2.
`
`Lionra is the owner of U.S. Patent No. 7,916,630, entitled “Monitoring Condition of
`
`Network with Distributed Components,” which issued March 29, 2011 (the “’630 patent”). A copy
`
`of the ’630 patent is attached to this complaint as Exhibit 1.
`
`1
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 1 of 26
`
`
`
`3.
`
`Lionra is the owner of U.S. Patent No. 8,566,612, entitled “System and Method for a Secure
`
`I/O Interface,” which issued October 2, 2013 (the “’612 patent”). A copy of the ’612 patent is
`
`attached to this complaint as Exhibit 2.
`
`4.
`
`Lionra
`
`is
`
`the owner of U.S. Patent No. 7,921,323, entitled “Reconfigurable
`
`Communications Infrastructure for ASIC Networks,” which issued November 16, 2006 (the “’323
`
`patent”). A copy of the ’323 patent is attached to this complaint as Exhibit 3.
`
`5.
`
`Lionra is the owner of U.S. Patent No. 7,302,708, entitled “Enforcing Computer Security
`
`Utilizing an Adaptive Lattice Mechanism,” which issued November 27, 2007 (the “’708 patent”).
`
`A copy of the ’708 patent is attached to this complaint as Exhibit 4.
`
`6.
`
`Lionra is the owner of U.S. Patent No. 7,685,436, entitled “System and Method for a Secure
`
`I/O Interface,” which issued March 23, 2010 (the “’436 patent”). A copy of the ’436 patent is
`
`attached to this complaint as Exhibit 5.
`
`Defendant and the A ccused Products
`
`7.
`
`On information and belief, Defendant Cisco is a California corporation with its principal
`
`place of business at 170 West Tasman Drive, San Jose, California 95134. Cisco can be served
`
`through its registered agent, Prentice Hall Corporation System, 211 E. 7th Street, Suite 620,
`
`Austin, TX 78701.
`
`8.
`
`The Accused Products include firewall products such as the Cisco Firepower 4100 and the
`
`Cisco Secure Web Application Firewall, aggregation router products such as the Cisco ASR 901,
`
`wireless access points such as the Cisco Catalyst 9100, network switch products such as the Cisco
`
`Catalyst 9500.
`
`2
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 2 of 26
`
`
`
`Jurisdiction and V enue
`
`9.
`
`This action arises under the patent laws of the United States, Title 35 of the United States
`
`Code. This Court has original subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
`
`1338(a).
`
`10.
`
`This Court has personal jurisdiction over Cisco in this action because, among other reasons,
`
`Cisco has committed acts within the Eastern District of Texas giving rise to this action and has
`
`established minimum contacts with the forum state of Texas. Cisco maintains several places of
`
`business within the State, including at 2250 East President George Bush Turnpike, Richardson,
`
`TX 75082. Cisco directly and/or through subsidiaries or intermediaries (including distributors,
`
`retailers, and others), has committed and continues to commit acts of infringement in this District
`
`by, among other things, making, using, importing, offering for sale, and/or selling products and/or
`
`services that infringe the patents-in-suit. Thus, Cisco purposefully availed itself of the benefits of
`
`doing business in the State of Texas and the exercise of jurisdiction over Cisco would not offend
`
`traditional notions of fair play and substantial justice. Cisco is registered to do business in the State
`
`of Texas, and has appointed Prentice Hall Corporation System, 211 E. 7th Street, Suite 620, Austin,
`
`TX 78701 as its agent for service of process.
`
`11.
`
`Venue is proper in this district under 28 U.S.C. §1400(b) and 28 U.S.C. §§ 1391(c).
`
`Defendants have regular and established places of business in this district as set forth above.
`
`Count 1 – Claim for infringement of the ’6 30 patent.
`
`12.
`
`Lionra incorporates by reference each of the allegations in paragraphs 1–11 above and
`
`further alleges as follows:
`
`13.
`
`On March 29, 2011, the United States Patent and Trademark Office issued U.S. Patent No.
`
`7,916,630, entitled “Monitoring Condition of Network with Distributed Components.” Ex. 1.
`
`3
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 3 of 26
`
`
`
`14.
