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`Exhibit 1
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`Case 3:17-cv-05659-WHA Document 292-1 Filed 12/04/18 Page 2 of 2
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`Page 54
`·1· ·whether SRX customers had enabled a license to Sky
`·2· ·ATP?
`·3· · · · · · MS. CAIRE:· Objection; form.
`·4· · · · · · THE WITNESS:· It was relevant insofar as
`·5· ·I'm aware that that's been made part of the
`·6· ·discovery record in this case.
`·7· ·BY MS. CARSON:
`·8· · · · Q.· Do you know how many SRX customers in the
`·9· ·U.S. during the damages period enabled a license to
`10· ·Sky ATP?
`11· · · · · · MS. CAIRE:· Objection; form.
`12· · · · · · THE WITNESS:· My recollection is that
`13· ·Juniper does not track that information and that's
`14· ·not evidence that's available in the case.· So I
`15· ·don't know.
`16· ·BY MS. CARSON:
`17· · · · Q.· How many Sky ATP licenses did you identify
`18· ·in your analysis?
`19· · · · A.· I would refer you to supplemental Exhibit
`20· ·1.4, which identifies 211 Sky ATP units in the U.S.
`21· ·and 547 worldwide between Q4 2015 and Q1 2017.
`22· · · · Q.· When you say "units," do you mean licenses?
`23· · · · A.· If memory serves, those are paid licenses.
`24· · · · Q.· Okay.· Was that relevant to your analysis?
`25· · · · · · MS. CAIRE:· Objection; form.
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`Page 55
`·1· · · · · · THE WITNESS:· It's part of my analysis.
`·2· ·BY MS. CARSON:
`·3· · · · Q.· Would you agree that that -- what was the
`·4· ·number, 220?· Is that what you said?
`·5· · · · A.· I quantified --
`·6· · · · Q.· Oh, 211, sorry.· Just strike my question.
`·7· · · · A.· Sure.
`·8· · · · Q.· Would you agree that 211 licenses
`·9· ·represents a relatively small proportion of the
`10· ·overall SRX units?
`11· · · · · · MS. CAIRE:· Objection; form.
`12· · · · · · THE WITNESS:· Arithmetically, it does.
`13· ·BY MS. CARSON:
`14· · · · Q.· It's less than 1 percent; correct?
`15· · · · · · MS. CAIRE:· Objection; form.
`16· · · · · · THE WITNESS:· (Witness using calculator.)
`17· · · · · · Yes.
`18· · · · · · (Deposition Exhibit 1164 was marked for
`19· · · · · · identification)
`20· ·BY MS. CARSON:
`21· · · · Q.· In the Exhibit 1064 -- do you see that?
`22· · · · · · MS. CAIRE:· Counsel, it's 1164.
`23· · · · · · MS. CARSON:· 1164.· Sorry.· Still back at
`24· ·last week.
`25· ·//
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`Page 56
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`·1· ·BY MS. CARSON:
`·2· · · · Q.· All right.· Taking a look at Exhibit 1164,
`·3· ·this is a web page from Juniper's website that's
`·4· ·entitled "Juniper Sky Advanced Threat Prevention
`·5· ·Installation Overview."
`·6· · · · · · Do you see that?
`·7· · · · A.· Yes.
`·8· · · · Q.· And do you see it says:
`·9· · · · · · "Although Juniper Sky ATP is a free add-on
`10· · · · · · to an SRX Series device, you must still
`11· · · · · · enable it prior to using it."
`12· · · · · · Do you see that?
`13· · · · A.· Yes.
`14· · · · Q.· And just to be clear, it's my understanding
`15· ·that, in performing your analysis, you did not
`16· ·endeavor to determine how many customers had enabled
`17· ·a Sky ATP license; correct?
`18· · · · A.· Incorrect.
`19· · · · Q.· You did endeavor to determine how many Sky
`20· ·ATP licenses had been enabled?
`21· · · · A.· Yes.· Again, my understanding is that's not
`22· ·tracked by Juniper and that information is not
`23· ·available.
`24· · · · Q.· What is that understanding based upon?
`25· · · · A.· If memory serves, there were some
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`Page 57
`·1· ·interrogatory responses that related to the absence
`·2· ·of information about this subject matter.
`·3· · · · Q.· If that information were available to you,
`·4· ·would it have impacted your analysis?
`·5· · · · · · MS. CAIRE:· Objection; form.
`·6· · · · · · THE WITNESS:· I don't think so in a
`·7· ·material way for the reasons that we've talked about
`·8· ·today.
`·9· ·BY MS. CARSON:
`10· · · · Q.· So if you had learned that only 100
`11· ·customers had enabled a free license to Sky ATP
`12· ·during the damages period, that wouldn't impact your
`13· ·analysis in any way?
`14· · · · · · MS. CAIRE:· Objection; form.
`15· · · · · · THE WITNESS:· I don't think so.· No.
`16· · · · · · My analysis was based on the cost savings
`17· ·methodology, as we've talked about this morning.
`18· ·BY MS. CARSON:
`19· · · · Q.· You served an errata on November 1st;
`20· ·correct?
`21· · · · A.· I don't know when that was sent to you, but
`22· ·that sounds right, because I think we were working
`23· ·on it on Halloween.· So that timing sounds
`24· ·consistent.
`25· · · · Q.· Was the errata your idea?
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