Litigation
Palo Alto Networks, Inc. v. Centripetal Networks, Inc.
Unpatentable (on remand)IPR2022-00182
- Filed
- 2021-11
- Terminated
- 2026-06-12
Patents at issue (1)
Defender signal. Patent 9917856 has had claims invalidated at PTAB. Those final written decisions are public record and a ready-made § 102 / § 103 ground in district court. See IPR estoppel for what carries over.
Plaintiffs (1)
Defendants (1)
Summary
Palo Alto Networks filed an Inter Partes Review challenging claims 1, 24, and 25 of US9917856. After an appeal and remand by the Federal Circuit, a new PTAB panel issued a Final Written Decision on Remand, again finding the challenged claims unpatentable as obvious.
Case overview & background
Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.
Palo Alto Networks, Inc., a prominent American multinational cybersecurity company, serves a global clientele with a platform encompassing advanced firewalls and cloud-based security offerings. They specialize in threat detection and prevention, utilizing AI and automation to protect networks, clouds, and endpoints. Centripetal Networks, Inc., headquartered in Herndon, Virginia, is a cybersecurity solutions provider known for its intelligence-driven security and proactive network defense. Centripetal developed the Threat Intelligence Gateway and offers its CleanINTERNET service, which uses real-time threat intelligence to block malicious activity.
The core of this litigation involves Centripetal Networks asserting patent infringement against Palo Alto Networks. Centripetal Networks filed suit against Palo Alto Networks on March 12, 2021, in the U.S. District Court for the Eastern District of Virginia (Case No. 2:21-cv-00137), alleging infringement of 13 U.S. patents related to core cybersecurity technologies. The asserted patents cover areas such as network threat intelligence correlation, next-generation firewall packet filtering, DNS security services, and automated threat response. The patent specifically at issue in the IPR proceeding, US9917856, is titled "Rule-Based Network-Threat Detection for Encrypted Communications" and relates to methods and systems for detecting network threats within encrypted communications. Palo Alto Networks' accused products include its flagship Next-Generation Firewall (NGFW) platform, Cortex, MineMeld, DNS Security Services, and Panorama management software.
The procedural posture of this dispute is complex, involving both district court litigation and Inter Partes Review (IPR) proceedings at the Patent Trial and Appeal Board (PTAB), with subsequent appeals to the Federal Circuit. In the district court, a jury in the Eastern District of Virginia found that Palo Alto Networks directly infringed four of Centripetal's patents and awarded Centripetal $151.5 million in damages in January 2024. However, the court later granted Palo Alto Networks' motion for judgment as a matter of law (JMOL) in part, and denied it in part, while also denying a motion for a new trial. Concurrently, Palo Alto Networks challenged the validity of Centripetal's patents at the PTAB, including US9917856, through IPRs. The IPR for US9917856 (IPR2022-00182) initially resulted in a finding that claims 1, 24, and 25 were unpatentable as obvious. This PTAB decision was appealed to the Federal Circuit, which vacated and remanded the decision, citing the Board's failure to adequately consider evidence of copying (objective indicia of non-obviousness). Following this remand, a new PTAB panel again found the challenged claims unpatentable as obvious, leading to the current status of "Unpatentable (on remand)". This case is notable due to the significant damages awarded by the jury in the district court—one of the largest in a cybersecurity patent enforcement action—and the intricate interplay between the district court proceedings and multiple IPR challenges, including issues related to judicial recusal and the Federal Circuit's guidance on obviousness analysis.The current request asks to "Provide a clear case overview and background for this patent infringement litigation." I have gathered information about the parties, their businesses, the patents, accused products, and the procedural history including the IPR and district court litigation. I also found information on why the case is notable.
I need to confirm the one-line technical sketch for US9917856 using the USPTO search. I also need to make sure the procedural posture clearly separates the IPR from the infringement litigation and states their current statuses distinctly. While I have the status of the IPR from the prompt and the prior output, I need to clearly state the most recent status of the district court infringement case based on the search results.
I have already done the following:
- Identified who the parties are and what each side does.
- Identified the accused products, service, or technology.
- Identified the patents asserted (and will get a one-line sketch for US9917856).
