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2004 Exhibit: Ex 2004 Wenke Lee Transcript

Document IPR2023-00458, No. 2004 Exhibit - Ex 2004 Wenke Lee Transcript (P.T.A.B. Dec. 22, 2023)

· · · · · Going back to your declaration at paragraph 42, you say, "In fact, namespaces can have a flat structure forming a single collection of unique names."

· · · · · THE WITNESS:· I don't know how you can organize your data -- I mean, the point is that every file within the directory should be uniquely identified.· That's all.· It's simple, yeah.

· · ·Q.· ·So it provides some metadata field examples.· And then if you go to paragraph 142, one of the examples, is, quote:· "File ancestry information such as:· Copied from, moved from, created from, version of."

· · · · · THE WITNESS:· I don't know exactly the term they use, child or not.· But like -- like what paragraph 142 says, basically it tells you, hey, the ancestry information is such that this file is copied from which file.· Yeah.

· · · · · So my point is that putting all these things together, you would expect that the POSITA will understand that, yes, the user access the file, but then the placement into the appropriate Fortinet Ex. 2004, Page 74 of 212

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- Quinn Emanuel Urquhart & Sullivan

1024 Exhibit: Ex 1024 Declaration of Andrew N Kleing

Document IPR2023-00458, No. 1024 Exhibit - Ex 1024 Declaration of Andrew N Kleing (P.T.A.B. Jul. 18, 2023)

I will be subject to the USPTO Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq.

Declaration of Andrew N. Klein i. Adobe Inc. v. RAH Color Technologies LLC Cases:

experience representing clients in cases involving patents or other intellectual property interests.

I regularly litigate patent cases in various forums including federal district courts across the United States.

Respectfully submitted, /Andrew N. Klein/ Andrew N. Klein Perkins Coie LLP 3150 Porter Drive Palo Alto, California 94304-1212 Netskope Exhibit 1024

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2001 Exhibit: Ex 2001 Declaration of Dr John Black

Document IPR2023-00458, No. 2001 Exhibit - Ex 2001 Declaration of Dr John Black (P.T.A.B. Jun. 20, 2023)

Overall, Petitioner appears to completely ignore or overlook the fact that the Petition relies on multiple dissimilar policies to address the single “policy” recited by the independent claims.

In contrast, Herrmann teaches a gateway system that enforces the installation and use of approved anti-virus applications on client computers before they can access a network or other protected resources.

Overall, Petitioner once again appears to completely ignore or overlook the fact that the Petition relies on multiple dissimilar policies in Auradkar to address the single “policy” recited by the independent claims.

More specifically, Petitioner contends that a POSITA “would have been motivated to modify [Auradkar’s] technique by Chiueh’s mechanism that allowed searching individual document pages.” Id. 79; see also id. 97, 106 (more discussion of the same alleged combination).

Given these teachings, Petitioner does not explain how or why a POSITA would look to modify Auradkar’s platform to implement Auradkar’s complex techniques on Chambers’ simple “network access device” (i.e., the purported “gateway” device), which cannot even function properly without a separate “management server.” See Chambers, ¶¶24-28.

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