`
`Lionra is the owner of the ’630 patent with full rights to pursue recovery of royalties for
`
`damages for infringement, including full rights to recover past and future damages.
`
`15.
`
`16.
`
`Each claim of the ’630 patent is valid, enforceable, and patent-eligible.
`
`Lionra and its predecessors in interest have satisfied the requirements of 35 U.S.C. § 287(a)
`
`with respect to the ’630 patent, and Lionra is entitled to damages for Defendant’s past
`
`infringement.
`
`17.
`
`Defendant has directly infringed (literally and equivalently) and induced others to infringe
`
`the ’630 patent by making, using, selling, offering for sale, or importing products that infringe the
`
`claims of the ’630 patent and by inducing others to infringe the claims of the ’630 patent without
`
`a license or permission from Lionra. These products include without limitation the Cisco ASR 901
`
`Router, which infringes at least claim 1 of the ’630 patent.
`
`18.
`
`On information and belief, the ASR 901 performs a method for monitoring a system
`
`condition of a network with distributed components organized in a logical ring structure:
`
`(https://www.cisco.com/c/en/us/td/docs/wireless/asr_901/Configuration/Guide/b_asr901-
`
`scg/b_asr901-scg_chapter_0111111.pdf at 1.)
`
`19.
`
`On information and belief, in the ASR 901 each component in the system monitors only a
`
`single respective neighboring component among said distributed components that is a predecessor
`
`
`
`4
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 4 of 26
`
`
`
`or successor of said each component in the logical ring structure to determine a current condition
`
`of the respective neighboring component:
`
`
`
`
`
`(https://www.cisco.com/c/en/us/td/docs/wireless/asr_901s/scg/b_scg_for_asr901s/b_scg_for_asr
`
`901s_chapter_0101011.pdf at 3, 5.)
`
`20.
`
`On information and belief, in the ASR 901 each component in the system informs all other
`
`components of the system about the current condition of the respective neighboring component
`
`when the current condition corresponds to at least one predefined condition:
`
`5
`
`
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 5 of 26
`
`
`
`(https://www.cisco.com/c/en/us/td/docs/wireless/asr_901s/scg/b_scg_for_asr901s/b_scg_for_asr
`
`901s_chapter_0101011.pdf at 6.)
`
`Count 2 – Claim for infringement of the ’ 612 patent.
`
`21.
`
`Lionra incorporates by reference each of the allegations in paragraphs 1–20 above and
`
`further alleges as follows:
`
`22.
`
`On October 2, 2013, the United States Patent and Trademark Office issued U.S. Patent No.
`
`8,566,612, entitled “System and Method for a Secure I/O Interface.” Ex. 2.
`
`23.
`
`Lionra is the owner of the ’612 patent with full rights to pursue recovery of royalties for
`
`damages for infringement, including full rights to recover past and future damages.
`
`24.
`
`25.
`
`Each claim of the ’612 patent is valid, enforceable, and patent-eligible.
`
`Lionra and its predecessors in interest have satisfied the requirements of 35 U.S.C. § 287(a)
`
`with respect to the ’612 patent, and Lionra is entitled to damages for Defendant’s past
`
`infringement.
`
`26.
`
`Defendant has directly infringed (literally and equivalently) and induced others to infringe
`
`the ’612 patent by making, using, selling, offering for sale, or importing products that infringe the
`
`claims of the ’612 patent and by inducing others to infringe the claims of the ’612 patent without
`
`a license or permission from Lionra. These products include without limitation the Cisco
`
`Firepower 4100 Series, which infringes at least claim 1 of the ’612 patent.
`
`27.
`
`On information and belief, the Cisco Firepower 4100 includes a security processor which
`
`includes a switching system to send the outgoing packets and receive the incoming packets:
`
`6
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 6 of 26
`
`
`
`
`
`
`
`(https://www.cisco.com/c/en/us/products/collateral/security/firepower-4100-series/datasheet-c78-
`
`742474.html)
`
`28.
