Case 3:17-cv-05659-WHA Document 154-15 Filed 07/12/18 Page 1 of 3
`
`Case 3:17-cv-05659-WHA Document 154-15 Filed 07/12/18 Page 1 of 3
`
`EXHIBIT 14
`
`

`

`Case 3:17-cv-05659-WHA Document 154-15 Filed 07/12/18 Page 2 of 3
`
`Juniper also objects to this Interrogatory on the grounds that it is overbroad, unduly
`
`burdensome, oppressive, vague and ambiguous, not proportional to the needs of the case, and
`
`seeks irrelevant information.
`
`Subject to these specific objections and the general objections incorporated herein, Juniper
`
`responds as follows:
`
`Based on Juniper’s investigation to date, Juniper first became aware of the existence of the
`
`Asserted Patents at or after the time the Complaint in this matter was filed. See Dkt. Nos. 1
`
`(Complaint) and 14 (Proof of Service of Summons).
`
`Juniper contends that it does not infringe any of the Asserted Patents and further contends that
`
`the Asserted Patents are invalid and unenforceable, as set forth in Juniper’s Answer and
`
`Counterclaims. See Dkt. No. 42.
`
`FIRST SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 1:
`
`Juniper incorporates herein by reference all General Objections set forth above.
`
`Juniper also specifically objects to this Interrogatory because Finjan’s Interrogatories were
`
`improperly served as set forth in the General Objections above. Juniper provides this specific
`
`objection and response in an abundance of caution and in order to facilitate discovery, although
`
`this Interrogatory is moot and no response is required.
`
`Juniper also specifically objects to this Interrogatory to the extent that it seeks information
`
`or documents that are subject to the attorney-client privilege, that evidence or constitute attorney
`
`work product, or that otherwise are not discoverable or are the subject of any other applicable
`
`privilege or immunity, whether based upon statute or recognized at common law, specifically
`
`including documents protected by the common interest privilege and/or joint defense agreements.
`
`Juniper further specifically objects to the definition of “You” as overbroad, unduly
`
`burdensome, oppressive, indefinite, vague and ambiguous. Juniper also objects to this definition
`
`to the extent that it purports to impose discovery obligations on persons or entities other than the
`
`parties to this action. Juniper will construe the term “You” to mean “Juniper Networks, Inc.”
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10496077
`
`
`- 11 -
`
`JUNIPER’S SECOND SUPPLEMENTAL RESPONSE TO
`FINJAN’S FIRST SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 154-15 Filed 07/12/18 Page 3 of 3
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`Juniper also objects to this Interrogatory on the grounds that it is overbroad, unduly
`
`burdensome, oppressive, vague and ambiguous, not proportional to the needs of the case, and
`
`seeks irrelevant information.
`
`Subject to these specific objections and the general objections incorporated herein, Juniper
`
`further responds as follows:
`
`Juniper and Finjan engaged in correspondence and discussions throughout 2014 and
`
`2015. During the course of those discussions, Juniper became aware that Finjan claimed to be the
`
`owner of a patent portfolio, which included at least some of the Asserted Patents. The only patent
`
`that Finjan provided specific infringement allegations for was U.S. Patent No. 6,965,968, which
`
`has not been asserted in this case. In response to Finjan’s allegations of infringement as to the
`
`’968 patent, Juniper provided Finjan with numerous pieces of prior art that Juniper believed
`
`invalidated the patent.
`
`INTERROGATORY NO. 2:
`
`For each of the Accused Instrumentalities, identify all releases or versions that are or have
`
`been made, used, offered for sale, sold in the United States, or imported into the United States by You
`
`or on Your behalf from the year 2012 to the present.
`
`RESPONSE TO INTERROGATORY NO. 2:
`
`Juniper incorporates herein by reference all General Objections set forth above.
`
`Juniper also specifically objects to this Interrogatory because Finjan’s Interrogatories were
`
`improperly served as set forth in the General Objections above. Juniper provides this specific
`
`objection and response in an abundance of caution and in order to facilitate discovery, although
`
`this Interrogatory is moot and no response is required.
`
`Juniper further specifically objects to the definition of “You” as overbroad, unduly
`
`burdensome, oppressive, indefinite, vague and ambiguous. Juniper also objects to this definition
`
`to the extent that it purports to impose discovery obligations on persons or entities other than the
`
`parties to this action. Juniper will construe the term “You” to mean “Juniper Networks, Inc.”
`
`Juniper also specifically objects to the definition of “Accused Instrumentalities” as
`
`including Advanced Threat Protection Appliance and Contrail. Advanced Threat Protection
`
`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10496077
`
`
`- 13 -
`
`JUNIPER’S SECOND SUPPLEMENTAL RESPONSE TO
`FINJAN’S FIRST SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
`
`