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`Case 3:17-cv-05659-WHA Document 154-15 Filed 07/12/18 Page 1 of 3
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`EXHIBIT 14
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`Case 3:17-cv-05659-WHA Document 154-15 Filed 07/12/18 Page 2 of 3
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`Juniper also objects to this Interrogatory on the grounds that it is overbroad, unduly
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`burdensome, oppressive, vague and ambiguous, not proportional to the needs of the case, and
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`seeks irrelevant information.
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`Subject to these specific objections and the general objections incorporated herein, Juniper
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`responds as follows:
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`Based on Juniper’s investigation to date, Juniper first became aware of the existence of the
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`Asserted Patents at or after the time the Complaint in this matter was filed. See Dkt. Nos. 1
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`(Complaint) and 14 (Proof of Service of Summons).
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`Juniper contends that it does not infringe any of the Asserted Patents and further contends that
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`the Asserted Patents are invalid and unenforceable, as set forth in Juniper’s Answer and
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`Counterclaims. See Dkt. No. 42.
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`FIRST SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 1:
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`Juniper incorporates herein by reference all General Objections set forth above.
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`Juniper also specifically objects to this Interrogatory because Finjan’s Interrogatories were
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`improperly served as set forth in the General Objections above. Juniper provides this specific
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`objection and response in an abundance of caution and in order to facilitate discovery, although
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`this Interrogatory is moot and no response is required.
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`Juniper also specifically objects to this Interrogatory to the extent that it seeks information
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`or documents that are subject to the attorney-client privilege, that evidence or constitute attorney
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`work product, or that otherwise are not discoverable or are the subject of any other applicable
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`privilege or immunity, whether based upon statute or recognized at common law, specifically
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`including documents protected by the common interest privilege and/or joint defense agreements.
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`Juniper further specifically objects to the definition of “You” as overbroad, unduly
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`burdensome, oppressive, indefinite, vague and ambiguous. Juniper also objects to this definition
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`to the extent that it purports to impose discovery obligations on persons or entities other than the
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`parties to this action. Juniper will construe the term “You” to mean “Juniper Networks, Inc.”
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
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`10496077
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`- 11 -
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`JUNIPER’S SECOND SUPPLEMENTAL RESPONSE TO
`FINJAN’S FIRST SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
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`Case 3:17-cv-05659-WHA Document 154-15 Filed 07/12/18 Page 3 of 3
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`Juniper also objects to this Interrogatory on the grounds that it is overbroad, unduly
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`burdensome, oppressive, vague and ambiguous, not proportional to the needs of the case, and
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`seeks irrelevant information.
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`Subject to these specific objections and the general objections incorporated herein, Juniper
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`further responds as follows:
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`Juniper and Finjan engaged in correspondence and discussions throughout 2014 and
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`2015. During the course of those discussions, Juniper became aware that Finjan claimed to be the
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`owner of a patent portfolio, which included at least some of the Asserted Patents. The only patent
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`that Finjan provided specific infringement allegations for was U.S. Patent No. 6,965,968, which
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`has not been asserted in this case. In response to Finjan’s allegations of infringement as to the
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`’968 patent, Juniper provided Finjan with numerous pieces of prior art that Juniper believed
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`invalidated the patent.
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`INTERROGATORY NO. 2:
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`For each of the Accused Instrumentalities, identify all releases or versions that are or have
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`been made, used, offered for sale, sold in the United States, or imported into the United States by You
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`or on Your behalf from the year 2012 to the present.
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`RESPONSE TO INTERROGATORY NO. 2:
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`Juniper incorporates herein by reference all General Objections set forth above.
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`Juniper also specifically objects to this Interrogatory because Finjan’s Interrogatories were
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`improperly served as set forth in the General Objections above. Juniper provides this specific
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`objection and response in an abundance of caution and in order to facilitate discovery, although
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`this Interrogatory is moot and no response is required.
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`Juniper further specifically objects to the definition of “You” as overbroad, unduly
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`burdensome, oppressive, indefinite, vague and ambiguous. Juniper also objects to this definition
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`to the extent that it purports to impose discovery obligations on persons or entities other than the
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`parties to this action. Juniper will construe the term “You” to mean “Juniper Networks, Inc.”
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`Juniper also specifically objects to the definition of “Accused Instrumentalities” as
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`including Advanced Threat Protection Appliance and Contrail. Advanced Threat Protection
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10496077
`
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`- 13 -
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`JUNIPER’S SECOND SUPPLEMENTAL RESPONSE TO
`FINJAN’S FIRST SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
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