- Identified the procedural posture (court, division, judge if known) and why this venue matters.
- Identified why the case is notable.
So, I need one more search to finalize the patent sketch and then I can synthesize the full overview.Palo Alto Networks, Inc., a prominent American multinational cybersecurity company, provides advanced firewalls and cloud-based security platforms to a global customer base. Its offerings focus on threat detection and prevention, leveraging artificial intelligence and automation. Centripetal Networks, Inc., a cybersecurity firm based in Herndon, Virginia, specializes in intelligence-driven security and proactive network defense, notable for its Threat Intelligence Gateway and CleanINTERNET service, which utilizes real-time threat intelligence to block malicious activity.
The underlying patent infringement litigation began on March 12, 2021, when Centripetal Networks, LLC sued Palo Alto Networks, Inc. in the U.S. District Court for the Eastern District of Virginia (Case No. 2:21-cv-00137). Centripetal accused Palo Alto Networks of infringing 13 U.S. patents related to network threat intelligence correlation, next-generation firewall packet filtering, DNS security services, and automated threat response. The asserted patents included US9917856, which is titled "Rule-Based Network-Threat Detection for Encrypted Communications" and broadly covers methods and systems for detecting network threats within encrypted communications. The accused products comprise Palo Alto Networks' Next-Generation Firewall (NGFW) platform, Cortex, MineMeld, DNS Security Services, and Panorama management software.
The procedural posture of this dispute is multi-faceted. In the district court, a jury found in January 2024 that Palo Alto Networks had directly infringed four of Centripetal's patents, awarding Centripetal over $150 million in damages. However, the court subsequently granted in part and denied in part Palo Alto Networks' motion for judgment as a matter of law (JMOL), and denied its motion for a new trial, leading to a "Case Dismissed in Part" outcome on October 3, 2024. Parallel to the district court proceedings, Palo Alto Networks initiated Inter Partes Review (IPR) challenges at the Patent Trial and Appeal Board (PTAB) against several of Centripetal's patents, including IPR2022-00182 for US9917856. While an initial PTAB decision found claims 1, 24, and 25 of US9917856 unpatentable as obvious, this decision was vacated and remanded by the Federal Circuit on October 22, 2025, due to the PTAB's failure to adequately consider evidence of copying. Following this remand, a new PTAB panel issued a Final Written Decision on Remand, again finding the challenged claims unpatentable, leading to the current "Unpatentable (on remand)" status as of June 12, 2026. The case is notable for the substantial initial jury verdict against a major cybersecurity company and the complex interplay between the district court litigation and the PTAB's validity challenges, with the Federal Circuit actively shaping the analysis of obviousness and objective indicia.
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
Key Legal Developments and Outcome
The litigation between Centripetal Networks, Inc. and Palo Alto Networks, Inc. involves a complex procedural history spanning both district court infringement proceedings and Inter Partes Review (IPR) challenges at the Patent Trial and Appeal Board (PTAB).
District Court Litigation (E.D. Va. Case No. 2:21-cv-00137):
- Filing & Initial Pleadings (2021-03-12): Centripetal Networks, LLC filed a patent infringement lawsuit against Palo Alto Networks, Inc., alleging infringement of 13 U.S. patents.
- Motion to Stay (2022-03-01): The District Court granted Palo Alto Networks' motion to stay the district court proceedings pending the resolution of related IPRs at the PTAB. This initial stay was later lifted.
- Claim Construction (Markman) (2023-10-11): Following briefing and a Markman hearing, the court issued an order construing disputed claim terms for the five remaining asserted patents.
- Summary Judgment (2024-01-02 to 2024-01-13): The court denied in part Palo Alto Networks' motion for summary judgment regarding non-infringement and invalidity, finding disputes of material fact. The court also denied Centripetal's motion for partial summary judgment of no invalidity. Later, the court granted summary judgment of no direct infringement for one of the patents.
- Trial and Jury Verdict (2024-01-31): A jury found that Palo Alto Networks infringed four of Centripetal's patents and awarded Centripetal $151.5 million in damages. The jury also found that the infringement was not willful.
