JOINT CLAIM CONSTRUCTION CASE NO. 5:17-cv-00072-BLF-SVK 

AND PRE-HEARING STATEMENT 

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PAUL J. ANDRE (State Bar No. 196585) 

pandre@kramerlevin.com 

LISA KOBIALKA (State Bar No. 191404) 

lkobialka@kramerlevin.com 

JAMES HANNAH (State Bar No. 237978) 

jhannah@kramerlevin.com 

KRAMER LEVIN NAFTALIS 

 & FRANKEL LLP 

990 Marsh Road 

Menlo Park, CA 94025 

Telephone: (650) 752-1700 

Facsimile: (650) 752-1800 

Attorneys for Plaintiff 

FINJAN, INC. 

DUANE MORRIS LLP 

Patrick S. Salceda (CA SBN 247978) 

psalceda@duanemorris.com 

One Market Plaza 

Spear Tower, Suite 2200 

San Francisco, CA 94105 

Telephone: 415.957.3000 

Facsimile: 650.618.2713 

Attorneys for Defendant 

CISCO SYSTEMS, INC. 

(Complete list of counsel for Defendant on 

signature page) 

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

SAN JOSE DIVISION 

FINJAN, INC., a Delaware Corporation, 

 Plaintiff, 

v. 

CISCO SYSTEMS, INC., 

 Defendant. 

Case No.: 5:17-cv-00072-BLF-SVK 

JOINT CLAIM CONSTRUCTION AND 

PRE-HEARING STATEMENT 

PURSUANT TO DKT. NO. 70 

Case 5:17-cv-00072-BLF Document 85 Filed 11/20/17 Page 1 of 14
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JOINT CLAIM CONSTRUCTION CASE NO. 5:17-cv-00072-BLF-SVK 

AND PRE-HEARING STATEMENT 

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Pursuant to the Joint Stipulated Case Schedule As Modified By The Court (Dkt. No. 70) and 

Patent L.R. 4-3, Plaintiff Finjan, Inc. (“Finjan”) and Defendant Cisco Systems, Inc. (“Cisco” or 

“Defendant”) hereby submit this Joint Claim Construction and Pre-Hearing Statement. 

I. PATENT L.R. 4-3(a): PROPOSED CONSTRUCTION OF EACH DISPUTED TERM. 

The parties’ agreed upon claim constructions are provided below. 

U.S. Patent No. 6,154,844 

Claim Term Claim(s) Agreed Construction 

Downloadable 1, 15, 43 an executable application program, which is downloaded from a 

source computer and run on the destination computer. 

U.S. Patent No. 8,677,494 

Claim Term Claim(s) Agreed Construction 

Downloadable 10 an executable application program, which is downloaded from 

a source computer and run on the destination computer 

database 10 a collection of interrelated data organized according to a 

database schema to serve one or more applications 

U.S. Patent No. 6,804,780 

Claim Term Claim(s) Agreed Construction 

“Downloadable” 1, 9, 17, 18 an executable application program, which is downloaded from a 

source computer and run on the destination computer. 

II. PATENT L.R. 4-3(b): PROPOSED CONSTRUCTION OF EACH DISPUTED TERM. 

The parties’ proposed additional claim constructions are provided below. All supporting 

evidence for the parties’ claim constructions is provided in Exhibit A. The parties reserve their rights 

to cite additional supporting evidence based on arguments raised in the claim construction briefs. 

U.S. Patent No. 6,154,844 

Claim Term Claim(s) Finjan’s Proposed 

Construction 

Defendants’ Proposed 

Construction 

inspector 1, 15, 43 No construction necessary – 

Plain and ordinary meaning. 

external server that is not a 

network gateway for 

performing content inspection 

Case 5:17-cv-00072-BLF Document 85 Filed 11/20/17 Page 2 of 14
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JOINT CLAIM CONSTRUCTION CASE NO. 5:17-cv-00072-BLF-SVK 

AND PRE-HEARING STATEMENT 

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U.S. Patent No. 6,154,844 

Claim Term Claim(s) Finjan’s Proposed 

Construction 

Defendants’ Proposed 

Construction 

of a Downloadable 

web server 1, 15, 43 No construction necessary – 

Plain and ordinary meaning. 

web server that is not a network 

gateway 

Downloadable 

security profile 

that identifies 

suspicious code in 

[the/a] [received] 

Downloadable 

1, 15, 43 No construction necessary – 

Plain and ordinary meaning. 

a profile that includes a list of 

code within [the/a] [received] 

Downloadable for performing 

undesirable, hostile, or 

potentially hostile suspicious 

operations 

before a web 

server makes the 

Downloadable 

available to web 

clients 

1, 15, 43 No construction necessary – 

Plain and ordinary meaning. 