`
`On information and belief, the Cisco Firepower 4100 includes a packet engine, coupled to
`
`the switching system, to handle classification processing for the incoming packets received by the
`
`packet engine from the switching system and the outgoing packets sent by the packet engine to the
`
`switching system, wherein the packet engine is one of a plurality of packet engines and
`
`substantially all of the incoming and outgoing packets to the security processor transit one of the
`
`plurality of packet engines:
`
`
`
`7
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 7 of 26
`
`
`
`(https://www.cisco.com/c/en/us/products/collateral/security/firepower-4100-series/datasheet-c78-
`
`742474.html)
`
`
`
`(https://www.cisco.com/c/en/us/td/docs/security/secure-firewall/management-center/device-
`
`config/710/management-center-device-config-71/intrusion-overview.html)
`
`29.
`
`On information and belief, the Cisco Firepower 4100 includes a cryptographic core,
`
`coupled to the packet engine and receiving the incoming packets from the switching system via
`
`the packet engine and communicating the outgoing packets to the switching system via the packet
`
`engine, to provide encryption and decryption processing for packets received from and sent to the
`
`packet engine, wherein the packet engine is interposed between the switching system and the
`
`cryptographic core:
`
`(https://www.cisco.com/c/en/us/products/collateral/security/firepower-4100-series/datasheet-c78-
`
`742474.html)
`
`(https://www.cisco.com/c/en/us/td/docs/security/firepower/623/fdm/fptd-fdm-config-guide-
`
`623/fptd-fdm-ssl-decryption.pdf at 1.)
`
`30.
`
`On information and belief, the Cisco Firepower 4100 includes a signature database:
`
`8
`
`
`
`
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 8 of 26
`
`
`
`(https://www.cisco.com/c/en/us/products/collateral/security/firepower-4100-series/datasheet-
`
`c78-742474.html)
`
`
`
`
`
`(https://www.cisco.com/c/en/us/td/docs/security/secure-firewall/management-center/device-
`
`config/710/management-center-device-config-71/intrusion-overview.html)
`
`31.
`
`On information and belief, the Cisco Firepower 4100 includes an intrusion detection
`
`system coupled between the cryptographic core and the packet engine and responsive to at least
`
`one packet matching a signature stored in the signature database:
`
`
`
`9
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 9 of 26
`
`
`
`(https://www.cisco.com/c/en/us/td/docs/security/firepower/630/configuration/guide/fpmc-config-
`
`guide-v63/overview_of_network_analysis_and_intrusion_policies.pdf at 1, 2.)
`
`
`
`
`
`(https://www.cisco.com/c/en/us/td/docs/security/secure-firewall/management-center/device-
`
`config/710/management-center-device-config-71/intrusion-overview.html)
`
`Count 3 – Claim for infringement of the ’ 323 patent.
`
`32.
`
`Lionra incorporates by reference each of the allegations in paragraphs 1–31 above and
`
`further alleges as follows:
`
`33.
`
`On November 16, 2006, the United States Patent and Trademark Office issued U.S. Patent
`
`No. 7,921,323, entitled “Reconfigurable Communications Infrastructure for ASIC Networks.”
`
`Ex. 3.
`
`34.
`
`Lionra is the owner of the ’323 patent with full rights to pursue recovery of royalties for
`
`damages for infringement, including full rights to recover past and future damages.
`
`35.
`
`Each claim of the ’323 patent is valid, enforceable, and patent-eligible.
`
`10
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 10 of 26
`
`
`
`36.
`
`Lionra and its predecessors in interest have satisfied the requirements of 35 U.S.C. § 287(a)
`
`with respect to the ’323 patent, and Lionra is entitled to damages for Defendant’s past
`
`infringement.
`
`37.
`
`Defendant has directly infringed (literally and equivalently) and induced others to infringe
`
`the ’323 patent by making, using, selling, offering for sale, or importing products that infringe the
`
`claims of the ’323 patent and by inducing others to infringe the claims of the ’323 patent without
`
`a license or permission from Lionra. These products include without limitation the Cisco Catalyst
`
`9500 Series, which infringes at least claim 27 of the ’323 patent.
`
`38.
`
`On information and belief, the Cisco Catalyst 9500 is designed and intended for use in a
`
`communications infrastructure, comprising two or more separate signal processing circuits:
`
`(https://www.cisco.com/c/en/us/td/docs/switches/lan/catalyst9500/software/release/16-
`
`9/configuration_guide/ha/b_169_ha_9500_cg.pdf at 14.)
