Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 1 of 141
`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 1 of 141
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`EXHIBIT 1
`EXHIBIT 1
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`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 2 of 141
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`Contact
`
`www.linkedin.com/in/anthony-
`pham-finance (LinkedIn)
`
`Anthony Pham
`
`Sr. Director of Finance at Netskope
`San Francisco Bay Area
`
`Top Skills
`Financial Analysis
`Financial Modeling
`Forecasting
`
`Experience
`
`Netskope
`Sr. Director of Finance
`August 2018 - Present 
`Los Altos, California
`
`Juniper Networks
`11 years 5 months
`Director of Finance - Corporate FP&A
`April 2017 - August 2018 (1 year 5 months)
`Responsible for core FP&A team, finance system and analytics team and a
`shared services management reporting team.
`Drove current quarter execution to meet and exceed financial guidance
`Drove the earnings process; CFO commentary and guidance.
`Prepared financial material for presentation at Board of Directors meetings.
`
`Director of Finance - G&A
`October 2015 - April 2017 (1 year 7 months)
`• Controller for G&A functions, including IT, HR, Legal, Finance and Global
`Shared Services.
`• Business Partner to one EVP and four SVPs and multiple VPs across the
`world wide G&A functions.
`• Owned business finance business support, through quarterly forecasting and
`managing of G&A opex spend, annual and strategic planning, manage key
`cost drivers, and develop robust financial processes.
`• Led a team of three in Sunnyvale and an extended support team of four in
`India
`
`Senior Finance Manager - Corporate FP&A
`April 2014 - October 2015 (1 year 7 months)
`• Responsible for core FP&A processes; annual budget, quarterly forecasts
`and long range strategic planning processes.
`• Drove the annual operating plan development and budgeting process
`including cross functional planning activities.
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`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 3 of 141
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`• Provided expert decision support by anticipating key issues and informational
`needs.
`
`Senior Finance Manager - R&D Business Unit
`April 2010 - March 2014 (4 years)
`• Provide FP&A support to switching business unit by coordinating and
`driving forecast/budget of revenue, margin, opex, headcount, and capex.
`Performed monthly financial updates, quarterly reporting, variance and
`budget gap analysis, risk and opportunities and presented results to executive
`management.
`• Support financial modeling for strategic initiatives.
`• Drive process for improvement in detailed project reporting.
`• Led “best practice” team to drive opex, hc and capex forecasting process
`improvements
`
`Finance Manager - IT
`October 2008 - April 2010 (1 year 7 months)
`• Execute a process of accurate financial planning, forecasting and reporting
`for expense, capex, and headcount. Provide overall business and financial
`management support to CIO and executive team.
`• Develop and implement project reporting process and reports.
`• Responsible for providing accounting, reporting and external audit support for
`a CRM program
`• Train, develop, and mentor shared service individual.
`
`Senior Financial Analyst - Customer Service
`April 2007 - October 2008 (1 year 7 months)
`• Provide FP&A support to America’s Customer Service VP by coordinating
`and driving forecast/budget of revenue, opex, headcount, and capex.
`• Responsible for monthly and quarterly reporting package, including
`development of financial dashboard
`• Lead and develop America’s internal FY08 planning process.
`• Drive margin analysis to improve profitability.
`
`Boston Scientific
`Senior Financial Analyst
`January 2006 - April 2007 (1 year 4 months)
`
`Scholastic/Klutz
`Senior Financial Analyst
`2005 - 2006 (2 years)
`
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`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 4 of 141
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`Sun Microsystems
`Financial Analyst
`2000 - 2005 (6 years)
`
`Managemark
`Financial Analyst
`2000 - 2000 (1 year)
`
`Lockheed Martin
`Finance
`1999 - 2000 (2 years)
`
`Education
`Santa Clara University
`MBA, Finance · (2002 - 2006)
`
`University of California, Santa Barbara
`BA, Business Economics, Minor in Sport Management · (1994 - 1999)
`
`Page 3 of 3
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`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 5 of 141
`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 5 of 141
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`EXHIBIT 2
`EXHIBIT 2
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`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 6 of 141
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`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Joshua Glucoft (301249)
`jglucoft@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`Rebecca Carson (SBN 254105)
`rcarson@irell.com
`Kevin Wang (SBN 318024)
`kwang@irell.com
`840 Newport Center Drive, Suite 400
`Newport Beach, California 92660-6324
`Telephone: (949) 760-0991
`Facsimile: (949) 760-5200
`
`Attorneys for Defendant
`JUNIPER NETWORKS, INC.,
`
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`)
`Case No. 3:17-cv-05659-WHA
`)
`
`)
`
`JUNIPER NETWORKS, INC.’S FIRST
`)
`SUPPLEMENT TO INITIAL
`)
`DISCLOSURES
`)
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`)
`
`)
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`)
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`)
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`FINJAN, INC.,
`
`Plaintiff,
`
`vs.