Plain and ordinary meaning 

of “web client” is “an 

application on the computer 

of an end user that requests a 

Downloadable from the web 

server.” 

before any web server makes 

the Downloadable available to 

any web client 

content inspection 

engine for using 

the first rule set to 

generate a first 

Downloadable 

security profile 

that identifies 

suspicious code in 

a Downloadable, 

and for linking the 

first Downloadable 

security profile to 

the Downloadable 

before a web 

server makes the 

Downloadable 

available to web 

clients 

15 No construction necessary – 

Plain and ordinary meaning. 

software running on an external 

server that is not a network 

gateway for performing content 

inspection of a Downloadable 

that performs the functions 

recited in the claim 

*Subject to the constructions 

for terms within the recited 

functions 

means for 

receiving a 

Downloadable 

43 Governed by 35 U.S.C. § 

112(6): 

Function: receiving a 

Downloadable 

Governed by 35 U.S.C. § 112(6): 

Function: 

receiving a Downloadable 

Structure: 

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JOINT CLAIM CONSTRUCTION CASE NO. 5:17-cv-00072-BLF-SVK 

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U.S. Patent No. 6,154,844 

Claim Term Claim(s) Finjan’s Proposed 

Construction 

Defendants’ Proposed 

Construction 

Structure: Downloadable file 

interceptor 

inspector 125 that is external to 

a network gateway 

means for 

generating a first 

Downloadable 

security profile 

that identifies 

suspicious code in 

the received 

Downloadable 

43 Governed by 35 U.S.C. § 

112(6): 

Function: generating a first 

Downloadable security profile 

that identifies suspicious code 

in the received Downloadable 

Structure: content inspection 

engine programmed to perform 

the algorithm disclosed at Col. 

8, lines 51-60 of the ’844 

Patent 

Governed by 35 U.S.C. § 112(6): 

Function: 

“generating a first 

[Downloadable security profile 

that identifies suspicious code 

in the received Downloadable] 

Structure: 

Content inspection engine 160 

of inspector 125 programmed to 

perform the algorithm disclosed 

at 8:49-60 of the ’844 patent 

and 5:36-47, 5:54-57, 8:23-24, 

9:20-42, and Fig. 7 of U.S. 

Patent No. 6,092,194

means for linking 

the first 

Downloadable 

security profile to 

the Downloadable 

before a web 

server makes the 

Downloadable 

available to web 

clients 

43 Governed by 35 U.S.C. § 

112(6): 

Function: linking the first 

Downloadable security profile 

to the Downloadable before a 

web server makes the 

Downloadable available to web 

clients 

Structure: content inspection 

engine programmed to perform 

the algorithm of step 630 

disclosed at Fig. 6; col. 8, lines 

65-67; and col. 6, lines 13-24 

Governed by 35 U.S.C. § 112(6): 

Function: 

“linking the first Downloadable 

security profile to the 

Downloadable [before a web 

server makes the Downloadable 

available to web clients]” 

Structure: 

Content inspection engine 160 

of inspector 125 programmed to 

perform step 630 of FIG. 6, 

disclosed at 8:65-67 and col. 6, 

lines 13-20. Specifically, 

attaching a Downloadable 

security profile to the 

Downloadable (col. 8, lines 65-

67 and col. 6, lines 13-18) or 

attaching to the Downloadable 

a pointer that points to a stored 

Downloadable security profile 

(col. 6, lines 18-20).

receiving...; 

generating...; and 

linking....” 

1 No construction necessary – 

Plain and ordinary meaning. 

Order of steps is performed as 

recited in the claim. 

Case 5:17-cv-00072-BLF Document 85 Filed 11/20/17 Page 4 of 14
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JOINT CLAIM CONSTRUCTION CASE NO. 5:17-cv-00072-BLF-SVK 

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U.S. Patent No. 8,677,494 

Claim Term Claim(s) Finjan’s Proposed 

Construction 

Defendants’ Proposed 

Construction 

Downloadable 

scanner 

10 No construction necessary 

– Plain and ordinary 

meaning. 

software for disassembling 

machine code of a Downloadable 

and resolving commands to 

identify suspicious operations in 

the Downloadable 

U.S. Patent No. 6,804,780 

Claim Term Claim(s) Finjan’s Proposed 

Construction 

Defendants’ Proposed 

Construction 

“obtaining...; 

fetching...; and 

performing....” 

