Free Proposed Pretrial Order - District Court of Delaware - Delaware

Case 1:04-cv-01199-SLR

Document 465-12

Filed 10/06/2006

Page 1 of 3

SRI v. ISS and Symantec Exhibit 11 to the Proposed Pre-Trial Order WITNESSES SRI INTENDS TO CALL TO TESTIFY EITHER IN PERSON OR BY DEPOSITION PURSUANT TO LR 16-4(d)(7) SRI anticipates putting on its case-in-chief on the issue of infringement by both defendants in an efficient manner. To that end, SRI intends to call the following witnesses either "live" or by deposition in its case-in-chief. SRI cannot anticipate all of the objections and issues that may arise as SRI presents its case. SRI expects to call fewer witnesses. Those witnesses whose names are followed by "(SRI)" can be reached through counsel for SRI. The names of individuals affiliated with each defendant or who were represented at deposition by defendants' counsel are followed by "(Symantec)" or "(ISS)" and can presumably be reached through litigation counsel. SRI also reserves the right to call anyone appearing on either of Symantec's or ISS's witness lists. Patrick Lincoln (SRI) Phillip Porras (SRI) Alfonso Valdes (SRI) George Kesidis (expert) . 692 Tanager Drive State College, PA 16803 (814) 238-1516 Specialty: Cyber security and network intrusion detection Paul Griswold (ISS) Robert McEwin (ISS) Bernard Palmer (ISS) Jim Pruss (ISS) Holly Stewart (ISS) Peter Tosto (ISS) Paul Agbabian (Symantec) Mark Bagley (Symantec) Jeremy Bennett (Symantec) Robert Geiger (Symantec) Grant Geyer (Symantec)

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Case 1:04-cv-01199-SLR

Document 465-12

Filed 10/06/2006

Page 2 of 3

Brian Hernacki (Symantec) Howard Lev (Symantec) William Luk (Symantec) Edward Taranto (Symantec) Robert Allen 462 South Fourth St. Suite 1100 Louisville, Kentucky 40201 Robert Ferrill One HealthSouth Parkway Birmingham, Alabama 35243 Andrew Gault 1610 Morningside Ave. Pittsburgh, PA 15206 Douglas Song 1290 Bardstown Trail Ann Arbor, Michigan 48105 SRI' s rebuttal case on the issues of validity and enforceability will be responsive to the evidence presented by defendants. Defendants have identified nearly 300 prior art references and have articulated various theories of unenforceability. Moreover, because this list of witnesses is being exchanged simultaneously with defendants, SRI is unable to know from which witnesses it will be able to elicit testimony on cross examination. As such, SRI cannot accurately identify the witnesses it may call either live or by deposition in its rebuttal case. SRI identifies the following individuals which it may call in its rebuttal case, but expects to call far fewer witnesses. Richard Abramson (SRI) Keith Skinner (SRI) Robert Graham (ISS) Jim Innes (ISS) Joe Kleinwaechter (ISS) Thomas Noonan (ISS) Sandeep Kumar (Symantec) Enrique Salem (Symantec) Col. Timothy Gibson 4109 John Trammel Court Fairfax, Virginia 22030

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Case 1:04-cv-01199-SLR

Document 465-12

Filed 10/06/2006

Page 3 of 3

Y. Frank Jou 214 Coltsgate Drive Cary, North Carolina 27511 Theresa Lunt 892 Bruce Drive Palo Alto, California 94303 Michael Skroch Sandia National Laboratories, New Mexico P.O. Box 5800 Albuquerque, New Mexico 87185 Carl Wright 2352 Cypress Cove Circle Unit C Herndon, Virginia 20171

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