Free Redacted Document - District Court of Delaware - Delaware

Case 1:04-cv-01199-SLR Document 318-15 Filed 06/23/2006 Page 1 014

Case 1:04-cv-01199-SLR Document 318-15 Filed 06/23/2006 Page 2 of 4
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I IN THE UNITED STATES DISTRICT COURT
I 2 EGR THE DISTRICT OF DELAWARE
3
I 4 SRI INTERNATIONAL, INC., a
California Corporation,
5
I Plaintiff,
5
va- Case No. 04»l199—SLR
I 7
INTERNET SECURITY SYSTEMS,
8 TNC., a Delaware
I corporation, INTERNET
9 SECURITY SYSTEMS, INC., a
I Georgia corporation, and
IO SYMANTEC CORPORATION, a
Delawaxe coxpozation,
I ll
Qefendante.
T2 J
I 13
14 Deposition of
I E5 FREDERICK M. AVQLIO
16 May 18, 2006
I?
I 18
19
20 Reported by
I John Wisaenbach, CSR 6862
21
I 22 SHAFT MOSS & ASSOCIATES
Certified Shorthand Reporters
23 $10 Sutter Street, Suite 607
I San Francisco, California 94104
Z4 {415) 402~0004
{550) 692~8900
I 25 SAX: {415) 402-0005

Case 1:04-cv-01199-SLR Document 318-15 Filed 06/23/2006 Page 3 of 4
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I 75
I l Q. And "applicatien gateway" is another term
2 that you use te refer tc semething that’S referred
I 3 te by others as a proxy server?
4 A. That’s correct.
I 5 Q. Okay. So a proxy server weuld be another
6 type of firewall, distinct from a packet filter?
I 7 A. Yes, in —- in firewalling terms. lhere
B are —— I meas, there may be other uses ef the term.
I 9 But in computer and network security, application
EO gateway is a mechanism for firewalling, eee could
I ll say a type of firewall, alas called a prexy firewall
I 12 er employing proxy servers.
13 Q. Se that —— and then there was a third type
I le that yes mention here: hybrids. Those would be
15 firewalls that implement some combination of packet
I 16 filtering and proxy servers?
37 A. That's correct-
I 18 Q. 50 would you agree, then, as ef November
l9 1998, at least, that not all firewalls were
I 20 proxy-based firewalls?
I 21 A. That's correct.
22 Q. And would you also agree that as of
I 23 November 1998, not all, quote~snquete, prexy servers
Z5 were firewalls?
I 25 A. That’s correct.
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Case 1:04-cv-01199-SLR Document 318-15 Filed 06/23/2006 Page 4 of 4
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| 94
I CERTIFICATE O? RE?ORTER
I 2 I, JOHN WISSENBACH, a Certified Shorthand
l 3 Reporter, hereby certify that the witness in the
Q foregoing deposition was by me duly sworn to tell
I 5 the truth, the whole truth, and nothing but the
6 truth in the within—entitled cause;
I 7 That said deposition was taken down in
8 shorthand by me, a disinterested person, at the time
I 9 and place therein stated, and that tee testimony of
10 the said witness was thereafter reduced to
I il_ typewritinq, by computer, under my direction and
I 12 supervision;
13 That before completion of the deposition,
I IQ review of the transcript [ ] was [X] was not
15 requeeted. if requested, any changes made by the
I I6 deponent (and provided to the reporter) during the
I? period allowed are appended hereto.
I IB I further certify that I am not of counsel
19 or attorney for either or any of the parties to the
l 20 said deposition, nor in any way interested in the
22 event of this cause, and that I am not related to
l 22 any of the parties thereto.
I 23 Umm:
24
I 25 JOHN WISSENBACH, CSR eo. 6852
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