`
`
`JUNIPER NETWORKS, INC.,
`
`Defendant.
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`10567759
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`
`JUNIPER’S FIRST SUPPLEMENT TO
`INITIAL DISCLOSURES
`(Case No. 3:17-cv-05659-WHA)
`
`

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`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 7 of 141
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`
`JUNIPER NETWORKS, INC.’S FIRST SUPPLEMENT TO INITIAL DISCLOSURES
`Defendant Juniper Networks, Inc. (“Juniper”), by and through its undersigned attorneys,
`provides this first supplement to Initial Disclosures to plaintiff Finjan, Inc. (“Finjan”) in
`compliance with Rule 26(a)(1) of the Federal Rules of Civil Procedure.
`Juniper’s disclosures represent a good faith effort to identify information it reasonably
`believes is discoverable and that it may use to support its claims and defenses as required by Fed.
`R. Civ. P. 26(a)(1). Juniper makes these disclosures based on information reasonably available to
`it at this time and reserves the right to supplement or correct these disclosures under Fed. R. Civ.
`P. 26(e) upon continuing investigation and to include information acquired hereafter or omitted by
`mistake or inadvertence. By making these disclosures, Juniper does not waive its right to object to
`production or disclosure of any information, document, electronically stored information, or
`tangible thing on the basis of privilege, work product doctrine, relevance, undue burden, or any
`other valid objection.
`Throughout this document, U.S. Patent No. 6,154,844 will be referred to as “the ‘844
`Patent”; U.S. Patent No. 6,804,780 will be referred to as “the ‘780 Patent”; U.S. Patent
`No. 7,613,926 will be referred to as “the ‘926 Patent”; U.S. Patent No. 7,647,633 will be referred
`to as “the ‘633 Patent”; U.S. Patent No. 8,141,154 will be referred to as “the ‘154 Patent”; U.S.
`Patent No. 8,677,494 will be referred to as “the ‘494 Patent”; and U.S. Patent No. 7,418,731 will
`be referred to as “the ‘731 Patent.” Collectively, these patents will be referred to as “the patents-
`in-suit.”
`I.
`Individuals Likely To Have Discoverable Information That Juniper May Use To
`Support Its Claims And Defenses
`To the extent currently known, Juniper identifies the individuals set forth below as likely to
`have non-privileged, relevant, discoverable information that Juniper may use to support its claims
`or defenses, except for those witnesses whose testimony will be used solely for impeachment. The
`following disclosures do not include expert witnesses, who will be identified at a later date in
`accordance with the Federal Rules of Civil Procedure and the Scheduling Order entered in this
`matter. Juniper expressly reserves the right to identify or to call as witnesses additional or
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`10567759
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`- 1 -
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`JUNIPER’S FIRST SUPPLEMENT TO
`INITIAL DISCLOSURES
`(Case No. 3:17-cv-05659-WHA)
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`

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`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 8 of 141
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`different individuals if, during the course of discovery and investigation related to this matter,
`Juniper learns that such additional or different individuals have relevant knowledge.
`In making these disclosures, Juniper does not waive its right to object to discovery of
`information from any of these individuals or any other individuals, by deposition or otherwise, on
`any and all grounds, including, without limitation, the attorney-client privilege, the work product
`doctrine, or any applicable privilege. Any individual designated in this disclosure with an asterisk
`(*) by his or her name should be contacted through Irell & Manella LLP, 1800 Avenue of the
`Stars, Suite 900, Los Angeles, California, 90067, (310) 277-1010, regardless of whether that
`individual’s contact information is also set forth in the chart below. Juniper objects to Finjan
`directly contacting any current or former employee of Juniper. In addition to the individuals listed
`below, Juniper notes that there are likely other individuals who may have knowledge of relevant
`facts and who Juniper may ultimately use to support its claims or defenses except to the extent
`such testimony would be used solely for impeachment, including:
`•
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`Individuals who worked with the named inventors of the patents-in-suit in
`connection with the conception, reduction to practice, design, and development of
`any of the purported inventions claimed in the patents-in-suit;
`
`•
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`•
`•
`•
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`Individuals with knowledge of any facts relating to affirmative defenses or
`counterclaims raised by Juniper;
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`Individuals identified by Finjan as likely to have relevant information;
`Individuals involved in the prosecution or licensing of the patents-in-suit; and
`Individuals whose names appear in the documents, deposition transcripts, and other
`discovery provided by the parties in this matter.