1 No construction necessary 

– Plain and ordinary 

meaning. 

Order of steps is performed as 

recited in the claim. 

“software 

component[s]” 1, 9, 17, 18 No construction necessary 

– Plain and ordinary 

meaning. 

code module required to be 

included within a Downloadable 

for execution as part of the 

Downloadable 

“performing a 

hashing function 

on the 

Downloadable and 

the 

fetched software 

components 

to generate a 

Downloadable 

ID” 

1, 9, 17, 18 performing a hashing 

function on the 

Downloadable together with 

its fetched software 

components to generate a 

Downloadable ID 

performing a hashing function on 

the Downloadable together with 

its fetched software components 

to generate a unique and 

reproducible number or string 

that is the same whether the 

software components are 

referenced by the Downloadable 

and or are included with the 

Downloadable 

“means for 

fetching at least 

one software 

component 

identified by the 

one or more 

references” 

17 Governed by 35 U.S.C. § 

112(6): 

Function: fetching at least 

one software component 

identified by the one or 

more references 

Structure: ID generator 

programmed to perform the 

algorithm of step 820 

disclosed at Fig. 8; col. 9, 

lines 62-63; and col. 4, lines 

56-66.

Governed by 35 U.S.C. § 112(6): 

Function: 

“fetching at least one software 

component identified by the one 

or more references” 

Structure: 

Indefinite 

“means for 

performing a 17 Governed by 35 U.S.C. § 

112(6): 

Governed by 35 U.S.C. § 112(6): 

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JOINT CLAIM CONSTRUCTION CASE NO. 5:17-cv-00072-BLF-SVK 

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U.S. Patent No. 6,804,780 

Claim Term Claim(s) Finjan’s Proposed 

Construction 

Defendants’ Proposed 

Construction 

hashing function 

on the 

Downloadable and 

the fetched 

software 

components to 

generate a 

Downloadable ID” 

 

Function: performing a 

hashing function on the 

Downloadable and the 

fetched software 

components to generate a 

Downloadable ID 

Structure: ID generator 

programmed to perform the 

algorithm of step 840 

disclosed at Fig. 8; col. 9, 

lines 65-67.

Function: 

“performing a hashing function 

on the Downloadable and the 

fetched software components to 

generate a Downloadable ID” 

*This function is subject to the 

construction identified elsewhere 

herein 

Structure: 

ID generator 315 programmed to 

perform algorithm of steps 830 

and 840 described at 9:62-67. 

“means for 

obtaining a 

Downloadable that 

includes 

one or more 

references to 

software 

components 

required 

to be executed by 

the 

Downloadable” 

17 Governed by 35 U.S.C. § 

112(6): 

Function: obtaining a 

Downloadable that includes 

one or more references to 

software components 

required to be executed by 

the Downloadable 

Structure: ID generator 

programmed to perform the 

algorithm of step 810 

disclosed at Fig. 8; col. 4, 

lines 50-54; col. 9, lines 58-

61

Governed by 35 U.S.C. § 112(6): 

Function: 

obtaining a Downloadable that 

includes one or more references 

to software components 

required to be executed by the 

Downloadable 

Structure: 

Indefinite 

“communications 

engine for 

obtaining a 

Downloadable that 

includes one or 

more 

references to 

software 

components 

required to be 

executed by the 

Downloadable” 

9 No construction necessary 

– Plain and ordinary 

meaning. 

Governed by 35 U.S.C. § 112(6): 

Function: 

obtaining a Downloadable that 

includes one or more references 

to software components required 

to be executed by the 

Downloadable 

Structure: 

Indefinite 

“ID generator 

coupled to the 

9 No construction necessary 

– Plain and ordinary 

Governed by 35 U.S.C. § 112(6): 

Case 5:17-cv-00072-BLF Document 85 Filed 11/20/17 Page 6 of 14
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U.S. Patent No. 6,804,780 

Claim Term Claim(s) Finjan’s Proposed 

Construction 

Defendants’ Proposed 

Construction 

communications 

engine that 

fetches at least one 

software 

component 

identified by the 

one or more 

references” 

meaning. Function: 

fetching at least one software 

component identified by the one 

or more references 

Structure: 

Indefinite 

U.S. Patent No. 8,141,154 

Claim Term Claim(s) Finjan’s Proposed 

Construction 

Defendants’ Proposed 

Construction 

“a call to a first 

function” 

