Free Redacted Document - District Court of Delaware - Delaware


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Date: June 26, 2006
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Category: District Court of Delaware
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Case 1 :04-cv-01 199-SLR Document 323 Filed 06/26/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SRI INTERNATIONAL, INC., a California
C0‘POmUO“> Civil Action No. 04-CV—1 199 (SLR)
Plaintiff and
Counterclaim-Defendant, FILED UNDER SEAL
v_ THIS DOCUMENT CONTAINS MATERIALS
WHICH ARE CONFIDENTIAL OR
INTERNET SECURITY SYSTEMS, INC., a RESTRICTED CONFIDENTIAL - SOURCE
Delaware corporation, INTERNET _ CODE AND COVERED BY A PROTECTIVE
SECURITY SYSTEMS, INC., 3 G€0fg18 ORDER. THIS DOCUMENT SHALL NOT BE
¢<>rp<>t¤¤<>¤» wd SYMANTEC _ MADE AVAILABLE TO ANY r>ERsoN
3 D€l&W3I`C COI`pOI`3tlOl'1,
Defendants and COumcrClaim_ COUNSEL OF RECORD FOR THE PARTIES.
Plaintiffs.
DECLARATION OF PAUL S. GREWAL IN SUPPORT OF SYMANTEC
CORPORATION’S MOTION FOR SUMMARY JUDGMENT OF NON-
INFRINGEMENT
I, Paul S. Grewal, declare as follows:
1. I am a member of the law firm of Day Casebeer Madrid & Batchelder LLP, counsel for
Defendant Symantec Corporation. I am admitted to practice law before all courts of the State of
California.
2. I make this declaration of my own personal knowledge. If called to testify as to the truth
of the matters stated herein, I could and would do so competently. I
3. Attached hereto as Exhibit A is a true and correct copy of U.S. Patent No. 6,321,338.
4. Attached hereto as Exhibit B is a true and correct copy of U.S. Patent No. 6,708,212.
5. Attached hereto as Exhibit C is a true and correct copy of U.S. Patent No. 6,484,203.

Case 1:04-cv-01199-SLR Document 323 Filed 06/26/2006 Page 2 of 3
6. Attached hereto as Exhibit D is a true and correct copy of U.S. Patent No. 6,711,615.
7. Attached hereto as Exhibit E is a true and correct copy of selected pages of the 5/26/06
and 5/27/06 deposition transcripts of Dr. George Kesidis.
8. Attached hereto as Exhibit F is a true and correct copy of the Declaration of Dr. Jeffery
Hansen.
9. Attached hereto as Exhibit G is a true and correct copy of the Expert Report of Dr.
George Kesidis on Infringement.
10. Attached hereto as Exhibit H is a true and correct copy of selected pages of the deposition
transcript of Dr. Jeffery Hansen.
11. Attached hereto as Exhibit I is a true and correct copy of selected pages of the deposition
transcript of Brian Hemacki.
12. Attached hereto as Exhibit J is a true and correct copy of selected pages of the deposition
transcript of Jeremy Bennett.
13. Attached hereto as Exhibit K is a true and correct copy of selected pages of the deposition
transcript of Howard Lev.
14. Attached hereto as Exhibit L is a true and correct copy of selected pages of the deposition
transcript of Tasha Van Es.
15. Attached hereto as Exhibit M is a true and correct copy of Mike Smith and Mark
J anczura, Draft Architecture / Process List Design Doc. For SNS 5.0, modified August 5, 2005 bearing
BATES Production Nos.: SYM_P__0136893-0136916.
16. Attached hereto as Exhibit N is a true and correct copy of a Recourse Technologies Q&A
document regarding ManHunt 2.0 bearing BATES Production Nos.: SYM_P_0176251-0176253.
17. Attached hereto as Exhibit O is a true and correct copy of M. Lyle and Brandon Suzuki,

=01·e199-SLR Document 323 Filed 06/26/2006 Page 3 of 3
· Recourse Technologies, F1owChaser Data Store (F DS) Specification, modified July 1, 2002 bearing
BATES Production Nos.: SYM_P__0134095—0134099. e A
18. Attached hereto as Exhibit P is a true and correct copy ofthe Declaration of Jeremy F.
Bennett.
19. Attached hereto as Exhibit Q is a true and correct copy of the Declaration of Brandon
Suzuki.- ‘
20. Attached hereto as Exhibit R is a true and correct copy of selected pages of the deposition Q
transcript of Paul Agbabian. .
21. Attached hereto as Exhibit S is a true and correct copy of the deposition transcript of
Carolyn Bardani.
1 declare under penalty of perjury under the laws of the United States that the foregoing is true
and correct to the best of my knowledge. l
Dated: June 16, 2006
Bw ‘
_ Paul S. Lrrewal