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`Case 3:17-cv-05659-WHA Document 260 Filed 11/27/18 Page 1 of 4
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`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Joshua Glucoft (SBN 301249)
`jglucoft@irell.com
`Casey Curran (SBN 305210)
`ccurran@irell.com
`Sharon Song (SBN 313535)
`ssong@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
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`NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCISCO DIVISION
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`FINJAN, INC., a Delaware Corporation,
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`Plaintiff,
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`vs.
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`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
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`Defendant.
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`
`)
`)
`)
`)
`)
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`Case No. 3:17-cv-05659-WHA
`
`DECLARATION OF JOSH GLUCOFT IN
`SUPPORT OF DEFENDANT JUNIPER
`NETWORKS, INC.’S OPPOSITIONS TO
`FINJAN, INC.’S MOTIONS IN LIMINE
`NOS. 1-4
`
`December 4, 2018
`
`Date:
`9:00 a.m.
`Time:
`Courtroom: Courtroom 12, 19th Floor
`Before:
`Hon. William Alsup
`
`
`
`DECLARATION OF JOSH GLUCOFT ISO
`JUNIPER’S OPPOSITIONS TO FINJAN’S
` MOTIONS IN LIMINE NOS. 1-4
`Case No. 3:17-cv-05659-WHA
`
`

`

`Case 3:17-cv-05659-WHA Document 260 Filed 11/27/18 Page 2 of 4
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`DECLARATION OF JOSH GLUCOFT
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`I, Josh Glucoft, declare as follows:
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`1.
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`I am a member in good standing of the State Bar of California and an associate at
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`Irell & Manella LLP, counsel of record in this action for Defendant Juniper Networks, Inc.
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`(“Juniper”). I have personal knowledge of the facts set forth in this declaration, and I could and
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`would testify competently thereto if called upon to do so. I make this declaration in support of
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`Juniper’s Oppositions to Finjan, Inc.’s Motions in Limine Nos. 1-4.
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`2.
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`Attached as Exhibit 1 is a true and correct copy of a LinkedIn profile of Anthony
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`Pham.
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`3.
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`Attached as Exhibit 2 is a true and correct copy of Juniper’s First Supplement to
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`Initial Disclosures, dated September 10, 2018.
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`4.
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`Attached as Exhibit 3 is a true and correct copy of Juniper’s Second Supplement to
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`Initial Disclosures, dated November 5, 2018.
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`5.
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`Attached as Exhibit 4 is a true and correct copy of an email that I sent to Kristopher
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`Kastens, dated November 7, 2018.
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`6.
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`Attached as Exhibit 5 is a true and correct copy of excerpts from Juniper’s
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`Objections and Responses to Finjan’s Fourth Set of Interrogatories, dated May 29, 2018.
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`7.
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`Attached as Exhibit 6 is a true and correct copy of excerpts from the deposition of
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`Eric B. Cole, taken November 14, 2018.
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`8.
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`Attached as Exhibit 7 is a true and correct copy of an email that I sent to Kristopher
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`Kastens, dated September 10, 2018.
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`9.
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`Attached as Exhibit 8 is a true and correct copy of excerpts from the Expert
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`Rebuttal Report of Aviel D. Rubin, dated October 11, 2018.
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`Attached as Exhibit 9 is a true and correct copy of excerpts from the Expert Report
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`of Dr. Eric Cole, dated September 10, 2018.
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`11.
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`Attached as Exhibit 10 is a true and correct copy of excerpts from IPR2015-01892,
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`Patent Owner’s Response.
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`- 1 -
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`DECLARATION OF JOSH GLUCOFT ISO
`JUNIPER’S OPPOSITIONS TO FINJAN’S
` MOTIONS IN LIMINE NOS. 1-4
`Case No. 3:17-cv-05659-WHA
`
`

`

`Case 3:17-cv-05659-WHA Document 260 Filed 11/27/18 Page 3 of 4
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`12.
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`Attached as Exhibit 11 is a true and correct copy of excerpts from IPR2016-00159,
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`Patent Owner’s Response.
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`13.
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`Attached as Exhibit 12 is a true and correct copy of excerpts from the deposition of
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`Eric B. Cole, taken on June 21, 2018.
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`14.
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`Attached as Exhibit 13 is a true and correct copy of an excerpt from Merriam-
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`Webster’s definition of “the” available at
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`https://web.archive.org/web/20180619213854/https://www.merriam-webster.com/dictionary/the.
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`15.
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`Attached as Exhibit 14 is a true and correct copy of F5 Networks, Inc. v. Radware,
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`Inc., Dkt. No. 173, No. 3:17-cv-03166-VC (N.D. Cal. Nov. 19, 2018).
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`16.
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`Attached as Exhibit 15 is a true and correct copy of excerpts from the deposition of
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`David Kroll, taken on November 16, 2018.
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`17.
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`Attached as Exhibit 16 is a true and correct copy of excerpts from the Expert
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`Report of Kevin M. Arst, dated September 11, 2018.
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`18.
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`Attached as Exhibit 17 is a true and correct copy of excerpts from the deposition of
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`Alessandro Orso, Ph.D., taken on October 26, 2018.
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`19.
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`Attached as Exhibit 18 is a true and correct copy of excerpts from the Expert
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`17
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`Report of Aviel D. Rubin, dated September 11, 2018.
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`20.
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`Attached as Exhibit 19 is a true and correct copy of D. Gryaznov, “Scanners of the
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`Year 2000: Heuristics”, Virus Bulletin Conference, September 1995.
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`Attached as Exhibit 20 is a true and correct copy of excerpts from the Expert
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`Damages-Related Rebuttal Report of Aviel D. Rubin, dated November 7, 2018.
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`22.
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`Attached as Exhibit 21 is a true and correct copy of excerpts from the Rebuttal
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`Expert Report of Keith R. Ugone, Ph.D., dated November 7, 2018.
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`23.
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` Attached as Exhibit 22 is a true and correct copy of excerpts from the Expert
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`Rebuttal Report of Dr. Alessandro Orso, dated October 11, 2018.
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`24.
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`Attached as Exhibit 23 is a true and correct copy of excerpts from the deposition of
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`John Garland, take on November 2, 2018.
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`- 2 -
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`DECLARATION OF JOSH GLUCOFT ISO
`JUNIPER’S OPPOSITIONS TO FINJAN’S
` MOTIONS IN LIMINE NOS. 1-4
`Case No. 3:17-cv-05659-WHA
`
`

`

`Case 3:17-cv-05659-WHA Document 260 Filed 11/27/18 Page 4 of 4
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`
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`Dated: November 23, 2018
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`Respectfully submitted,
`
`IRELL & MANELLA LLP
`
`By: /s/ Joshua Glucoft
`Josh Glucoft (SBN 301249)
`jglucoft@irell.com
`1800 Avenue of the Stars, Ste 900
`Los Angeles, California 90067
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`Attorneys for Defendant
`JUNIPER NETWORKS, INC.
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`- 3 -
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`DECLARATION OF JOSH GLUCOFT ISO
`JUNIPER’S OPPOSITIONS TO FINJAN’S
` MOTIONS IN LIMINE NOS. 1-4
`Case No. 3:17-cv-05659-WHA
`
`