Case 3:17-cv-05659-WHA Document 365-5 Filed 01/31/19 Page 1 of 5
`Case 3:17-cv-05659-WHA Document 365-5 Filed 01/31/19 Page 1of5
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`EXHIBIT 4
`EXHIBIT 4
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`Case 3:17-cv-05659-WHA Document 365-5 Filed 01/31/19 Page 2 of 5
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`Case Clip(s) Detailed Report
`Thursday, December 13, 2018, 7:27:30 AM
`
`Finjan v. Juniper
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`Gupta, Shelly (Vol. 01) - 12/07/2018
`1 CLIP (RUNNING 00:12:14.590)
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`Plaintiff's Deposition Designations for Shelly Gupta - with Juniper's Counters (12-07-18)
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`16 SEGMENTS (RUNNING 00:12:14.590)
`SG1207-C
`1. PAGE 6:05 TO 6:10 (RUNNING 00:00:10.805)
` 05 Q. Please state your name for the record.
` 06 A. Shelly Gupta.
` 07 Q. Where do you work?
` 08 A. Juniper Networks.
` 09 Q. What is your position?
` 10 A. Senior Director of Finance.
`2. PAGE 23:10 TO 23:11 (RUNNING 00:00:05.261)
` 10 Q. (By Mr. Manes) Could you please open Exhibit 5
` 11 on the computer in front of you.
`3. PAGE 23:14 TO 23:14 (RUNNING 00:00:11.465)
` 14 THE WITNESS: Okay. Exhibit 5. Got it.
`4. PAGE 23:15 TO 23:21 (RUNNING 00:00:23.384)
` 15 Q. (By Mr. Manes) You've seen this document
` 16 before; correct?
` 17 A. Yes, I have.
` 18 Q. Do you know what it is?
` 19 A. My understanding of this document is that it
` 20 contains information about SRX units on which the free
` 21 Sky ATP license was enabled.
`5. PAGE 50:03 TO 50:08 (RUNNING 00:00:17.812)
` 03 Q. (By Mr. Manes) And on the printout, the grand
` 04 total of shipment quantity at serial number is 121;
` 05 correct?
` 06 A. On the printout that you show me, yes. The
` 07 grand total is 121 for shipment quantity at serial
` 08 number.
`6. PAGE 51:11 TO 51:16 (RUNNING 00:00:21.226)
` 11 Q. And please filter by the 13 SKU numbers that
` 12 are on the printout that I've handed you. And let me
` 13 know if the grand totals in the printout that I've
` 14 handed you accurately reflect the drop ship tab of
` 15 Exhibit 5?
` 16 A. So I'm going to go to Column M, which says
`7. PAGE 51:17 TO 51:21 (RUNNING 00:01:21.221)
` 17 "material over length part number key." I will select
` 18 SRX1500-AC, SRX1500-CHAS, SRX300, SRX340, SRX345,
` 19 SRX4100-AC, SRX4200-AC, SRX5400E-B2-AC,
` 20 SRX5400X-B5-AC-BB, SRX5600X-BASE, SRX5800BASE-HC-DC,
` 21 SRX5800E-B1-AC-TAA, and SRX5800X-BASE.
`8. PAGE 51:22 TO 52:04 (RUNNING 00:00:52.233)
` 22 These are all the SKUs that are on the printed
` 23 copy, and they seem to be the complete list of SKUs on
` 24 the spreadsheet as well. If I filter on them and I do a
` 25 sum total of Column G, which is the shipment -- sorry --
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`CONFIDENTIAL
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`page 1
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`Case 3:17-cv-05659-WHA Document 365-5 Filed 01/31/19 Page 3 of 5
`
`Case Clip(s) Detailed Report
`Thursday, December 13, 2018, 7:27:30 AM
`
`Finjan v. Juniper
`
` 00052:01 of Column H, which is the shipment net value, the sum
` 02 total is 7,219,586.09, which matches the number
` 03 represented in the grand total of shipments net value.
` 04 The printed copy that was handed to me.
