Case 3:17-cv-05659-WHA Document 251 Filed 11/27/18 Page 1 of 2
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`Paul Andre
`Partner
`T 650-752-1700
`F 650-752-1800
`PAndre@KRAMERLEVIN.com
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`November 27, 2018
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`990 Marsh Road
`Menlo Park, CA 94025-1949
`T 650.752.1700
`F 650.752.1800
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`Honorable William Alsup
`U.S. District Court, Northern District of California
`San Francisco Courthouse
`Courtroom 12 – 19th Floor
`450 Golden Gate Avenue
`San Francisco, CA 94102
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`Re:
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`Finjan, Inc. v. Juniper Networks, Inc., Case No. 3:17-cv-05659-WHA
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`Dear Judge Alsup:
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`Juniper’s letter to the Court yesterday (Dkt. 250) is incorrect -- Juniper did not inform
`Finjan which SRX products are able to interface with Sky ATP. Paragraph 6 of the
`Kastens’s declaration states: “Juniper never informed Finjan that its production of source
`code for the accused products was specific to only certain models of SRX products.”
`(Emphasis added.) This declaration is made in the context of Finjan’s Dabuert motion for
`the ‘494 Patent, where the accused products for the ’494 Patent include Sky ATP by itself
`and SRX with Sky ATP.
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`The mapping between SRX series and Junos versions (which is the operating system that
`runs on SRX) in Juniper’s letter is a red herring because the mapping does not show
`which SRX or Junos version is able to interface with Sky ATP. See Juniper’s Letter at pp. 1 –
`2. In addition, the mapping itself shows that each SRX model supports many Junos
`versions, and it does not provide an identification of which Junos version the accused
`SRX models are running on.
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`More troublesome, however, is Juniper’s misstatement regarding the accused products.
`The mapping in Juniper’s letter was generated after the expiration date of the ’494
`Patent (i.e. January 2017), as evidenced by the inclusion of Junos versions 17.3, 17.4,
`which came out in late 2017. See Juniper’s Letter at p. 1. Additionally, the mapping
`between SRX and Junos in Juniper’s letter does not accurately reflect SRX models during
`the timeframe of the accused infringement because the SRX series was rebranded in
`2016 as shown in the product transition chart below. Ex. 1 at p. 28.
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`KRAMER LEVIN NAFTALIS & FRANKEL LLP
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` SILICON VALLEY | NEW YORK | PARIS
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`Case 3:17-cv-05659-WHA Document 251 Filed 11/27/18 Page 2 of 2
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`Hon. William Alsup
`November 27, 2018
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`This product transition chart also shows that the SRX100 and 200 series were rebranded
`into the SRX300 series; SRX1400 was rebranded into SRX1500; and SRX3400 was rebranded
`into SRX5400. Contrary to Juniper’s statement, the current SRX300, 1500, and 5400 series
`do include Sky ATP functionalities. See Ex. 2 (Sky ATP Datasheet) at p. 2 (which shows that
`SkyATP supports SRX340, 1500, and 5000 product lines, and Junos version 15.1X49 or later);
`see also Juniper’s Letter at p. 1 (which shows that SRX3XX runs Junos version 15.1X49).
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`At least for the above-mentioned reasons, Juniper’s request to strike Paragraph 6 of Mr.
`Kastens’s declaration should be denied.
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`Respectfully submitted,
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`Paul Andre
`Counsel for Plaintiff Finjan, Inc.
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