`
`Name & Contact Information
`Volodymyr (“Volvon”) Kuznetsov*
`1133 Innovation Way
`Sunnyvale, CA 94089
`408-745-2000
`Yuly Tenorio*
`1133 Innovation Way
`Sunnyvale, CA 94089
`408-745-2000
`
`Summary of Information
`May have technical information about accused
`Juniper products.
`
`May have technical information about accused
`Juniper products.
`
`10567759
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`- 2 -
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`JUNIPER’S FIRST SUPPLEMENT TO
`INITIAL DISCLOSURES
`(Case No. 3:17-cv-05659-WHA)
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`

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`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 9 of 141
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`Name & Contact Information
`Frank Jas*
`1133 Innovation Way
`Sunnyvale, CA 94089
`408-745-2000
`Rakesh Manocha*
`1133 Innovation Way
`Sunnyvale, CA 94089
`408-745-2000
`Raju Manthena*
`1133 Innovation Way
`Sunnyvale, CA 94089
`408-745-2000
`Chandra Nagarajan*
`1133 Innovation Way
`Sunnyvale, CA 94089
`408-745-2000
`Shelly Gupta*
`1133 Innovation Way
`Sunnyvale, CA 94089
`408-745-2000
`Michael Bushong*
`1133 Innovation Way
`Sunnyvale, CA 94089
`408-745-2000
`Michael Marcellin*
`1133 Innovation Way
`Sunnyvale, CA 94089
`408-745-2000
`Scott Coonan*
`1133 Innovation Way
`Sunnyvale, CA 94089
`408-745-2000
`Shlomo Touboul
`Senior Advisor, Finjan
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`Summary of Information
`May have technical information about accused
`Juniper and Cyphort products.
`
`May have technical information about accused
`Juniper products.
`
`May have technical information about accused
`Juniper products.
`
`May have technical information about accused
`Juniper products.
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`May have financial information related to accused
`Juniper products.
`
`May have marketing information related to the
`accused Juniper products.
`
`May have company information related to Juniper.
`
`May have company information related to Juniper,
`Juniper’s licensing practices, and Juniper’s
`communications with Finjan.
`
`Named inventor on the ‘844, ‘780, ‘926, ‘633, ‘731,
`and ‘494 Patents. May have information regarding
`the patents-in-suit, including: inventorship;
`conception and reduction to practice; prior art and
`inequitable conduct; alleged embodiments of the
`patents-in-suit; offers for sale; assignments or other
`transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`
`10567759
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`- 3 -
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`JUNIPER’S FIRST SUPPLEMENT TO
`INITIAL DISCLOSURES
`(Case No. 3:17-cv-05659-WHA)
`
`

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`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 10 of 141
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`Name & Contact Information
`Nachshon Gal
`
`Yigal Mordechai Edery
`
`Nimrod Itzhak Vered
`
`David R. Kroll
`
`David Gruzman
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`10567759
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`Summary of Information
`Named inventor on the ‘844 Patent. May have
`information regarding the patents-in-suit, including:
`inventorship; conception and reduction to practice;
`prior art and inequitable conduct; alleged
`embodiments of the patents-in-suit; offers for sale;
`assignments or other transactions regarding
`ownership; secondary considerations regarding the
`obviousness of the patents-in-suit; and licensing and
`enforcement activities.
`Named inventor on the ‘926, ‘633, and ‘494 Patents.
`May have information regarding the patents-in-suit,
`including: inventorship; conception and reduction to
`practice; prior art and inequitable conduct; alleged
`embodiments of the patents-in-suit; offers for sale;
`assignments or other transactions regarding
`ownership; secondary considerations regarding the
`obviousness of the patents-in-suit; and licensing and
`enforcement activities.
`Named inventor on the ‘926, ‘633, and ‘494 Patents.
