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`DECLARATION OF SHELLY GUPTA
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`I Shelly Gupta, declare as follow:
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`1. I have personal knowledge of the facts set forth in this declaration, and I could and would
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`testify competently thereto if called upon to do so.
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`2. I am a Senior Director of Finance at Juniper Networks, Inc., I am responsible for managing a
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`team of professionals which provides finance support to Juniper’s Research and
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`Development Centers. In my role I help to oversee Juniper’s revenues and operating
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`expenses.
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`3. I have been deposed on two separate occasions in this case, most recently yesterday,
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`December 7, 2018.
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`4. I understand from Finjan’s Offer of Proof (Dkt. 303) that Finjan seeks to calculate revenues
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`for SRX devices associated with free Sky ATP licenses using the “Shipment Quantity” and
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`“Shipments Net Value” columns (columns G and H) in the spreadsheet marked JNPR-
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`FNJN_29028_01012873. However, these columns do not identify the net values associated
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`with the specific SRX devices for which a free Sky ATP license was activated (devices
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`which the spreadsheet identifies by unique Serial Number). Instead, these columns expose
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`the value of all products from a particular SRX product line that were included in the same
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`sales order with the specific Sky ATP-enabled SRX devices (identified by Serial Number).
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`For example, in Column L (“Sales Order Number”) as sorted in ascending order, Row 26
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`reflects a sales order that included 200 SRX300 devices, only one of which was enabled to
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`use the free version of Sky ATP.
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`Case 3:17-cv-05659-WHA Document 305-1 Filed 12/08/18 Page 2 of 3
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`Finjan’s proposed $7.2 million number includes the revenues for the other 199 SRX300
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`devices included in this shipment—SRX devices that were not used with the free version
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`of Sky ATP. Finjan repeats this same error for each of the shipments covered by the
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`spreadsheet.
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`5. Additionally, Finjan’s use of the Shipment Quantity and Shipment Net Value columns leads
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`to double counting. The spreadsheet includes a separate row for each Sky ATP-enabled SRX
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`device (identified by Serial Number). In turn, each row includes information regarding the
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`sales order in which that specific device was included. For those sales orders that included
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`more than one Sky ATP-enabled SRX device, there are therefore multiple corresponding
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`rows in the spreadsheet (one row for each Sky ATP enabled SRX device), all of which refer
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`to the same sales order. For example, the rows highlighted in the below image refer to a
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`single sales order that included 3 SRX1500-AC units that were enabled with Sky ATP.
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`The fact that these three rows refer to the same sales order is clear from the fact that they
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`all have the identical Sales Order Number (15015402). But when Finjan manipulated the
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`spreadsheet to come up with its alleged $7.2 million revenue figure, Finjan counted the
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`revenue from that single sales order three times.
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`6. During my deposition yesterday I became concerned that Finjan might overstate the relevant
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`financial figures associated with SRX devices enabled to use the free version of Sky ATP. I
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`stated that the Drop Ship tab contains a larger population of data than is relevant and made
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`clear that Finjan should use the “us_prod tab.” I explained that the “us_prod” reflects the
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`values of SRX units enabled with free Sky ATP.
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`- 2 -
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`Case 3:17-cv-05659-WHA Document 305-1 Filed 12/08/18 Page 3 of 3
`Case 3:17-cv-05659-WHA Document 305-1 Filed 12/08/18 Page 3 of 3
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`ExecutedDecember8, 2018 at anta (IgAQ California. Ideclareunder
`penalty ofperjury underthe laws ofthe United States ofAmerica that the foregoingis true
`and correct.
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`Shelly Gupta
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