1 No construction necessary 

– Plain and ordinary 

meaning. 

a statement or instruction in a 

program requesting the services 

of a particular (i.e., first) function 

“a first function” 1 No construction necessary 

– Plain and ordinary 

meaning. 

substitute function 

“a second 

function” 

1 No construction necessary 

– Plain and ordinary 

meaning. 

original function, which is 

different than the first function 

U.S. Patent No. 7,647,633 

Claim Term Claim(s) Finjan’s Proposed 

Construction 

Defendants’ Proposed 

Construction 

“mobile 

protection code” 

1, 8, 13, 14 code that, at runtime, 

monitors or intercepts 

actually or potentially 

malicious code operations 

without modifying the code 

operations 

mobile executable code that, at 

runtime, monitors for and 

intercepts actually or potentially 

malicious code operations 

“informationdestination of the 

downloadableinformation” 

1, 8, 13 No construction necessary – 

Plain and ordinary meaning. 

The plain and ordinary 

meaning of the terms 

“information-destination” 

and “downloadableinformation destination” is a 

device or process that is 

capable of receiving and 

initiating or otherwise 

hosting a mobile code 

execution. 

client(s) that originally requested, 

and is the final destination for, 

the downloadable-information 

“downloadableinformation 

destination” 

14 

Case 5:17-cv-00072-BLF Document 85 Filed 11/20/17 Page 7 of 14
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U.S. Patent No. 7,647,633 

Claim Term Claim(s) Finjan’s Proposed 

Construction 

Defendants’ Proposed 

Construction 

“determining ... 

whether the 

downloadableinformation 

includes 

executable code” 

1, 8, 13 No construction necessary – 

Plain and ordinary meaning. 

distinguishing between two 

alternative possibilities: 

executable code is included in the 

downloadable-information, and 

executable code is not included in 

the downloadable-information 

“information recommunicator” 2, 3, 9, 10 No construction necessary – 

Plain and ordinary meaning. 

server 

“means for 

receiving 

downloadableinformation” 

13 Governed by 35 U.S.C. § 

112(6): 

Function: receiving 

downloadable‐information 

Structure: recommunicating device 

Governed by 35 U.S.C. § 112(6): 

Function: 

receiving downloadableinformation 

Structure: 

server 

“means for 

determining 

whether the 

downloadableinformation 

includes 

executable code” 

13 Governed by 35 U.S.C. § 

112(6): 

Function: determining 

whether the downloadable‐

information includes 

executable code 

Structure: code detection 

engine to perform the 

algorithm of col. 2 at 63-66, 

col. 14, line 58 to col. 15, 

line 8 or col. 16, lines 16-27. 

Governed by 35 U.S.C. § 112(6): 

Function: 

determining whether the 

downloadable-information 

includes executable code 

Structure: 

sever with content inspection 

engine for performing algorithm 

of FIG. 10a described at 19:18-47 

“means for 

causing mobile 

protection code to 

be communicated 

to at least one 

informationdestination of the 

downloadableinformation, if the 

downloadableinformation is 

determined to 

include 

13 Governed by 35 U.S.C. § 

112(6): 

Function: if the 

downloadable-information is 

determined to include 

executable code, causing 

mobile protection code to be 

communicated to at least one 

information-destination of 

the downloadableinformation without 

modifying the executable 

Governed by 35 U.S.C. § 112(6): 

Function: 

causing mobile protection code to 

be communicated to at least one 

information-destination of the 

downloadable-information, if the 

downloadable-information is 

determined to include executable 

code 

Structure: 

server with packaging engine 403 

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U.S. Patent No. 7,647,633 

Claim Term Claim(s) Finjan’s Proposed 

Construction 

Defendants’ Proposed 

Construction 

executable code” code 

Structure: transfer engine 

programmed to perform the 

algorithm of col. 14, lines 24-

36.

of FIG. 4 performing the 

algorithm described at 12:38-

12:64 and 13:19-13:41 

“A computer 

program product, 

comprising a 

computer usable 

medium having a 

computer readable 

program code 

therein, 

the computer 

readable program 

code adapted to be 

executed for 

computer security, 

the method 

comprising:” 

14 “A computer program 

product, comprising a 

computer usable 

medium having a computer 

readable program code 

therein, 

the computer readable 

program code adapted to be 

executed for computer 

security, comprising:” 

Indefinite under IPXL (mixed 

statutory classes) and Nautilus

“A computer 

program product, 

comprising a 

computer usable 

medium having a 

computer readable 

program code 

therein, the 

computer readable 

program code 

adapted to be 

executed for 

computer security, 

the method 

comprising: 

providing a 

system...; 

receiving ...; and 

causing ...” 

