`
`
`
`
`
`
`
`
`
`
`
`
`
`Exhibit 1
`
`
`
`Case 3:17-cv-05659-WHA Document 308-2 Filed 12/09/18 Page 2 of 9
`
`Juniper’s Witnesses
`
`Analysis Group
`
`Keith Ugone
`Managing Principal of
`
`DDX01.5
`
`
`
`SRX Devices Enabled For Sky ATP
`
`Case 3:17-cv-05659-WHA Document 308-2 Filed 12/09/18 Page 3 of 9
`
`60,000
`
`50,000
`
`40,000
`
`30,000
`
`20,000
`
`10,000
`
`57,142
`
`SRX Devices Sx
`Enabled for Sky ATP
`
`DDX01.23
`
`
`
`Case 3:17-cv-05659-WHA Document 308-2 Filed 12/09/18 Page 4 of 9
`Accused Product Revenues
`
`Sky ATP
`
`~$550,000
`
`~1,250,000
`
`
`
`
`
`Total
`~$1,800,000
`
`SRX with Sky ATP enabled
`
`
`
`DDX01.25
`
`
`
`Non-Infringing Alternative
`
`Case 3:17-cv-05659-WHA Document 308-2 Filed 12/09/18 Page 5 of 9
`
`An alternative that:
`
`Y Doesnotinfringe the patent
`
`ls cost-effective
`
`ls acceptable
`
`v Y
`
`Y Is technically feasible
`
`
`
`DDX01.31
`
`
`
`Juniper Had Many Non-Infringing Options
`
`Case 3:17-cv-05659-WHA Document 308-2 Filed 12/09/18 Page 6 of 9
`
`
`
`Delay release
`of Sky ATP
`
`
`
`
`
`
`
`Store JSON
`
`
`Results In A
`
`File Store
`
`
`
`
`
`}|Store Only
`=| Verdict
`
`
`
`Non-infringing
`Uses
`
`
`DDX01.32
`
`
`
`Case 3:17-cv-05659-WHA Document 308-2 Filed 12/09/18 Page 7 of 9
`
`Maximum Royalty
`
`No more than $100,000
`
`JUNIPEL.
`
`TWORKS
`
`
`
`elersecurirt DDX01.34
`
`
`
`Finjan’s Assertion History For The ’494 Patent
`
`Case 3:17-cv-05659-WHA Document 308-2 Filed 12/09/18 Page 8 of 9
`
`Filed
`
`Settled
`
`Filed Settled
`
`Zfavast| Settled
`websense an | Settled
`(ABarracuda| Settled
`Settled
`
`Filed
`
`a p
`
`roofpoint.
`
`®
`
`Settled
`
`Filed
`
`Filed
`
`SOPHOS
`
`(symantec.
`
`Filed
`
`Settled
`
`Settled
`
`BLUE COAT
`
`
`DDX01.36
`
`
`
`November 12, 2015 Email
`Case 3:17-cv-05659-WHA Document 308-2 Filed 12/09/18 Page 9 of 9
`From John Garland To Meredith McKenzie
`
`From: John Garland [john.garland @finjan.com]
`Sent: Thursday, November 12, 2015 1:28:24 PM
`To: Meredith McKenzie
`Subject: Re: Reconnecting, renewing licensing discussions, and introductions.
`imenedhately be bark te yn
`
`“Scott reneged on an offer to assist
`onalitigation matter (his offer)
`against one of our defendants”
`
`
`
`
`
`John Garland
`
`Finjan Director
`Of Business
`Development
`
`Meredith,
`
`il
`BX
`rial
`aid es a HLA
`
`HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY
`
`
`FINJAN-JN 303420
`
`DDX01.38
`
`
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