Finjan LLC v. Palo Alto Networks, Inc.

Background

Finjan asserted four patents against Palo Alto Networks, Inc. The patents concern computer-security techniques, including scanning files for malicious software, monitoring potentially harmful code in a protected environment, inspecting dynamically generated executable code, and analyzing incoming content for potential exploits.

The order addressed claim construction, which is the court’s process for defining the meaning and scope of patent-claim language. The parties had agreed on several terms and asked the court to resolve seven additional terms at that stage. The court also granted Palo Alto Networks’ motion for leave to submit supplemental claim-construction authority and considered that material and additional material submitted by Finjan.

Rulings on the Patent Terms

The court adopted the parties’ seven stipulated constructions, without prejudice to later consideration of whether wording should be clarified or simplified for jury instructions. It also accepted the parties’ agreements concerning two additional terms:

- “Mobile protection code” means “code that, at runtime, monitors or intercepts actually or potentially malicious code operations without modifying the executable code.” - “Lexical constructs for the specific programming language” required no construction beyond its plain and ordinary meaning at that stage.

For the contested terms, the court ruled as follows:

- “File cache” means “a memory for temporarily holding a file.” - “Incoming files from the Internet” received no additional construction beyond its plain and ordinary meaning. The court rejected Palo Alto Networks’ proposed limitation that the files must have been requested by an intranet computer. - The preamble of claim 14 of the ’633 patent was corrected by deleting “the method,” leaving a computer-program-product claim. The court rejected Palo Alto Networks’ argument that the claim was indefinite because it claimed mixed statutory subject matter. The ruling was without prejudice to a later argument that the claim is invalid under computer-readable-media claim law or on another basis. The court did not decide whether dependent claims referring to “the method of claim 14” are invalid or can also be corrected. - “Downloadable-information destination” means “user device that includes one or more devices or processes that are capable of receiving and initiating or otherwise hosting a mobile code execution.” - “Parse tree” means “a hierarchical structure of interconnected nodes built from scanned content.” This stipulated construction was adopted without prejudice to later clarification or simplification for jury instructions. - “Programming language” required no further construction. The court rejected Palo Alto Networks’ argument that the term was indefinite because the patent’s dependent claims identify a universal resource indicator and hypertext markup language as specific programming languages. - “Content” means “data or information, which has been modified and is received over a network.” - “Content processor” means “a processor that processes modified content.” The court rejected Palo Alto Networks’ proposed additional limitation requiring the processor to be an application located on the protected client computer.

Effect of the Order

The court stated that the stipulated and contested patent terms would be defined as set out in the order. The order resolved claim-meaning disputes for the case; it did not enter a ruling on infringement, damages, or the ultimate validity of the asserted patents.