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`DECLARATION OF REBECCA CARSON
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`I, Rebecca Carson, declare as follows:
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`1.
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`I am a member in good standing of the State Bar of California and a partner at
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`Irell & Manella LLP, counsel of record in this action for Defendant Juniper Networks, Inc.
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`(“Juniper”). I have personal knowledge of the facts set forth in this declaration, and I could and
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`would testify competently thereto if called upon to do so.
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`2.
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`Attached as Exhibit 1 is a true and correct copy of U.S. Patent No. 6,804,780
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`(“the ’780 Patent”) asserted by Plaintiff Finjan, Inc. (“Finjan”) in this matter and the subject of
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`Juniper’s motion for summary judgment.
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`3.
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`Attached as Exhibit 2 is a true and correct copy of excerpts of the prosecution
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`history of the ’780 Patent, which was downloaded from the USPTO website.
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`4.
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`Attached as Exhibit 3 is a true and correct copy of excerpts of Exhibit B-1 to
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`Finjan’s Infringement Contentions charting Claim 9 of the ’780 Patent against the SRX alone
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`and in combination with Sky ATP and ATP Appliance.
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`5.
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`Attached as Exhibit 4 is a true and correct copy of excerpts of Exhibit B-2 to
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`Finjan’s Infringement Contentions charting Claim 9 of the ’780 Patent against Sky ATP.
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`6.
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`Attached as Exhibit 5 is a true and correct copy of excerpts of Exhibit B-3 to
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`Finjan’s Infringement Contentions charting Claim 9 of the ’780 Patent against ATP Appliance,
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`served on March 8, 2018.
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`7.
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`Attached as Exhibit 6 is a true and correct copy of excerpts of the May 24, 2018
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`deposition transcript of John Garland. Mr. Garland served as Finjan’s Rule 30(b)(6) witness on
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`the following topic: “All facts and circumstances regarding any efforts taken to comply with the
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`marking and notice provisions of 35 U.S.C. § 287 with respect to the Asserted Patents, including
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`any efforts by Finjan to ensure compliance by its licensees with said marking provisions.”
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`8.
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`Attached as Exhibit 7 is a true and correct copy of excerpts of Juniper’s Notice of
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`Specific Unmarked Products Under Artic Cat, Inc. v. Bombardier Recreational.
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`9.
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`Attached as Exhibit 8 is a true and correct copy of excerpts of Finjan’s Objections
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`and Response to Juniper’s First Set of Interrogatories (Nos. 1-10).
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`10643460
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`DECLARATION OF REBECCA CARSON ISO
`JUNIPER’S MOTION FOR SUMMARY JUDGMENT
`(Case No. 3:17-cv-05659-WHA)
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`Case 3:17-cv-05659-WHA Document 371-4 Filed 02/14/19 Page 2 of 2
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`10.
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`Attached as Exhibit 9 is a true and correct copy of excerpts of the October 30,
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`2018 deposition transcript of Julie Mar-Spinola.
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`11.
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`12.
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`Exhibit 10 has been intentionally omitted.
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`Attached as Exhibit 11 is a true and correct copy of excerpts of the July 3, 2018
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`deposition transcript of Dr. Michael Mitzenmacher, Finjan’s expert in the first round of summary
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`judgment related to the ‘780 Patent. See Dkt. No. 129-1.
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`13.
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`Attached as Exhibit 12 is a true and correct copy of excerpts of the trial transcript
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`of Finjan Software Ltd. v. Secure Computing Corp., Case No. 06-469-GMS (D. Del.), available
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`at Dkt. No. 228 (Mar. 4, 2008).
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`14.
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`Attached as Exhibit 13 is a true and correct copy of excerpts of the trial transcript
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`of Finjan Software Ltd. v. Secure Computing Corp., Case No. 06-469-GMS (D. Del), available at
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`Dkt. No. 230 (Mar. 6, 2008).
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`15.
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`Attached as Exhibit 14 is a true and correct copy of excerpts of the transcript of
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`the summary judgment hearing in this matter held on July 26, 2018 (Dkt. No. 175).
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`16.
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`Attached as Exhibit 15 is a true and correct copy of excerpts of the Cyphort
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`datasheet produced by Finjan, produced as Bates FINJAN-JN 045296 at 045299.
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`17.
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`Attached as Exhibit 16 is a true and correct copy of excerpts of “Functional
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`Requirements for Uniform Resource Names” by K. Sollins et al., submitted to the Internet
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`Engineering Task Force’s Network Working Group in December 1994, available at
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`https://web.archive.org/web/19991013104107/https://www.ietf.org/rfc/rfc1737.txt.
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`18.
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`Attached as Exhibit 17 is a true and correct copy of excerpts of Volume 3: Sorting
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`and Searching from The Art of Computer Programming by Donald E. Knuth, published in 1973
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`by Addison-Wesley Publishing Company, Inc.
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`Executed this 14th day of February, 2019, at Newport Beach, California.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`/s/ Rebecca Carson
`Rebecca Carson
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`- 2 -
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`DECLARATION OF REBECCA CARSON ISO
`JUNIPER’S MOTION FOR SUMMARY JUDGMENT
`(Case No. 3:17-cv-05659-WHA)
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`10643460
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