14 “A computer program 

product, comprising a 

computer usable 

medium having a computer 

readable program code 

therein, 

the computer readable 

program code adapted to be 

executed for computer 

security, comprising: 

providing a system...; 

receiving ...; and causing 

...” 

Indefinite under Nautilus

standard 

“causing mobile 

protection code to 

be executed by the 

mobile code 

executor at a 

14 No construction necessary – 

Plain and ordinary meaning. 

packaging mobile protection code 

with the downloadableinformation such that upon 

receipt of the package the mobile 

protection code is initiated by the 

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U.S. Patent No. 7,647,633 

Claim Term Claim(s) Finjan’s Proposed 

Construction 

Defendants’ Proposed 

Construction 

downloadableinformation 

destination” 

mobile code executor at the 

downloadable-information 

destination before initiating the 

downloadable-information 

III. PATENT L.R. 4-3(c): IDENTIFICATION OF 10 TERMS WHOSE CONSTRUCTION 

WILL BE MOST SIGNIFICANT TO RESOLUTION OF THE CASE. 

The parties hereby identify in the table below five (5) terms each for a total of ten (10) terms 

per Patent L.R. 4-3(c): 

No. Patent [Claim] Term Identifying Party 

1 ’844 patent [43] means for receiving a Downloadable Finjan 

2 ’844 patent [43] means for generating a first Downloadable 

security profile that identifies suspicious code in 

the received Downloadable 

Finjan 

3 ’844 patent [43] means for linking the first Downloadable 

security profile to the Downloadable before a 

web server makes the Downloadable available 

to web clients 

Finjan 

4 ’844 patent: [1, 

15, 43] 

before a web server makes the Downloadable 

available to web clients 

Cisco 

5 ’633 patent: [13] means for determining whether the 

downloadable-information includes executable 

code 

Finjan 

6 ’633 patent: [13] means for causing mobile protection code to be 

communicated to at least one informationdestination of the downloadable-information, if 

the downloadable- information is determined to 

include executable code 

Finjan 

7 ’633 patent: [1, 8, 

13/14] 

information-destination of the downloadableinformation”/“downloadable-information 

destination 

Cisco 

8 ’494 patent: [10] Downloadable scanner Cisco 

9 ’780 patent [1, 9, 

17, 18] 

performing a hashing function on the 

Downloadable and the fetched software 

components to generate a Downloadable ID 

Cisco 

10 ’154 patent: [1] a first function/a second function Cisco 

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Finjan’s Statement:

Finjan does not consider any of the disputed terms significant or case or claim dispositive. 

Cisco’s Statement:

Cisco believes each of the ten (10) terms listed above is claim dispositive individually and case 

dispositive in the aggregate. 

Cisco’s Additional Statement: 

In addition to the ten (10) terms identified above by the parties under Patent L.R. 4-3(c), Cisco 

believes that there is a fundamental dispute that must be resolved by the Court under O2 Micro Int’l v. 

Beyond Innovation Tech. Co., regarding the additional terms listed in Exhibit A that are not in the list 

of ten (10) terms identified above. Of these terms, Cisco believes that the sub-set of terms listed below 

are most important, as their constructions are claim dispositive. Cisco will seek leave of Court to brief 

more than the ten (10) terms identified jointly by the parties. 

A. ’844 patent

1. “inspector” (claims 1, 15, 43) 

2. “Downloadable security profile that identifies suspicious code in [the/a] [received] 

Downloadable” (claims 1, 15, 43) 

3. “content inspection engine for using the first rule set to generate a first Downloadable 

security profile that identifies suspicious code in a Downloadable, and for linking the first 

Downloadable security profile to the Downloadable before a web server makes the Downloadable 

available to web clients” (claim 15) 

B. ’780 patent

4. “software components” (claims 1, 9, 17 and 18) 

5. “means for performing a hashing function on the Downloadable and the fetched 

software components to generate a Downloadable ID” (claim 17) 

C. ’154 patent

6. “a call to a first function” (claim 1) 

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D. ’633 patent 

7. “mobile protection code” (claims 1, 8, 13, 14) 

8. “determining ... whether the downloadable-information includes executable code” 

(claim 1, 8, 13) 

9. Indefiniteness (claim 14): 

a. “A computer program product, comprising a computer usable medium having a 

computer readable program code therein, the computer readable program code adapted 

to be executed for computer security, the method comprising:” 

b. “A computer program product, comprising a computer usable medium having a 

computer readable program code therein, the computer readable program code adapted 

to be executed for computer security, the method comprising: providing a system...; 

receiving ...; and causing ...” 