`9. PAGE 52:05 TO 52:11 (RUNNING 00:00:33.807)
` 05 If I do a sum total of Column G, which is the
` 06 shipment quantity, the sum total is 2,162, which matches
` 07 the shipment quantity column on the printed copy.
` 08 And if I do a sum total of Column E, which is
` 09 the shipment quantity at serial number, it is 121, which
` 10 matches the sum of shipment quantity at serial number
` 11 column grand total on the printed copy.
`10. PAGE 52:22 TO 53:08 (RUNNING 00:00:25.504)
` 22 Q. (By Mr. Manes) Can we agree that all of the
` 23 numbers that we've just went over are accurately
` 24 reflected on the printout as you've just read them from
` 25 the drop ship tab?
` 00053:01 A. So all the numbers that we looked at and we
` 02 tied one by one, yes, they tie -- for the columns that
` 03 we looked at tie with the columns that are represented
` 04 on the printed copy.
` 05 Q. Okay.
` 06 I'd like to mark the printed copy I've handed
` 07 you as Exhibit 12.
` 08 (Exhibit 12 was marked for identification.)
`11. PAGE 53:09 TO 53:09 (RUNNING 00:00:03.422)
` 09 Q. (By Mr. Manes) Please open back up Exhibit 3.
`12. PAGE 69:04 TO 70:21 (RUNNING 00:03:29.162)
` 04 Q. Please push "okay."
` 05 For Cell B5, what number do you have under the
` 06 sum of achievement net for Branch SRX products?
` 07 A. So for the products that we just selected, Cell
` 08 B5 on my spreadsheet shows 4,866,086.
` 09 Q. For Cell C5, what value do you show for the sum
` 10 of achievement cost for the Branch SRX Series -- or
` 11 Branch SRX category? Excuse me.
` 12 A. So for Cell C5, which is the sum of achievement
` 13 cost for the Branch SRX SKUs that we just selected, it
` 14 shows 2,423,095.
` 15 Q. And for Cell D5 under Branch SRX category, what
` 16 value do you show in the sum of achievement quantity?
` 17 A. Sum of achievement quantity in Cell B5 for the
` 18 SKUs that we selected under Branch SRX shows 5,546.
` 19 Q. Moving down to Row 16, which shows the High-End
` 20 SRX Series, what value do you show in Cell B16, which is
` 21 the sum of achievement net for the High-End SRX Series?
` 22 A. Cell B16, for the High-End SRX Series SKUs that
` 23 we selected, sum of achievement net is 7,913,610.
` 24 Q. For Cell C16?
` 25 A. Cell C16, which is sum of achievement cost for
` 00070:01 the High-End SRX SKUs that we selected, it shows
` 02 1,468,930.
` 03 Q. And for Cell D16?
` 04 A. D16, which is the sum of achievement quantity
` 05 for High-End SRX SKUs that we selected, it is 235.
` 06 Q. And for Cell B22, which is the Mid-End SRX
` 07 Series?
` 08 A. Cell B22 for Mid-End SRX Series for the SKUs
` 09 that we selected reads 2,571,104.
` 10 Q. And Cell C22?
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`CONFIDENTIAL
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`page 2
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`Case 3:17-cv-05659-WHA Document 365-5 Filed 01/31/19 Page 4 of 5
`
`Case Clip(s) Detailed Report
`Thursday, December 13, 2018, 7:27:30 AM
`
`Finjan v. Juniper
`
` 11 A. C22, which is the sum of achievement cost for
` 12 Mid-End SRX Series for SKUs that we selected, it reads
` 13 1,274,531.
` 14 Cell D22 which is sum of quantity for the
` 15 Mid-End Series SKUs that we selected, it reads 713.
` 16 Q. And for Cell B27?
` 17 A. Cell B27, which is Sky ATP for SKUs that we
` 18 selected, it reads 614,840; Cell C27 reads 0; and Cell
` 19 D27 reads 219.
` 20 Q. And just for the record, Cell C27 is the sum of
` 21 achievement cost for Sky ATP; correct?
`13. PAGE 70:23 TO 71:22 (RUNNING 00:01:45.267)
` 23 Q. (By Mr. Manes) In the view that we're looking
` 24 at here.
