`DECLARATION OF SCO1T J. COONAN
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`I .
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`I am employed by Juniper Networks, Inc. ("Juniper"). I have been employed with
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`Juniper since 2004 and currently hold the title of Senior Director ofIP, Litigation & Strategy. I have
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`personal knowledge of the facts set forth in this Declaration and, if called as a witness, could and
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`would testify competently to such facts under oath.
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`2.
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`In July 2014, Finjan, Inc. ("Finjan") reached out to Juniper and asked Juniper to take a
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`license to Finjan' s patent portfolio. It also provided Juniper with an "exemplary" claim chart for U.S.
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`Patent No. 6,965,968 ("'968 Patent''), and asked Juniper to enter into an NOA. This is the only claim
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`chart that Finjan ever provided to Juniper before Finjan sued Juniper.
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`3.
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`Juniper informed Finjan it did not want to enter into an NOA. In addition, on February
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`13, 2015, I provided Finj an with ten references that Juniper believed invalidated the '968 patent.
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`4.
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`After I sent Finjan the list of prior art for the ' 968 patent, Finjan ceased contacting
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`Juniper for more than seven months. lo November 2015, Juniper was contacted by Mr. John Garland,
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`a consultant who was helping Finjan with its licensing cITons. At Mr. Garland's request,
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`5.
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`6.
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`Executed thi,ltlh clay of June, 2018, at \l.Al.,~ , North Carolina.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`Scott J. Coonan
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`ORCI..A.RA'nON OF SCOTT' J. COONAN lN SUPPORT OF
`IUNIPIJR'S C)PPOSITTON
`(Case No, 3;17~·--05659-WHt\)
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`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 2 of 9
`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 2 of 9
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`REDACTED VERSION OF DOCUMENT SOUGHTTO BE SEALED
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`(cid:40)(cid:91)(cid:75)(cid:76)(cid:69)(cid:76)(cid:87)(cid:3)(cid:36)(cid:3)
`Exhibit A
`(cid:3)
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`(cid:3)
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`(cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3)
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`(cid:3)
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`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 3 of 9
`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 3 of 9
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`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`JNPR-FNJN_2901100960577
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`CONFIDENTIAL
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`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 4 of 9
`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 4 of 9
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`JNPR-FNJN_2901100960578
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`CONFIDENTIAL
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`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 5 of 9
`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 5 of 9
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`JNPR-FNJN_2901100960579
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`CONFIDENTIAL
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`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 6 of 9
`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 6 of 9
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED CONFIDENTIAL
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`JNPR-FNJN_2901100960580
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`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 7 of 9
`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 7 of 9
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED CONFIDENTIAL
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`JNPR-FNJN_2901100960581
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`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 8 of 9
`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 8 of 9
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`JNPR-FNJN_2901100960582
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`CONFIDENTIAL
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`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 9 of 9
`Case 3:17-cv-05659-WHA Document 125-11 Filed 06/28/18 Page 9 of 9
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED CONFIDENTIAL
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`JNPR-FNJN_2901100960583
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