`
`
`
`11
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 11 of 26
`
`
`
`39.
`
`On information and belief, each one of said two or more signal processing circuits includes
`
`multiple ASIC devices that each itself includes a packet router:
`
`(https://www.cisco.com/c/en/us/products/collateral/switches/catalyst-9500-series-switches/white-
`
`paper-c11-741484.pdf at 11.)
`
`
`
`12
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 12 of 26
`
`
`
`
`
`(https://www.cisco.com/c/en/us/products/collateral/switches/catalyst-9500-series-switches/white-
`
`paper-c11-741484.pdf at 22.)
`
`40.
`
`On information and belief, said packet router of each one of said ASIC devices of each
`
`given one of said respective two or more signal processing circuits being coupled through
`
`respective first and second common interfaces and an intervening high speed serial optical link to
`
`a respective packet router of each of the ASIC devices of each other of said two or more signal
`
`13
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 13 of 26
`
`
`
`processing circuits with no other processing device intervening between the high speed optical link
`
`and said ASIC devices of each of said two or more signal processing circuits:
`
`(https://www.cisco.com/c/en/us/products/collateral/switches/catalyst-9500-series-switches/white-
`
`
`
`paper-c11-741484.pdf at 15.)
`
`14
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 14 of 26
`
`
`
`(https://www.cisco.com/c/en/us/td/docs/switches/lan/catalyst9500/software/release/16-
`
`9/configuration_guide/ha/b_169_ha_9500_cg.pdf at 14.)
`
`Count 4 – Claim for infringement of the ’ 708 patent.
`
`
`
`41.
`
`Lionra incorporates by reference each of the allegations in paragraphs 1–40 above and
`
`further alleges as follows:
`
`42.
`
`On November 27, 2007, the United States Patent and Trademark Office issued U.S. Patent
`
`No. 7,302,708, entitled “Enforcing Computer Security Utilizing an Adaptive Lattice Mechanism.”
`
`Ex. 4.
`
`43.
`
`Lionra is the owner of the ’708 patent with full rights to pursue recovery of royalties for
`
`damages for infringement, including full rights to recover past and future damages.
`
`44.
`
`Each claim of the ’708 patent is valid, enforceable, and patent-eligible.
`
`15
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 15 of 26
`
`
`
`45.
`
`Lionra and its predecessors in interest have satisfied the requirements of 35 U.S.C. § 287(a)
`
`with respect to the ’708 patent, and Lionra is entitled to damages for Defendant’s past
`
`infringement.
`
`46.
`
`Defendant has directly infringed (literally and equivalently) and induced others to infringe
`
`the ’708 patent by making, using, selling, offering for sale, or importing products that infringe the
`
`claims of the ’708 patent and by inducing others to infringe the claims of the ’708 patent without
`
`a license or permission from Lionra. These products include without limitation the Cisco Secure
`
`Web Application Firewall, which infringes at least claim 1 of the ’708 patent.
`
`47.
`
`On information and belief, the Secure Web Application Firewall performs a method for
`
`secure access to a computer system:
`
`(https://www.cisco.com/c/en/us/products/collateral/security/advanced-waf-bot-aag.pdf)
`
`(https://www.cisco.com/c/dam/en/us/products/collateral/security/secure-ddos-services.pdf)
`
`16
`
`
`
`
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 16 of 26
`
`
`
`48.
`
`On information and belief, the Secure Web Application Firewall receives in the computer
`
`system a request from an entity with a predetermined access level for access to a first base node
`
`representing at least one of an information type and a computer system function:
`
`(https://www.radware.com/partners/cisco-waf-bot/)
`
`(https://www.cisco.com/c/en/us/products/collateral/security/advanced-waf-bot-aag.pdf)
`
`
`
`
`
`
`
`(https://www.cisco.com/c/en/us/products/collateral/security/advanced-waf-bot-aag.pdf)
`
`49.