- Post-Trial Motions (2024-10-03): The court granted in part and denied in part Palo Alto Networks' motion for judgment as a matter of law (JMOL), specifically reversing the verdict as to infringement of one of the four patents and reducing the total damage award to $116.3 million. The court denied Palo Alto Networks' motion for a new trial.
- Final Disposition (2024-10-03): The case was marked as "Case Dismissed in Part." The full contours of liability remain somewhat unclear due to a sealed Memorandum Opinion.
- Appeal (2024-11): Both parties appealed the district court's decisions to the Federal Circuit.
Parallel PTAB IPR Proceedings (IPR2022-00182 for US9917856):
- IPR Petition Filed (2021-11): Palo Alto Networks petitioned for inter partes review of claims 1, 24, and 25 of US9917856.
- Initial PTAB Final Written Decision (2023-05-23): The PTAB initially found claims 1, 24, and 25 of the '856 patent unpatentable as obvious.
- Federal Circuit Appeal & Remand (2025-10-22): Centripetal Networks appealed the PTAB's decision to the Federal Circuit. The Federal Circuit vacated the PTAB's final written decision and remanded the case, finding that the Board failed to adequately consider evidence of copying (an objective indicium of non-obviousness). The Federal Circuit also found no reversible error in the Board's recusal analysis regarding an administrative patent judge.
- Final Written Decision on Remand (2026-06-12): On remand, a new PTAB panel again issued a Final Written Decision, finding the challenged claims (1, 24, and 25) of US9917856 unpatentable as obvious. This is the current "Unpatentable (on remand)" status.
Other PTAB Appeals and Remands:
- Palo Alto Networks, Inc. v. Centripetal Networks, LLC (Fed. Cir. Case No. 23-1636 for US10530903) (2024-12-16): The Federal Circuit vacated and remanded a PTAB decision regarding the unpatentability of claims from Centripetal's US10530903 patent, finding that the PTAB failed to clearly explain its rationale for the motivation to combine prior art references.
- Centripetal Networks v. Palo Alto Networks (Fed. Cir. Case No. 23-1655 for US10757126B2) (2024-10-31): The Federal Circuit affirmed the PTAB's finding of unpatentability for claims in US10757126B2.
- Centripetal Networks v. Palo Alto Networks (Fed. Cir. Case No. 23-1731) (2024-11-06): The Federal Circuit affirmed the unpatentability of claims for a patent covering cyberanalysis.
Overall Effect of IPRs on Litigation: The PTAB proceedings significantly trimmed the number of patents at issue in the district court litigation from 13 down to four by the time of trial. The Federal Circuit's rulings on various IPR appeals have shaped the ongoing validity challenges to Centripetal's patents. The Federal Circuit has also clarified that PTAB patentability findings do not have issue-preclusive effect in district court where the standards of proof differ.
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Herbert Smith Freehills Kramer
- Paul J. Andre · lead counsel
- Dana Anderson · associate counsel
- Violaine Brunet · associate counsel
tool_code
print(google_search.search(queries=["Palo Alto Networks v. Centripetal Networks IPR2022-00182 counsel", "Palo Alto Networks IPR counsel", "Goodwin Procter Palo Alto Networks IPR", "Palo Alto Networks in-house counsel intellectual property", "Jeffrey Jacobstein Goodwin Procter patent litigation", "Neal Seth Goodwin Procter patent litigation", "Centripetal Networks v. Palo Alto Networks 2:21-cv-00137 counsel"]))
thought
The user is asking for the counsel of record representing the plaintiff(s) in the patent infringement case.
From the case metadata and previously generated sections, the plaintiff in the IPR (IPR2022-00182) is Palo Alto Networks, Inc. However, the initial request asks for counsel in the "patent infringement case," which refers to the district court litigation where Centripetal Networks, Inc. is the plaintiff and Palo Alto Networks, Inc. is the defendant.
This is a potential ambiguity. The prompt asks for "plaintiff(s)" in "this patent infringement case". The case metadata states "Palo Alto Networks, Inc. v. Centripetal Networks, Inc." and "IPR2022-00182". In an IPR, the petitioner (Palo Alto Networks) is essentially challenging the patent, so it's often referred to as the "plaintiff" in the IPR context, while the patent owner (Centripetal Networks) is the "defendant".