`May have information regarding the patents-in-suit,
`including: inventorship; conception and reduction to
`practice; prior art and inequitable conduct; alleged
`embodiments of the patents-in-suit; offers for sale;
`assignments or other transactions regarding
`ownership; secondary considerations regarding the
`obviousness of the patents-in-suit; and licensing and
`enforcement activities.
`Named inventor on the ‘926, ‘633, and ‘494 Patents.
`May have information regarding the patents-in-suit,
`including: inventorship; conception and reduction to
`practice; prior art and inequitable conduct; alleged
`embodiments of the patents-in-suit; offers for sale;
`assignments or other transactions regarding
`ownership; secondary considerations regarding the
`obviousness of the patents-in-suit; and licensing and
`enforcement activities.
`Named inventor on the ‘154 Patent. May have
`information regarding the patents-in-suit, including:
`inventorship; conception and reduction to practice;
`prior art and inequitable conduct; alleged
`embodiments of the patents-in-suit; offers for sale;
`assignments or other transactions regarding
`ownership; secondary considerations regarding the
`obviousness of the patents-in-suit; and licensing and
`enforcement activities.
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`- 4 -
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`JUNIPER’S FIRST SUPPLEMENT TO
`INITIAL DISCLOSURES
`(Case No. 3:17-cv-05659-WHA)
`
`

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`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 11 of 141
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`Name & Contact Information
`Yuval Ben-Itzhak
`
`S.H. Michael Kim, Intellectual Property
`Counsel, Finjan
`
`John Garland, Finjan
`
`Julie Mar-Spinola, Chief IP Officer,
`Finjan
`
`Ivan Chaperot, Finjan
`
`Phil Hartstein, President and Chief
`Executive Officer, Finjan
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`10567759
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`Summary of Information
`Named inventor on the ‘154 Patent. May have
`information regarding the patents-in-suit, including:
`inventorship; conception and reduction to practice;
`prior art and inequitable conduct; alleged
`embodiments of the patents-in-suit; offers for sale;
`assignments or other transactions regarding
`ownership; secondary considerations regarding the
`obviousness of the patents-in-suit; and licensing and
`enforcement activities.
`May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
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`- 5 -
`
`JUNIPER’S FIRST SUPPLEMENT TO
`INITIAL DISCLOSURES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 12 of 141
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`
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`Name & Contact Information
`Michael D. Noonan, Chief Financial
`Officer and Treasurer, Finjan
`
`Atreyee Dhar, Director, Patent Analysis,
`Finjan
`
`Summary of Information
`May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`Glenn Daniel, Board of Directors, Finjan May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`
`Sharmila Patel, Controller, Senior
`Director of Finance, Finjan
`
`Daniel Chinn, Board of Directors
`Chairman, Finjan
`
`Eric Benhamou, Board of Directors,
`Finjan
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`10567759
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`JUNIPER’S FIRST SUPPLEMENT TO
`INITIAL DISCLOSURES
`(Case No. 3:17-cv-05659-WHA)
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`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 13 of 141
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`
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`Michael Southworth, Board of Directors,
`Finjan
`
`Summary of Information
`Name & Contact Information
`Harry Kellogg, Board of Directors, Finjan May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`Gary Moore, Board of Directors, Finjan May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`Alex Rogers, Board of Directors, Finjan May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; secondary
`considerations regarding the obviousness of the
`patents-in-suit; and licensing and enforcement
`activities.
`May have information regarding, among other
`things, the ‘844, ‘780, ‘926, ‘633, ‘154, and ‘494
`Patents, including scope, alleged validity,
`enforceability, prosecution history, the disclosure or
`failure to disclose certain information to the
`USPTO, the scope of the prior art, the conception
`and reduction to practice of the alleged invention(s),
`and positions taken in prosecution and
`administrative proceedings.
`May have information regarding, among other
`things, the ‘844, ‘780, ‘926, ‘633, ‘731, and ‘494
`Patents, including scope, alleged validity,
`enforceability, prosecution history, the disclosure or
`failure to disclose certain information to the
`USPTO, the scope of the prior art, the conception
`and reduction to practice of the alleged invention(s),
`and positions taken in prosecution and
`administrative proceedings.
`
`Dawn-Marie Bey
`Bey & Cotropia PLLC
`213 Bayly Court
`Richmond, VA 23229
`
`Marc Sockol
`Graham & James, LLP
`600 Hansen Way
`Palo Alto, CA 94304-1043
`
`1
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`10567759
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`- 7 -
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`JUNIPER’S FIRST SUPPLEMENT TO
`INITIAL DISCLOSURES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 14 of 141
`
`Name & Contact Information
`Marc Sockol
`Squire, Sanders & Dempsey, L.L.P.
