`Case 3:17-cv-05659-WHA Document 129-25 Filed 06/28/18 Page 1 of 3
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`EXHIBIT 23
`EXHIBIT 23
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`Case 3:17-cv-05659-WHA Document 129-25 Filed 06/28/18 Page 2 of 3
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`a.
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`b.
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`c.
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`d.
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`e.
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`f.
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`g.
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`h.
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`the basis on which the privilege is claimed;
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`the names and positions of the author of the document and all other persons
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`participating in the preparation of the document;
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`the name and position of each individual or other person to whom the document,
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`or a copy thereof, was sent or otherwise disclosed;
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`the date of the document;
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`a description of any accompanying material transmitted with or attached to such
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`document;
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`the number of pages in such document;
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`the particular request to which such document is responsive; and
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`whether any business or non-legal matter is contained or discussed in such
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`document.
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`4.
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`If Defendant’s response to a particular request is a statement that Defendant lacks the
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`ability to comply with that request, Defendant shall specify whether the inability to comply is because
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`the particular item or category of information never existed, has been destroyed, has been lost,
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`misplaced, or stolen, or has never been, or is no longer in the possession, custody, or control of
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`Defendant, in which case Defendant shall identify the name and address of any person or entity known
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`or believed by Defendant to have possession, custody, or control of that information or category of
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`information.
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`REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS
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`REQUEST FOR PRODUCTION NO. 1:
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`All documents, communications, or things relating to Finjan and its patents.
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`REQUEST FOR PRODUCTION NO. 2:
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`All documents, communications, or things relating to the Asserted Patents, including documents
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`or communications with third parties.
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`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
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`Case 3:17-cv-05659-WHA Document 129-25 Filed 06/28/18 Page 3 of 3
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`REQUEST FOR PRODUCTION NO. 3:
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`All documents, communications, or things relating to the timing and circumstances of the
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`moment You first became aware of each of the Asserted Patents.
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`REQUEST FOR PRODUCTION NO. 4:
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`All documents, communications, or things relating to any investigation or analysis You
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`performed of any of the Asserted Patents.
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`REQUEST FOR PRODUCTION NO. 5:
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`Documents, communications, or things sufficient to show the infringement or non-infringement
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`of the Asserted Patents by You or any other person or entity, including but not limited to, all
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`documents, communications, or things relating to Your efforts to assess the validity, infringement, or
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`enforceability of the Asserted Patents or to design around or avoid infringing the Asserted Patents.
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`REQUEST FOR PRODUCTION NO. 6:
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`Documents, communications, or things sufficient to show the alleged non-infringing
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`alternatives to the inventions of the Asserted Patents.
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`REQUEST FOR PRODUCTION NO. 7:
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`Documents, communications, or things sufficient to show any alleged prior art to, or searches
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`for prior art, regarding the Asserted Patents.
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`REQUEST FOR PRODUCTION NO. 8:
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`Documents, communications, or things sufficient to show the scope, patentability, novelty,
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`validity, invalidity, enforceability, or unenforceability of any claim of the Asserted Patents.
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`REQUEST FOR PRODUCTION NO. 9:
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`Documents, communications, or things sufficient to show any secondary consideration or other
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`objective evidence of non-obviousness of the Asserted Patents, including but not limited to any long-
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`felt need, failure of others, commercial success, copying of the claimed invention by others,
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`unexpected or superior results from the claimed invention, licensing or praise by others, criticism by
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`others, or any other objective indicia of non-obviousness.
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`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
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`CASE NO. 3:17-cv-05659-WHA
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