Pursuant to 37 C.F.R. § 42.53, Patent Owner Fortinet, Inc. (“Fortinet”) by and through its attorneys, will conduct cross-examination by deposition of Dr. Wenke Lee.

The deposition will take place remotely and commence on December 13 and December 14, 2023 at 9:00 am (PT), or at such place and time as agreed upon by the parties.

The cross-examination of Dr. Lee will be taken before a Notary Public or other officer authorized by law to administer oaths.

Dr. Lee will remain under oath commencing at 9:00 am (PT), or other time agreed upon by the parties, on December 13, 2023 until the conclusion of the deposition.

The deposition will be recorded using audiotape and/or stenographic means with real-time transcription.

Petitioner Netskope, Inc. and Patent Owner Fortinet, Inc. (the “Parties”) hereby stipulate to modify Due Dates 1, 2 and 3 in the Board’s Scheduling Order (Paper No. 11) of September 13, 2023, as follows: Prior Due Date Stipulated Due Date Due Date 1 (Patent Owner’s response December 22, 2023 to the petition): December 8, 2023 Due Date 2 (Petitioner’s reply to Patent March 15, 2024 Owner's response to petition): March 1, 2024 Due Date 3 (Patent Owner’s sur-reply April 26, 2024 to reply): April 12, 2024 Due Dates 1-3 remain unchanged as to Patent Owner’s motion to amend the patent, Petitioner’s opposition to a motion to amend, and Patent Owner’s reply to an opposition to a motion to amend (or Patent Owner’s revised motion to amend).

Due Dates 4-8 remain unchanged.

It is not believed that any other action by the parties or by the Board is required to put the requested schedule modification into effect.

Respectfully submitted,

/Thomas N. Millikan/ Lead Counsel Thomas N. Millikan, Reg. No. 72,316 Back-up Counsel Babak Tehranchi (Reg. No. 55,937) Andrew N. Klein (pro hac vice) Wei Yuan (Reg. No. 71,772) Attorneys for Petitioner Netskope, Inc.

Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner Fortinet, Inc. (“Patent Owner”), submits the following objections to Petitioner Netskope, Inc.’s (“Petitioner”) Exhibits 1002, 1014, 1018, 1019, 1020, 1021, 1022, and 1023.

Further, to the extent the uncited portions of Exhibit 1002 are deemed relevant, their admission would be unduly prejudicial, misleading, and a waste of time in view of the fact that

Patent Owner further objects to Appendices B through E of Exhibit 1002 because Petitioner has not established the documents therein are authentic copies.

Patent Owner further objects to Exhibit 1014 as Petitioner has not established it is a printed publication.

Patent Owner further objects to Exhibit 1019 as Petitioner has not established it is a printed publication.

Pursuant to 37 C.F.R. § 42.8, Patent Owner Fortinet, Inc. (“Patent Owner”),

Patent Owner’s Mandatory Notices hereby submits the following mandatory notices in connection with Netskope, Inc.’s Petition for Inter Partes review of U.S. Patent No. 9,280,678, Case No.

Related Matters Under 37 C.F.R. § 42.8(b)(2) The following judicial or administrative matters may affect or be affected by a decision in this proceeding: Netskope, Inc. v. Fortinet, Inc., No. 3:22-cv-01852-JSC (C.D.

Please address all correspondence and service to all counsel as listed above.

Patent Owner consents to service by email at the addresses listed above.

Referring to the example in Figure 2 below, annotated by Dr. Black, the system operates as an intermediary “Gateway” [204] that facilitates “interactions between enterprise users [202a, 202b, 202c] and cloud service providers [206a, 206b, 206c] for storage, retrieval, and searching of data and content stored by the providers.” Ex. 1001, 8:27-9:4; Ex. 2001, ¶¶31-32.

In an effort to remedy this deficiency, Petitioner alleges that a POSITA “would have added Herrmann’s gateway server and its access policy assignment functionality to Cidon’s management server.” Pet. 27; see also id., 21-22, 25-30, 44-46 (referring to Cidon/Shikfa/Herrmann combination in connection with multiple claim steps).