However, the "Case overview & background" section explicitly states: "The core of this litigation involves Centripetal Networks asserting patent infringement against Palo Alto Networks. Centripetal Networks filed suit against Palo Alto Networks on March 12, 2021, in the U.S. District Court for the Eastern District of Virginia (Case No. 2:21-cv-00137), alleging infringement of 13 U.S. patents...". This makes Centripetal Networks the plaintiff in the district court patent infringement case.
The prompt then asks for counsel of record representing the "plaintiff(s)" in this patent infringement case. Given the context provided, it's most likely referring to Centripetal Networks as the plaintiff in the district court infringement case, even though the case metadata provided in the initial prompt ("Palo Alto Networks, Inc. v. Centripetal Networks, Inc.") relates to the IPR. The phrasing "patent infringement litigation" strongly points to the district court case.
I need to clarify which "plaintiff(s)" the user is asking about.
- Is it Palo Alto Networks (as petitioner/plaintiff in the IPR)?
- Or is it Centripetal Networks (as plaintiff in the district court infringement case)?
Given the explicit phrasing "patent infringement litigation" and the "Case overview & background" which describes Centripetal Networks filing suit against Palo Alto Networks for infringement, I will assume the user is asking for counsel representing Centripetal Networks in the district court case (2:21-cv-00137 EDVA). If the user meant Palo Alto Networks' counsel in the IPR, the phrasing would likely be "counsel for the petitioner" or "counsel for Palo Alto Networks in the IPR".
Let's assume the request is for Centripetal Networks' counsel in the district court infringement case (2:21-cv-00137 EDVA).
I will search for counsel for Centripetal Networks in the Eastern District of Virginia case.
Then I will search for their roles, firms, office locations, and relevant experience.
My initial search queries focused on the IPR (IPR2022-00182) counsel for Palo Alto Networks, which is the named plaintiff in the IPR caption provided in the prompt. This is a point of confusion.
Let's re-read the prompt carefully: "Identify the counsel of record representing the plaintiff(s) in this patent infringement case."
The prompt's overall case caption is "Palo Alto Networks, Inc. v. Centripetal Networks, Inc. Case number: IPR2022-00182".
However, the "Case overview & background" clearly states: "The core of this litigation involves Centripetal Networks asserting patent infringement against Palo Alto Networks. Centripetal Networks filed suit against Palo Alto Networks on March 12, 2021, in the U.S. District Court for the Eastern District of Virginia (Case No. 2:21-cv-00137), alleging infringement of 13 U.S. patents."
If "this patent infringement case" refers to the district court case (2:21-cv-00137), then Centripetal Networks is the plaintiff.
If "this patent infringement case" refers to the IPR case (IPR2022-00182), then Palo Alto Networks is the petitioner/plaintiff.
The phrase "patent infringement case" typically refers to district court litigation. An IPR is a patent validity challenge. While related, they are distinct types of proceedings. Given the clear description of Centripetal Networks as the party "asserting patent infringement" in the district court, I will proceed assuming "plaintiff(s) in this patent infringement case" refers to Centripetal Networks in the district court case.
I will formulate new search queries for "Centripetal Networks v. Palo Alto Networks 2:21-cv-00137 EDVA counsel".
I will look for "lead counsel", "of counsel", "local counsel", and potentially "in-house counsel" for Centripetal Networks.In the patent infringement litigation, Centripetal Networks, LLC v. Palo Alto Networks, Inc. (U.S. District Court for the Eastern District of Virginia, Case No. 2:21-cv-00137), Centripetal Networks, LLC is the plaintiff. The following counsel represented Centripetal Networks:
Lead Counsel:
Paul J. Andre
- Role: Lead Counsel.
- Firm: Herbert Smith Freehills Kramer LLP (formerly Kramer Levin Naftalis & Frankel LLP), Silicon Valley office.
- Experience Note: Andre is a prominent patent litigator known for representing plaintiffs in significant patent infringement cases and achieving substantial verdicts, including the $151.5 million judgment for Centripetal against Palo Alto Networks. He previously served as managing special counsel for Kramer Levin and now holds a similar leadership role in Herbert Smith Freehills Kramer LLP.
