`
`DECLARATION OF CHANDRA NAGARAJAN
`
`I, Chandra Nagarajan, declare as follows:
`
`1.
`
`I have personal knowledge of the facts set forth in this declaration, and I could
`
`and would testify competently thereto if called upon to do so.
`
`2.
`
`I am a Senior Director in the Security business group within Juniper Networks,
`
`Inc. ("Juniper"). I am responsible for the engineering delivery of various products, including
`
`Juniper's Sky Advanced Threat Prevention service ("Sky ATP").
`
`3.
`
`Sky ATP as a solution is available in multiple different self-contained
`
`deployments distributed geographically across the world. Sky ATP has deployments in the
`
` A Sky ATP customer based in the U.S. would
`
`
`
` etc.
`
`4.
`
`Juniper SRX Series Services Gateways ("SRX") must be configured with a
`
`license in order to use the Basic and Premium Service offered by Juniper's Sky Advanced Threat
`
`Prevention offering ("Sky ATP"). A free service is also available without a license for all SRX
`
`customers that have a support contract. See
`
`https :/ /www. juniper. net/ documentation/en US/release-independent/sky-
`
`atp/topics/reference/ general/sky-atp-1 icenses-overview .html.
`
` of SRX
`
`customers have configured their SRX units to interface with Sky ATP through any type of Sky
`
`ATP offering, whether free, Basic, or Premium.
`
`5.
`
`The number of SRX devices that are configured with a Basic or Premium license
`
`can be determined from Juniper's sales data. I have reviewed Juniper's sales documentation for
`
`SRX and Sky ATP, located at JNPR-FNJN_29028_00472484 and JNPR(cid:173)
`
`FNJN_29028_00472485. The following table shows the number of SRX units that were sold
`
`and the number of paid Sky ATP licenses that were sold to SRX customers, by SRX ship-to
`
`destination country, from the time that Sky ATP was launched (fourth quarter of2015) through
`
`the end of the first quarter of 2017 (March 2017):
`
`- 1 -
`
`DECLARATION OF C. NAGARJAN ISO
`JUNIPER'S OPP. TO MSJ RE: '494 PATENT
`Case No, 3:l 7-cv-05659-WHA
`
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`
`
`Case 3:17-cv-05659-WHA Document 126-2 Filed 06/28/18 Page 2 of 2
`
`This table shows that, out of the approximately
`
` SRX units that Juniper shipped to the
`
`U.S. in the relevant time period,
`
` were configured to
`
`use Sky ATP with a paid Basic or Premium license.
`
`6.
`
`
`
`
`
`
`
`
`
` I would estimate that, at most,
`
`the launch of the Sky ATP service through the end of the first quarter of 2017.
`
`7.
`
`SRX units that have not been explicitly enrolled to use Sky ATP's service do not
`
` between
`
`interface with Sky ATP or send sample to Sky ATP for analysis.
`
`8.
`
`One of Sky ATP's static analyzers is
`
`
`
`
`
` does
`
`not, however, return all of the commands contained in the sample, nor does it always return
`
`
`
`9.
`
`Sky ATP uses its
`
`
`
`
`
` tries to
`
`fool the sample into believing that the sample is in a real client computer in order to get the
`
`sample to reveal its true nature
`
`.
`
` then returns
`
`the results of actions performed by the sample while in the safe "sandbox" environment. The
`
`results report contains a list of behaviors for the file, but
`
`
`
`
`
`
`
`Executed June 2..7 , 2018 at S ~" ~ California. I declare under penalty of perjury
`
`under the laws of the United States of America that the foregoing is true and correct.
`
`Chandra Nagarajan
`
`- 2 -
`
`DECLARA TJON OF C. NAGARJAN ISO
`JUNIPER'S OPP. TO MSJ RE: '494 PATENT
`Case No. 3:17-cv-05659-WHA
`
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`
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