`4900 Key Tower 127 Public Square
`Cleveland, OH 44114
`
`Mark A. Berger
`Squire, Sanders & Dempsey, L.L.P.
`4900 Key Tower 127 Public Square
`Cleveland, OH 44114
`
`Aaron Wininger
`Squire, Sanders & Dempsey, L.L.P.
`4900 Key Tower 127 Public Square
`Cleveland, OH 44114
`
`Eitan Law Group
`7 Shekar St.
`POB 2081
`Herzlia, Israel 46120
`
`Vladimir Sherman
`Eitan Law Group
`C/O Landon IP Inc.
`1700 Diagonal Road, Suite 450
`Alexandria, VA 22314
`
`
`
`Summary of Information
`May have information regarding, among other
`things, the ‘844 and ‘780 Patents, including scope,
`alleged validity, enforceability, prosecution history,
`the disclosure or failure to disclose certain
`information to the USPTO, the scope of the prior
`art, the conception and reduction to practice of the
`alleged invention(s), and positions taken in
`prosecution and administrative proceedings.
`May have information regarding, among other
`things, the ‘844 and ‘780 Patents, including scope,
`alleged validity, enforceability, prosecution history,
`the disclosure or failure to disclose certain
`information to the USPTO, the scope of the prior
`art, the conception and reduction to practice of the
`alleged invention(s), and positions taken in
`prosecution and administrative proceedings.
`May have information regarding, among other
`things, the ‘844 and ‘780 Patents, including scope,
`alleged validity, enforceability, prosecution history,
`the disclosure or failure to disclose certain
`information to the USPTO, the scope of the prior
`art, the conception and reduction to practice of the
`alleged invention(s), and positions taken in
`prosecution and administrative proceedings.
`May have information regarding, among other
`things, the ‘844 Patent, including scope, alleged
`validity, enforceability, prosecution history, the
`disclosure or failure to disclose certain information
`to the USPTO, the scope of the prior art, the
`conception and reduction to practice of the alleged
`invention(s), and positions taken in prosecution and
`administrative proceedings.
`May have information regarding, among other
`things, the ‘633 and ‘154 Patents, including scope,
`alleged validity, enforceability, prosecution history,
`the disclosure or failure to disclose certain
`information to the USPTO, the scope of the prior
`art, the conception and reduction to practice of the
`alleged invention(s), and positions taken in
`prosecution and administrative proceedings.
`
`1
`2
`3
`4
`5
`6
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`8
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`10
`11
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`13
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`15
`16
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`10567759
`
`
`
`- 8 -
`
`JUNIPER’S FIRST SUPPLEMENT TO
`INITIAL DISCLOSURES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 15 of 141
`
`Name & Contact Information
`Eppa Hite
`Carter Defilippo & Ferrell
`2225 East Bayshore Road, Suite 200
`Palo Alto, CA 94303
`
`Andrew L. Tiajoloff
`Tiajoloff & Kelly
`Chrysler Building, 37th Floor
`405 Lexington Avenue
`New York, NY 10174
`
`Glenn E. Von Tersch
`Perkins Coie, LLP
`P.O. Box 2168
`Menlo Park, CA 95026-2168
`
`
`Michael A. Oblon
`Perkins Coie, LLP
`607 Fourteenth Street, N.W.
`Washington, DC 20005-2003
`
`
`Eric Sophir
`King and Spalding LLP
`1700 Pennsylvania Avenue, NW
`Suite 200
`Washington, DC 20006
`
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`18
`19
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`28
`
`
`
`Summary of Information
`May have information regarding, among other
`things, the ‘844, ‘780, and ‘494 Patents, including
`scope, alleged validity, enforceability, prosecution
`history, the disclosure or failure to disclose certain
`information to the USPTO, the scope of the prior
`art, the conception and reduction to practice of the
`alleged invention(s), and positions taken in
`prosecution and administrative proceedings.
`May have information regarding, among other
`things, the ‘926 Patent, including scope, alleged
`validity, enforceability, prosecution history, the
`disclosure or failure to disclose certain information
`to the USPTO, the scope of the prior art, the
`conception and reduction to practice of the alleged
`invention(s), and positions taken in prosecution and
`administrative proceedings.