10. “causing mobile protection code to be executed by the mobile code executor at a 

downloadable-information destination” (claim 14) 

IV. PATENT L.R. 4-3(d): TIME FOR CLAIM CONSTRUCTION HEARING. 

The parties anticipate that they will not require more than three (3) hours for the entire claim 

construction hearing. 

V. PATENT L.R. 4-3(e): WITNESSES AT CLAIM CONSTRUCTION HEARING. 

Finjan’s Statement: 

Finjan intends to offer a declaration and may present live witness testimony from Dr. Nenad 

Medvidovic, University of Southern California, 941 Bloom Walk, Los Angeles, CA 90089, regarding a 

tutorial of the relevant technology, the technical background of the asserted patents, the qualifications 

of one of skill in the art at the time of the inventions, how the above terms are understood by one of 

skill in the art, and to support Finjan’s claim construction positions. Furthermore, Dr. Nenad 

Medvidovic will and rebut any testimony or opinions offered by Defendant’s expert witness. 

Defendant’s Statement:

Cisco intends to offer a declaration and may present live witness testimony from Dr. Paul 

Clark, Secure Methods, Inc., 4705 Broad Brook Drive, Bethesda, Maryland 20814, regarding a tutorial 

of the relevant technology, the technical background of the asserted patents, the qualifications of one 

of skill in the art at the time of the inventions, how the above terms are understood by one of skill in 

Case 5:17-cv-00072-BLF Document 85 Filed 11/20/17 Page 12 of 14
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JOINT CLAIM CONSTRUCTION CASE NO. 5:17-cv-00072-BLF-SVK 

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the art, and to support Cisco’s claim construction positions. Furthermore, Dr. Paul Clark will rebut any 

testimony or opinions offered by Finjan’s expert witness. 

Respectfully submitted, 

Dated: November 20, 2017 By: /s/ Lisa Kobialka 

Paul J. Andre (State Bar No. 196585) 

Lisa Kobialka (State Bar No. 191404) 

James Hannah (State Bar No. 237978) 

KRAMER LEVIN NAFTALIS 

& FRANKEL LLP 

990 Marsh Road 

Menlo Park, CA 94025 

Telephone: (650) 752-1700 

Facsimile: (650) 752-1800 

pandre@kramerlevin.com 

lkobialka@kramerlevin.com 

jhannah@kramerlevin.com 

Attorneys for Plaintiff 

FINJAN, INC. 

Respectfully submitted, 

Dated: November 20, 2017 By: /s/ Jarrad M. Gunther 

Patrick S. Salceda 

Email: psalceda@duanemorris.com 

Duane Morris LLP 

One Market Plaza 

Spear Tower, Suite 2200 

San Francisco, CA 94105 

Telephone: 415.957.3000 

Facsimile: 650.618.2713 

L. Norwood Jameson (admitted pro hac vice) 

Email: wjameson@duanemorris.com 

Matthew C. Gaudet (admitted pro hac vice) 

Email: mcgaudet@duanemorris.com 

David C. Dotson (admitted pro hac vice) 

Email: dcdotson@duanemorris.com 

Jennifer H. Forte (admitted pro hac vice) 

Email: jhforte@duanemorris.com 

Duane Morris LLP 

1075 Peachtree Street, Ste. 2000 

Atlanta, GA 30309 

Telephone: 404.253.6901 

Facsimile: 404.253.6901 

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Joseph A. Powers (admitted pro hac vice) 

Email: japowers@duanemorris.com 

Jarrad M. Gunther (admitted pro hac vice) 

Email: jmgunther@duanemorris.com 

Duane Morris LLP 

30 South 17th Street 

Philadelphia, PA 19103 

Telephone: 215.979.1000 

Facsimile: 215.979.1020 

Counsel for Defendant Cisco Systems, Inc. 

ATTESTATION 

In accordance with Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this 

document has been obtained from any other signatory to this document. 

/s/ Lisa Kobialka 

 Lisa Kobialka 

Case 5:17-cv-00072-BLF Document 85 Filed 11/20/17 Page 14 of 14