`
`On information and belief, the Secure Web Application Firewall determines if the access
`
`request completes a prohibited temporal access pattern for the entity:
`
`17
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 17 of 26
`
`
`
`(https://www.cisco.com/c/en/us/products/collateral/security/advanced-waf-bot-aag.pdf)
`
`(https://www.cisco.com/c/en/us/products/collateral/security/advanced-waf-bot-aag.pdf)
`
`(https://blog.radware.com/security/2019/06/idba-a-patented-bot-detection-technology/)
`
`50.
`
`On information and belief, the Secure Web Application Firewall compares a minimum
`
`access level established for the first base node to the predetermined access level:
`
`
`
`(https://www.radware.com/partners/cisco-waf-bot/)
`
`18
`
`
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 18 of 26
`
`
`
`
`
`(https://www.cisco.com/c/en/us/products/collateral/security/advanced-waf-bot-aag.pdf)
`
`51.
`
`On information and belief, the Secure Web Application Firewall grants the access request
`
`only if it does not complete a prohibited temporal access pattern for the entity and the minimum
`
`access level for the first base node does not exceed the predetermined access level:
`
`(https://www.radware.com/partners/cisco-waf-bot/)
`
`52.
`
`On information and belief, the Secure Web Application Firewall denies the request if the
`
`access request completes a prohibited temporal access pattern for the entity:
`
`
`
`(https://www.radware.com/partners/cisco-waf-bot/)
`
`
`
`19
`
`
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 19 of 26
`
`
`
`Count 5 – Claim for infringement of the ’ 436 patent.
`
`53.
`
`Lionra incorporates by reference each of the allegations in paragraphs 1–52 above and
`
`further alleges as follows:
`
`54.
`
`On March 23, 2010, the United States Patent and Trademark Office issued U.S. Patent No.
`
`7,685,436, entitled “System and Method for a Secure I/O Interface.” Ex. 5.
`
`55.
`
`Lionra is the owner of the ’436 patent with full rights to pursue recovery of royalties for
`
`damages for infringement, including full rights to recover past and future damages.
`
`56.
`
`57.
`
`Each claim of the ’436 patent is valid, enforceable, and patent-eligible.
`
`Lionra and its predecessors in interest have satisfied the requirements of 35 U.S.C. § 287(a)
`
`with respect to the ’436 patent, and Lionra is entitled to damages for Defendant’s past
`
`infringement.
`
`58.
`
`Defendant has directly infringed (literally and equivalently) and induced others to infringe
`
`the ’436 patent by making, using, selling, offering for sale, or importing products that infringe the
`
`claims of the ’436 patent and by inducing others to infringe the claims of the ’436 patent without
`
`a license or permission from Lionra. These products include without limitation the Cisco
`
`Firepower 4100, which infringes at least claim 1 of the ’436 patent.
`
`59.
`
`On information and belief, the Cisco Firepower 4100 includes a security processor which
`
`includes a switching system to send the outgoing packets and receive the incoming packets:
`
`
`
`20
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 20 of 26
`
`
`
`
`
`(https://www.cisco.com/c/en/us/products/collateral/security/firepower-4100-series/datasheet-
`
`c78-742474.html)
`
`60.
`
`On information and belief, the Cisco Firepower 4100 includes a packet engine, coupled to
`
`the switching system, to handle classification processing for the incoming packets received by the
`
`packet engine from the switching system and the outgoing packets sent by the packet engine to the
`
`switching system, wherein the packet engine is one of a plurality of packet engines and
`
`substantially all of the incoming and outgoing packets to the security processor transit one of the
`
`plurality of packet engines:
`
`(https://www.cisco.com/c/en/us/products/collateral/security/firepower-4100-series/datasheet-
`
`c78-742474.html)
`
`
`
`21
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 21 of 26
`
`
`
`
`
`(https://www.cisco.com/c/en/us/td/docs/security/secure-firewall/management-center/device-
`
`config/710/management-center-device-config-71/intrusion-overview.html)
`
`61.
`
`On information and belief, the Cisco Firepower 4100 provides the incoming packets and
`
`outgoing packets with a tag upon ingress to one of the plurality of packet engines and the tag
`
`determines an egress path within the security processor upon exit from a corresponding
`
`cryptographic core:
`
`
`
`
`
`(https://www.cisco.com/c/en/us/td/docs/security/asa/asa914/configuration/general/asa-914-
`
`general-config/interface-vlan.pdf at 1, 2.)
