`Case 3:17-cv-05659-WHA Document 262-2 Filed 11/27/18 Page 1 of 3
`
`
`
`APPENDIX B
`APPENDIX B
`
`
`
`
`
`
`
`Case 3:17-cv-05659-WHA Document 262-2 Filed 11/27/18 Page 2 of 3
`
`APPENDIX B – PLAINTIFF’S WITNESS LIST
`
`PLAINTIFF FINJAN, INC.’S LIST OF FACT AND EXPERT WITNESSES
`
`United States District Court
`For the Northern District of California (San Francisco Division)
`
`
`Finjan, Inc. v. Juniper Networks, Inc.
`
`Case No. 17-cv-05659-WHA Trial Date: December 10, 2018
`
`
`
`Plaintiff Finjan, Inc. (“Finjan”) identifies the following witnesses whom it may call live
`
`or by deposition at trial. This list is not a commitment that Finjan will call any particular witness
`
`at trial, or a representation that any of the witnesses listed are available or will appear for trial. If
`
`any third-party witness is unavailable, Finjan reserves the right to use his or her deposition
`
`testimony. With respect to Juniper Networks, Inc.’s (“Juniper”) witnesses, Finjan reserves the
`
`right to introduce testimony through deposition or live examination, as appropriate. Finjan also
`
`reserves the right to call any witnesses listed or called by Juniper, and to revise this list in light of
`
`further rulings by the Court, including any rulings regarding the amount of time allotted for the
`
`parties to present their case at trial, or any other changed circumstances.
`
`I.
`
`FACT AND EXPERT WITNESSES
`
`A. Witnesses That Finjan Will Call in its Case in Chief:
`
`Witness
`Dr. Kevin Arst
`Dr. Harry Bims
`
`Dr. Eric Cole (expert)
`
`John Garland
`
`Philip Hartstein,
`President of Finjan
`
`Substance of Testimony
`Non-cumulative testimony regarding the damages owed to Finjan
`Non-cumulative testimony regarding a tutorial of the technology
`involved in this case
`Non-cumulative testimony regarding Juniper’s infringement of U.S.
`Patent No. 8,677,494 (the “’494 Patent”); background of the ‘494
`Patent; background of the Accused Products; background of cyber
`security
`
`Non-cumulative testimony regarding Finjan’s licensing
`negotiations with Juniper; notice to Juniper of its infringement of
`the ‘494 Patent
`Non-cumulative testimony regarding Finjan’s business and
`licensing of its patents
`
`1
`
`
`
`Case 3:17-cv-05659-WHA Document 262-2 Filed 11/27/18 Page 3 of 3
`
`APPENDIX B – PLAINTIFF’S WITNESS LIST
`
`Witness
`David Kroll
`
`Dr. Alessandro Orso
`
`Substance of Testimony
`Non-cumulative testimony regarding the field of the art at the time
`of the invention
`Non-cumulative testimony regarding the patentability of the ‘494
`Patent
`
`B. Witnesses That Finjan Will Call by Deposition:
`
`Witness
`Coonan, Scott
`
`Mathena, Raju
`
`Nagarajan, Chandra
`
`Tenorio, Yuly
`
`Substance of Testimony
`Non-cumulative testimony regarding notice of infringement and
`damages owed to Finjan for Juniper’s infringement.
`Non-cumulative testimony regarding the technology of the accused
`products and Juniper’s infringement of the ‘494 Patent.
`Non-cumulative testimony regarding the technology of the accused
`products and Juniper’s infringement of the ‘494 Patent.
`Non-cumulative testimony regarding the technology of the accused
`products and Juniper’s infringement of the ‘494 Patent.
`
`C. Witnesses That Finjan May Call by Deposition:
`
`Witness
`Bushong, Mike
`
`Gupta, Shelly
`
`Manocha, Rakesh
`
`McKenzie, Meredith
`
`
`
`Substance of Testimony
`Non-cumulative testimony regarding the technology of the accused
`products, Juniper’s infringement of the ‘494 Patent, and damages
`owed to Finjan for Juniper’s infringement.
`Non-cumulative testimony regarding damages owed to Finjan for
`Juniper’s infringement.
`Non-cumulative testimony regarding the technology of the accused
`products and Juniper’s infringement of the ‘494 Patent.
`Non-cumulative testimony regarding notice of infringement and
`damages owed to Finjan for Juniper’s infringement.
`
`
`
`
`
`
`
`
`
`
`
`
`
`2
`
`