Petitioner asserts that a POSITA would have been motivated to make the purported modification “because, in addition to Auradkar’s existing whole-document search, the modified system would have allowed retrieval of encrypted document portions stored in the cloud.” Pet. 97; see also Pet. 79, 106 (identifying same alleged benefit).

Petitioner fails to explain how or why a POSITA would look to modify this comprehensive platform to implement Auradkar’s complex techniques on Chambers’ simple “network access device” (Petitioner’s identified “gateway” device) that cannot even perform its own existing functions without a separate “management server.” Chambers, ¶¶24- 28.

Auradkar teaches a comprehensive “trustworthy platform” that uses complex mathematical techniques to provide “containerless” protection of data stored by cloud services in a system of “distribute[d] trust” (Auradkar, Abstract, ¶¶9- 13), whereas Chambers teaches using “network access devices” to “automatically assign[] [network] access control policies (ACPs) based on [client] device types,” where the policies specify network parameters such as “bandwidth limits and traffic shaping rules, VLAN assignment, firewall rules, whether a captive portal should be applied to that device, etc.” Chambers, ¶¶21, 24-28, 32-40.

Patent Owner Fortinet, Inc., hereby appoints the following Practitioners associated with Customer Number 505708 as its attorneys to transact all business in the Patent Trial & Appeal Board of the United States Patent & Trademark Office, including the power to add or remove backup counsel, associated with the above-captioned inter partes review.

Printed Name: William Cooper Title: SVP of Litigation and Compliance Date: February 22, 2023

Pursuant to 37 C.F.R. § 42.8, Patent Owner Fortinet, Inc. (“Patent Owner”),

Patent Owner’s Mandatory Notices hereby submits the following mandatory notices in connection with Netskope, Inc.’s Petition for Inter Partes review of U.S. Patent No. 9,280,678, Case No.

Related Matters Under 37 C.F.R. § 42.8(b)(2) The following judicial or administrative matters may affect or be affected by a decision in this proceeding: Netskope, Inc. v. Fortinet, Inc., No. 3:22-cv-01852-JSC (C.D.

Please address all correspondence and service to all counsel as listed above.

Patent Owner consents to service by email at the addresses listed above.

Namespace Using naming conventions to identify objects is a conceptual framework for Petition for Inter Partes Review of U.S. Pat. No. 9,280,678 B2 PTAB Case No. IPR2023-00458 organizing and managing data and resources introduced decades ago.

Doing so would have ensured the number of generated indexes would be consistent with the searchable encryption mechanism, instead of having the system to make arbitrary decisions or wait for Petition for Inter Partes Review of U.S. Pat. No. 9,280,678 B2 PTAB Case No. IPR2023-00458 input from the administrator.

A POSITA would have made this modification because, in addition to Auradkar’s existing whole-document search, the modified system would have allowed retrieval of encrypted document portions stored in the cloud, “so that a bandwidth resource of the communication network [could] be effectively saved.” (Chiueh, ¶28; Lee, ¶220.)

Petition for Inter Partes Review of U.S. Pat. No. 9,280,678 B2 PTAB Case No. IPR2023-00458 As explained above, a POSITA would have found it obvious to use Chambers’ gateway device to perform the functions described in Auradkar, such as storing the searchable encryption file on one or more cloud platforms based on the

A POSITA would have found it obvious that Auradkar’s SAS constituted the claimed mediation module, because it “facilitat[ed] geographical and provider diversity in data placement, making the system agnostic with respect to specific cloud vendor APIs” (’678 Patent, 4:46-49.)

Pursuant to 37 C.F.R. 42.10(b), Petitioner, Netskope, Inc., hereby appoints the following lead and back-up counsel to transact all business before the Patent Trial and Appeal Board of the United States Patent and Trademark Office in connection with a Petition for Inter Partes Review of U.S. Patent No. 9,280,678 B2 entitled “Secure cloud storage distribution and aggregation.” 159955005.1

The undersigned is authorized to sign this Power of Attorney on behalf of- Petitioner Netskope,Inc.

Date: / ad 2 € - ZO a 4

Title: Intellectual Property Counselfor Netskope,Inc.