` 25 A. So what we're looking at is Column C represents
` 00071:01 sum of achievement cost.
` 02 Q. And Cell C27 in this view would represent the
` 03 sum of achievement cost for Sky ATP; correct?
` 04 A. So as I said, Column C is the achievement --
` 05 sum of achievement cost for the SKUs that is represented
` 06 in Cell -- in Column A.
` 07 Q. Right. And so Cell C27 reads zero; correct?
` 08 A. Cell C27 reads zero.
` 09 Q. And Cell D27 reads what?
` 10 A. Cell D27 reads 219.
` 11 Q. And finally in Row 41, which is the grand total
` 12 of the SKUs that we selected, Cell B41 reads what as a
` 13 grand total for the sum of achievement net for the SKUs
` 14 that we selected?
` 15 A. Cell B41, grand total reads 15,965,640.
` 16 Q. Cell C41 reads what for sum of achievement cost
` 17 for the SKUs that we selected?
` 18 A. Cell C41, which is the grand total column,
` 19 reads 5,166,556.
` 20 Q. And Cell D41, which is sum of achievement
` 21 quantity, reads what for the grand total?
` 22 A. Cell D41, grand total reads 6,713.
`14. PAGE 71:23 TO 72:07 (RUNNING 00:00:26.468)
` 23 Q. Could you please save the current pivot table
` 24 that you're looking at on your -- on the laptop in front
` 25 of you. Save it as a local copy, if you know how to do
` 00072:01 that.
` 02 MS. CURRAN: Do you want her to save it to the
` 03 desktop?
` 04 MR. MANES: Save it to the desktop, please.
` 05 THE WITNESS: Then should I name it
` 06 differently?
` 07 MR. MANES: We can name it Exhibit 13.
`15. PAGE 95:24 TO 96:10 (RUNNING 00:00:36.033)
` 24 Q. (By Mr. Manes) Ms. Gupta, off the record, we
` 25 saved the pivot table from what has been marked as
` 00096:01 Exhibit 13 as a new pdf on your laptop with both counsel
` 02 and yourself watching; is that correct?
` 03 A. That's correct.
` 04 Q. Can you please verify that the PDF that we just
` 05 discussed matches the pivot table of Exhibit 13 and the
` 06 values are accurate.
` 07 A. Yep.
` 08 MR. MANES: I'd like to mark that pdf as
` 09 Exhibit 16.
` 10 (Exhibit 16 was marked for identification.)
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`CONFIDENTIAL
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`page 3
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`Case 3:17-cv-05659-WHA Document 365-5 Filed 01/31/19 Page 5 of 5
`
`Case Clip(s) Detailed Report
`Thursday, December 13, 2018, 7:27:30 AM
`
`Finjan v. Juniper
`
`16. PAGE 97:01 TO 97:21 (RUNNING 00:01:11.520)
` 00097:01 Q. And I believe you mentioned a difference
` 02 between the drop ship sheet and the US_prod sheet in
` 03 terms of calculating figures. Could you just expand on
` 04 that.
` 05 A. Okay.
` 06 So my understanding is that US_prod tab
` 07 includes the free Sky ATP license, includes the
` 08 information around the free Sky ATP licenses that were
` 09 enabled on the SRX SKUs. So -- or the other way to say
` 10 it would be it is those SRX SKUs for which the device
` 11 I.D. is mentioned in Column A, on which the free Sky ATP
` 12 licenses were enabled.
` 13 That is what US_prod column -- US_prod
` 14 spreadsheet says.
` 15 Q. And how does that differ from the drop ship
` 16 sheet, if at all?
` 17 A. So drop ship is the total subset -- is the
` 18 total population, and US_prod is just those relevant SRX
` 19 SKUs on which the free Sky ATP licenses have been
` 20 enabled. So drop ship is a much larger population, and
` 21 US_prod is a subset of that information.
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`TOTAL: 1 CLIP FROM 1 DEPOSITION (RUNNING 00:12:14.590)
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`CONFIDENTIAL
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`page 4
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