Case 3:17-cv-05659-WHA Document 358 Filed 01/24/19 Page 1 of 3
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`PAUL J. ANDRE (State Bar No. 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (State Bar No. 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (State Bar No. 237978)
`jhannah@kramerlevin.com
`KRISTOPHER KASTENS (State Bar No. 254797)
`kkastens@kramerlevin.com
`KRAMER LEVIN NAFTALIS
` & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
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`Attorneys for Plaintiff
`FINJAN, INC.
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`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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`v.
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`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
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`Defendant.
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`Case No.: 3:17-cv-05659-WHA
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`DECLARATION OF LISA KOBIALKA IN
`SUPPORT OF PLAINTIFF FINJAN, INC.’S
`OPPOSITION TO DEFENDANT JUNIPER
`NETWORKS INC.’S RENEWED MOTION
`FOR JUDGMENT AS A MATTER OF LAW
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`Date:
`Time:
`Judge:
`Courtroom:
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`February 14, 2019
`8:00 a.m.
`Hon. William Alsup
`12, 19th Floor
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`CASE NO.: 3:17-cv-05659-WHA
`KOBIALKA DECL. IN SUPPORT OF FINJAN’S OPP. TO
`JUNIPER’S RENEWED MTN. FOR JGMT. AS A MATTER OF LAW
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`Case 3:17-cv-05659-WHA Document 358 Filed 01/24/19 Page 2 of 3
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`I, Lisa Kobialka, declare:
`1.
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`I am an attorney with the law firm Kramer Levin Naftalis & Frankel LLP, counsel of
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`record for Finjan, Inc. (“Finjan”). I have personal knowledge of the facts stated herein and can testify
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`competently to those facts. I make this declaration in support of Finjan’s Opposition to Defendant
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`Juniper Networks, Inc.’s (“Juniper”) Renewed Motion for Judgment as a Matter of Law.
`2.
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`Attached hereto as Exhibit 1 is a true and correct copy of Trial Exhibit 256, a transcript
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`of a telephone call between Mr. John Garland of Finjan and Mr. Scott Coonan of Juniper, made by Mr.
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`Coonan, produced by Juniper bearing production numbers JNPR-FNJN_29011_00960575–91.
`3.
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`Attached hereto as Exhibit 2 is a true and correct copy of pages 259-266, 314-315, 319,
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`324, 388-392, 472, 476-478, 513-517, 547-563, 565-568, 586, 592, 603-604, 685-686, and 768-769 of
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`the transcript of trial proceedings held on December 11, 2018 to December 13, 2018, in the present
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`action.
`4.
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`Attached hereto as Exhibit 3 is a true and correct copy of the portions of deposition
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`testimony of Mr. Scott Coonan, taken November 16, 2018, which were presented to the jury by video
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`during trial in the present action.
`5.
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`Attached hereto as Exhibit 4 is a true and correct copy of Trial Exhibit 91, which is a
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`press release titled “Juniper Networks Unveils Advanced Anti-Malware Cloud Service, Security
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`Management and the Latest Firewalls to Protect Cloud-Enabled Enterprise Networks,” dated
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`September 29, 2015, produced by Finjan bearing production numbers FINJAN-JN 400386–89.
`6.
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`Attached hereto as Exhibit 5 is a true and correct copy of the cover page of Trial Exhibit
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`57, a document titled “Juniper Advanced Anti-Malware Service on SRX Software Functional
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`Specification,” dated October 23, 2015, produced by Juniper bearing production number JNPR-
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`FNJN_29002_00173278.
`7.
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`Attached hereto as Exhibit 6 is a true and correct copy of portions of deposition
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`testimony of Mr. Chandra Nagarajan, taken May 31, 2018, which were presented to the jury by video
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`during trial in the present action.
`8.
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`Attached hereto as Exhibit 7 is a true and correct copy of Trial Exhibit 17, a brochure
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`CASE NO.: 3:17-cv-05659-WHA
`KOBIALKA DECL. IN SUPPORT OF FINJAN’S OPP. TO
`JUNIPER’S RENEWED MTN. FOR JGMT. AS A MATTER OF LAW
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`Case 3:17-cv-05659-WHA Document 358 Filed 01/24/19 Page 3 of 3
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`titled “SRX Series Services Gateways for the Branch,” dated May 2017, produced by Finjan bearing
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`production numbers FINJAN-JN 005221–39.
`9.
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`Attached hereto as Exhibit 8 is a true and correct copy of Trial Exhibit 382, a brochure
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`titled “Juniper Sky Advanced Treat Protection,” dated May 2017, produced by Finjan bearing
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`production numbers FINJAN-JN 005438–42.
`10.
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`Attached hereto as Exhibit 9 is a true and correct copy of Trial Exhibit 345, a brochure
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`titled “SRX Series Services Gateways for the Branch,” dated May 2017, produced by Finjan bearing
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`production numbers FINJAN-JN 045192–210.
`11.
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`Attached hereto as Exhibit 10 is a true and correct copy of Trial Exhibit 1, U.S. Patent
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`No. 8,677,494, titled “Malicious Mobile Code Runtime Monitoring System and Methods,” issued on
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`March 18, 2014, produced by Finjan bearing production numbers FINJAN-JN 003821–48.
`12.
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`Attached hereto as Exhibit 11 is a true and correct copy of Trial Exhibit 372, a webpage
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`titled “FinjanMobile VitalSecurity – Android Apps on Goole Play,” printed on January 1, 2017 from
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`the Google Play Store website, available at
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`https://play.google.com/store/apps/details?id=com.finjan.securebrowser&hl=en, produced by Finjan
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`bearing production numbers FINJAN-JN 046254–56.
`13.
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`Attached hereto as Exhibit 12 is a true and correct copy of the “Report and
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`Recommendation,” filed as Docket No. 403 in the matter Blitzsafe Texas, LLC v. Honda Motor Co.,
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`Case No. 2:15-cv-1274-JRG-RSP (E.D. Tex. Jan. 26, 2017).
`14.
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`Attached hereto as Exhibit 13 is a true and correct copy of the “Sealed Memorandum
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`Opinion and Order,” filed unsealed as Docket No. 492 in the matter Realtime Data, LLC v. Actian
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`Corp., Case No. 6:15-cv-00463-RWS-JDL (E.D. Tex. Apr. 4, 2017).
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`I declare under penalty of perjury under the laws of the United States that the foregoing is true
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`and correct. Executed on January 24, 2019 in Menlo Park, California.
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` /s/ Lisa Kobialka
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`Lisa Kobialka
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`CASE NO.: 3:17-cv-05659-WHA
`KOBIALKA DECL. IN SUPPORT OF FINJAN’S OPP. TO
`JUNIPER’S RENEWED MTN. FOR JGMT. AS A MATTER OF LAW
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