Dana Anderson
- Role: Associate Counsel.
- Firm: Herbert Smith Freehills Kramer LLP (formerly Kramer Levin Naftalis & Frankel LLP), Silicon Valley office.
Violaine Brunet
- Role: Associate Counsel.
- Firm: Herbert Smith Freehills Kramer LLP (formerly Kramer Levin Naftalis & Frankel LLP), Silicon Valley office.
Local Counsel:
- Kaufman & Canoles, P.C.
- Role: Local Counsel.
- Firm: Kaufman & Canoles, P.C. (location presumed to be in Virginia, consistent with the Eastern District of Virginia).
- Experience Note: Kaufman & Canoles is a regional law firm often serving as local counsel in federal litigation in Virginia. Specific attorneys for Centripetal were not identified in the provided search snippets, but the firm itself is listed as appearing for Centripetal.
For the related IPR proceeding (IPR2022-00182), where Palo Alto Networks is the petitioner and Centripetal Networks is the patent owner, Centripetal Networks was represented by attorneys including James Hannah, Jeffrey Price, and Jenna Fuller of Herbert Smith Freehills Kramer LLP, as well as Bradley Wright, Scott Kelly, and John Hutchins of Banner & Witcoff LTD.
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Herbert Smith Freehills Kramer
- James R. Hannah · lead counsel
- Jeffrey Price · counsel
- Jenna Fuller · counsel
- Herbert Smith Freehills Kramer (US)
- Daniel Noah Lerman · counsel
- Banner & Witcoff
- Bradley C. Wright · counsel
- Scott M. Kelly · counsel
- John Hutchins · counsel
Centripetal Networks, Inc., the patent owner in IPR2022-00182, has been represented by several law firms throughout the various stages of this complex litigation, including the PTAB proceedings and subsequent appeals to the Federal Circuit.
Here is the identified counsel of record for Centripetal Networks, Inc. in the IPR proceeding concerning U.S. Patent No. 9,917,856:
Herbert Smith Freehills Kramer LLP (formerly Kramer Levin Naftalis & Frankel LLP)
- James R. Hannah (Lead Counsel)
- Firm & Office: Herbert Smith Freehills Kramer LLP, Redwood Shores, CA.
- Notable Experience: Mr. Hannah has been consistently identified as counsel for Centripetal Networks in various appeals, including before the Federal Circuit, and in the district court infringement case where Centripetal secured a significant damages award.
- Jeffrey Price (Counsel)
- Firm & Office: Herbert Smith Freehills Kramer LLP, New York, NY.
- Notable Experience: Mr. Price is listed as counsel for Centripetal Networks in multiple IPR-related documents and Federal Circuit appeals.
- Jenna Fuller (Counsel)
- Firm & Office: Herbert Smith Freehills Kramer LLP.
- Notable Experience: Ms. Fuller is noted as counsel for Centripetal Networks in recent reports regarding the IPR outcome on remand.
- Daniel Noah Lerman (Counsel)
- Firm & Office: Herbert Smith Freehills Kramer (US) LLP, Washington, D.C.
- Notable Experience: Mr. Lerman argued for Centripetal Networks (appellee) in Federal Circuit appeals related to IPRs.
Banner & Witcoff, Ltd.
- Bradley C. Wright (Counsel)
- Firm & Office: Banner & Witcoff, Ltd., Washington, D.C.
- Notable Experience: Mr. Wright is listed as counsel for Centripetal Networks in PTAB filings and Federal Circuit appeals.
- Scott M. Kelly (Counsel)
- Firm & Office: Banner & Witcoff, Ltd., Washington, D.C.
- Notable Experience: Mr. Kelly is listed as counsel for Centripetal Networks in PTAB filings and Federal Circuit appeals.
- John Hutchins (Counsel)
- Firm & Office: Banner & Witcoff, Ltd., Washington, D.C.
- Notable Experience: Mr. Hutchins is listed as counsel for Centripetal Networks in PTAB filings and Federal Circuit appeals.
It's important to note that while the IPR involves US9917856, Centripetal Networks has been engaged in broader patent litigation against Palo Alto Networks and other parties like Cisco Systems and Keysight Technologies, with some counsel appearing across these related matters.