`
`62.
`
`On information and belief, the Cisco Firepower 4100 includes a cryptographic core,
`
`coupled to the packet engine and receiving the incoming packets from the switching system via
`
`22
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 22 of 26
`
`
`
`the packet engine and communicating the outgoing packets to the switching system via the packet
`
`engine, to provide encryption and decryption processing for packets received from and sent to the
`
`packet engine, wherein the packet engine is interposed between the switching system and the
`
`cryptographic core:
`
`(https://www.cisco.com/c/en/us/products/collateral/security/firepower-4100-series/datasheet-
`
`c78-742474.html)
`
`(https://www.cisco.com/c/en/us/td/docs/security/firepower/623/fdm/fptd-fdm-config-guide-
`
`623/fptd-fdm-ssl-decryption.pdf at 1.)
`
`63.
`
`On information and belief, the Cisco Firepower 4100 includes a signature database:
`
`(https://www.cisco.com/c/en/us/products/collateral/security/firepower-4100-series/datasheet-
`
`c78-742474.html)
`
`
`
`
`
`
`
`23
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 23 of 26
`
`
`
`
`
`(https://www.cisco.com/c/en/us/td/docs/security/secure-firewall/management-center/device-
`
`config/710/management-center-device-config-71/intrusion-overview.html)
`
`64.
`
`On information and belief, the Cisco Firepower 4100 includes an intrusion detection
`
`system coupled between the cryptographic core and the packet engine and responsive to at least
`
`one packet matching a signature stored in the signature database:
`
`
`
`
`
`(https://www.cisco.com/c/en/us/td/docs/security/firepower/630/configuration/guide/fpmc-config-
`
`guide-v63/overview_of_network_analysis_and_intrusion_policies.pdf at 1, 2.)
`
`24
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 24 of 26
`
`
`
`(https://www.cisco.com/c/en/us/td/docs/security/secure-firewall/management-center/device-
`
`config/710/management-center-device-config-71/intrusion-overview.html)
`
`65.
`
`Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Lionra requests a trial by
`
`Jury Trial D emanded
`
`
`
`jury of any issues so triable by right.
`
`Prayer for Relief
`
`
`
`Plaintiff Lionra respectfully requests the following relief from this Court:
`
`A.
`
`A judgment in favor of Lionra that Defendant has infringed the ’630, ’612, ’323, ’708,
`
`and ’436 patents, and that the ’630, ’612, ’323, ’708, and ’436 patents are valid, enforceable, and
`
`patent-eligible;
`
`B.
`
`A judgment and order requiring Defendant to pay Lionra compensatory damages, costs,
`
`expenses, and pre- and post-judgment interest for its infringement of the asserted patents, as
`
`provided under 35 U.S.C. § 284;
`
`C.
`
`A permanent injunction prohibiting Defendant from further acts of infringement of
`
`the ’630, ’612, ’323, ’708, and ’436 patents;
`
`D.
`
`A judgment and order requiring Defendant to provide an accounting and to pay
`
`supplemental damages to Lionra, including, without limitation, pre-judgment and post-judgment
`
`interest;
`
`E.
`
`A finding that this case is exceptional under 35 U.S.C. § 285, and an award of Lionra’s
`
`reasonable attorney’s fees and costs; and
`
`F.
`
`Any and all other relief to which Lionra may be entitled.
`
`25
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 25 of 26
`
`
`
`
`
`Dated: August 8, 2022
`
`
`
` /s/ Reza Mirzaie
`Reza Mirzaie
`CA State Bar No. 246953
`Marc A. Fenster
`CA State Bar No. 181067
`Neil A. Rubin
`CA State Bar No. 250761
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025
`Telephone: 310-826-7474
`Email: rmirzaie@raklaw.com
`Email: mfenster@raklaw.com
`Email: nrubin@raklaw.com
`
`ATTORNEYS FOR PLAINTIFF,
`LIONRA TECHNOLOGIES LIMITED
`
`26
`
`Ex. 1017
`CISCO SYSTEMS, INC. / Page 26 of 26
`
`
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