`May have information regarding, among other
`things, the ‘844, ‘780, ‘926, ‘633, and ‘731 Patents,
`including scope, alleged validity, enforceability,
`prosecution history, the disclosure or failure to
`disclose certain information to the USPTO, the
`scope of the prior art, the conception and reduction
`to practice of the alleged invention(s), and positions
`taken in prosecution and administrative
`proceedings.
`May have information regarding, among other
`things, the ‘844, ‘780, ‘926, and ‘633 Patents,
`including scope, alleged validity, enforceability,
`prosecution history, the disclosure or failure to
`disclose certain information to the USPTO, the
`scope of the prior art, the conception and reduction
`to practice of the alleged invention(s), and positions
`taken in prosecution and administrative
`proceedings.
`May have information regarding, among other
`things, the ‘926, ‘633, ‘154, and ‘494 Patents,
`including scope, alleged validity, enforceability,
`prosecution history, the disclosure or failure to
`disclose certain information to the USPTO, the
`scope of the prior art, the conception and reduction
`to practice of the alleged invention(s), and positions
`taken in prosecution and administrative
`proceedings.
`
`10567759
`
`
`
`- 9 -
`
`JUNIPER’S FIRST SUPPLEMENT TO
`INITIAL DISCLOSURES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 16 of 141
`
`
`
`Name & Contact Information
`Unknown representatives or agents of
`Finjan
`
`All attorneys, registered agents, and
`supporting staff involved in the
`prosecution of (including original,
`continuation, continuation-in-part,
`divisional, reexamination, or reissue
`applications) or post-grant proceedings
`related to (including inter partes reviews
`and ex parte reexaminations) the patents-
`in-suit, and any related patents or patent
`applications
`
`Summary of Information
`May have information regarding the patents-in-suit,
`including: their prosecution; alleged embodiments
`of the patents-in-suit; offers for sale; assignments or
`other transactions regarding ownership; and
`secondary considerations regarding the obviousness
`of the patents-in-suit; and licensing and
`enforcement activities.
`May have information regarding, among other
`things: the patents-in-suit (including scope, alleged
`validity, and enforceability); the prosecution history
`of the patents-in-suit; the disclosure or failure to
`disclose certain information to the United States
`Patent and Trademark Office (USPTO); the scope
`of the prior art; the conception and reduction to
`practice of the alleged inventions claimed and
`disclosed in the patents-in-suit; and positions taken
`in prosecution and administrative proceedings
`involving the patents-in-suit.
`May have information regarding prior art.
`
`May have information regarding prior art.
`
`All authors, inventors, and other
`developers of prior art disclosed during
`the initial prosecution of or post-grant
`proceedings related to the patents-in-suit
`All authors, inventors, and other
`developers of prior art, including but not
`limited to all prior art identified by
`Juniper in its invalidity contentions and
`all prior art and related references
`identified by any party adverse to Finjan
`in any litigation, arbitration, or
`administrative proceeding (including
`post-grant proceedings in the USPTO)
`
`II.
`Documents, Electronically Stored Information, And Tangible Things In Juniper’s
`Possession, Custody, Or Control That Juniper May Use To Support Its Claims Or
`Defenses, Unless The Use Would Be Solely For Impeachment.
`Based upon the limited information presently available to it, Juniper identifies the
`following categories of documents, electronically stored information, and tangible things
`(collectively, “Documents”) that Juniper may use to support its claims and defenses, unless the use
`would be solely for impeachment:
`
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`15
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`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`10567759
`
`
`
`- 10 -
`
`JUNIPER’S FIRST SUPPLEMENT TO
`INITIAL DISCLOSURES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 254-12 Filed 11/27/18 Page 17 of 141
`
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`•
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`•
`•
`•
`•
`
`•
`
`•
`•
`
`•
`
`•
`
`
`
`The patents-in-suit and related Documents, including but not limited to: the
`prosecution histories of the patents-in-suit and related patents and patent
`applications; post-grant proceedings in the USPTO regarding the patents-in-suit
`and related patents and patent applications, such as filings in inter partes reviews,
`ex parte reexaminations, reissue applications, and certificates of correction;
`Documents related to the alleged conception and reduction to practice of the
`patents-in-suit; and Documents related to the ownership of the patents-in-suit.
`
`Documents related to Finjan’s licensing of the patents-in-suit, including licenses
`and settlements, as well as any correspondence or internal analyses related to
`licensing or settlement