Case 3:17-cv-05659-WHA Document 360-3 Filed 01/24/19 Page 1 of 5
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`Exhibit 2
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`Case 3:17-cv-05659-WHA Document 360-3 Filed 01/24/19 Page 2 of 5
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`PAUL 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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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCICO 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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`PLAINTIFF FINJAN, INC.’S FIRST SET
`OF REQUESTS FOR PRODUCTION OF
`DOCUMENTS TO DEFENDANT
`JUNIPER NETWORKS, INC. (NOS. 1-60)
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`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
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`CASE NO. 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 360-3 Filed 01/24/19 Page 3 of 5
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`6.
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`The term “Accused Instrumentalities” shall include the following Juniper products and
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`services: Defendant’s SRX Gateways including the: SRX110; SRX220; SRX300; SRX550; SRX1400;
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`SRX1500; SRX3400; SRX3600; SRX4000; SRX5400; SRX5600; and SRX5800 gateway appliances,
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`as well as the vSRX Virtual Firewall and cSRX Container Firewall (collectively, “SRX Gateways”) as
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`described in the Complaint, including but not limited to at Exhibit 9 and paragraphs 43-52;
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`Defendant’s Sky Advanced Threat Protection or “Sky ATP” and Advanced Threat Protection
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`Appliance, as described in the Complaint, including but not limited to at Exhibit 10 and paragraphs 43-
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`52; Defendant’s Junos Space Security Director, as described in the Complaint, including but not
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`limited to at Exhibit 16 and paragraphs 43-52; and Defendant’s Contrail, as described in the
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`Complaint, including but not limited to at Exhibit 17 and paragraphs 43-52. The term “Accused
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`Instrumentalities” shall also include any and all previous or currently contemplated versions, revisions,
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`releases, or continuations of said Juniper products and services, and all additional products accused of
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`infringement by Finjan in this action in infringement contentions or similar pleadings.
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`7.
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`The term “person” or “entity” shall refer to any individual, corporation, proprietorship,
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`association, joint venture, company, partnership, or other business or legal entity, including
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`governmental bodies and agencies. The masculine includes the feminine and vice versa; the singular
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`includes the plural and vice versa.
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`8.
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`The term “document(s)” shall have the broadest meaning ascribed to it by Federal Rule
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`of Civil Procedure 34 and Federal Rule of Evidence 1001, and shall include within its meaning any and
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`all papers, videotapes or video recordings, photographs, films, recordings, memoranda, books, records,
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`accounts, letters, telegrams, correspondence, notes of meetings, notes of conversations, notes of
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`telephone calls, inter-office memoranda or written communications of any nature, recordings of
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`conversations either in writing or by means of any mechanical or electrical recording device, notes,
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`papers, reports, analyses, invoices, canceled checks or check stubs, receipts, minutes of meetings, time
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`sheets, diaries, desk calendars, ledgers, schedules, licenses, financial statements, telephone bills, logs,
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`and any differing versions of the foregoing whether denominated formal, informal, or otherwise, as
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`well as copies of the foregoing which differ in any way, including handwritten notations or other
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`2
`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
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`CASE NO. 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 360-3 Filed 01/24/19 Page 4 of 5
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`REQUEST FOR PRODUCTION NO. 18:
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`Documents, communications, or things sufficient to show the in-licensing or out-licensing of
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`patents or technology related to the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 19:
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`Documents, communications, or things sufficient to show the first offer for sale and sale of each
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`of the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 20:
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`Documents, communications, or things sufficient to show any sales or revenue generated from
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`each of the Accused Instrumentalities from the year 2012 to the present.
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`REQUEST FOR PRODUCTION NO. 21:
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`Documents, communications, or things sufficient to show the sales or revenue forecasts for each
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`of the Accused Instrumentalities generated in the past six (6) years, which forecast sales or revenue for
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`the year 2012 or any year past 2012.
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`REQUEST FOR PRODUCTION NO. 22:
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`Documents, communications, or things sufficient to show the market share of each of the
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`Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 23:
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`Documents, communications, or things sufficient to show the pricing of each of the Accused
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`Instrumentalities from the year 2012 to the present.
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`REQUEST FOR PRODUCTION NO. 24:
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`Documents, communications, or things sufficient to show the costs associated with of each of
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`the Accused Instrumentalities from the year 2012 to the present, including but not limited to,
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`production costs, marketing costs, distribution costs, research and development costs, advertising costs
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`and costs to update.
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`REQUEST FOR PRODUCTION NO. 25:
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`Documents, communications, or things sufficient to show the gross profits of each of the
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`Accused Instrumentalities from the year 2012 to the present.
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`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
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`CASE NO. 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 360-3 Filed 01/24/19 Page 5 of 5
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`REQUEST FOR PRODUCTION NO. 60:
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`Documents, communications, or things sufficient to show any of Your business plans within
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`the past six (6) years.
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`Dated: February 23, 2018
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`By: /s/ Kristopher Kastens
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`Paul J. Andre (State Bar. No. 196585)
`Lisa Kobialka (State Bar No. 191404)
`James Hannah (State Bar No. 237978)
`Kristopher Kastens (State Bar No. 254797)
`KRAMER LEVIN NAFTALIS
`& FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`pandre@kramerlevin.com
`lkobialka@kramerlevin.com
`jhannah@kramerlevin.com
`kkastens@kramerlevin.com
`
`
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`
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`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
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