Case 3:17-cv-05659-WHA Document 390-12 Filed 03/14/19 Page 1 of 3
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`Exhibit I
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`Case 3:17-cv-05659-WHA Document 390-12 Filed 03/14/19 Page 2 of 3
`HIGHLY CONFIDENTIAL SOURCE CODE - ATTORNEYS' EYES ONLY
`Transcript of Raju Manthena
`Conducted on May 30, 2018
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` A P P E A R A N C E S
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`ON BEHALF OF PLAINTIFF FINJAN, INC.:
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` KRISTOPHER B. KASTENS, ESQUIRE
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` SHANKER NAIR, ESQUIRE
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` KRAMER LEVIN NAFTALIS & FRANKEL LLP
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` 990 Marsh Road
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` Menlo Park, California 94025
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` (650) 752-1700
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`ON BEHALF OF DEFENDANT JUNIPER NETWORKS, INC.:
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` REBECCA CARSON, ESQUIRE
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` IRELL & MANELLA LLP
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` 840 Newport Center Drive, Suite 400
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` Newport Beach, California 92660
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` (949) 760-0991
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`ALSO PRESENT:
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` John Torreano, Videographer
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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 : Case No.
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`Corporation, : 3:17-cv-05659-WHA
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` Plaintiff, :
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`v. :
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`JUNIPER NETWORKS, INC., a :
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`Delaware Corporation, :
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` Defendant. :
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` HIGHLY CONFIDENTIAL SOURCE CODE - ATTORNEYS' EYES ONLY
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` VIDEOTAPED DEPOSITION OF RAJU MANTHENA
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` Sunnyvale, California
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` Wednesday, May 30, 2018
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` 9:02 a.m.
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`Job No.: 191865
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`Pages: 1 - 216
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`Reported By: Charlotte Lacey, RPR, CSR No. 14224
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` I N D E X
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` WITNESS PAGE
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` RAJU MANTHENA
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` Examination by Mr. Kastens 7
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` I N D E X O F E X H I B I T S
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` EXHIBITS DESCRIPTION PAGE
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`Exhibit 31 JWAS IP and HTTP cookie feed based 105
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` Policy Enforcement on SRX Software
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` Functional Specification, Bates
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` number JNPR-FNJN_29014_00197203
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`Exhibit 32 Argon SRX Architecture Version 0.6, 113
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` Bates number
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` JNPR-FNJN_29032_00590553
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`Exhibit 33 Reputation Adapter File Hash Lookup, 143
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` Bates number
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` JNPR-FNJN_29017_00553144
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`Exhibit 34 Command and Control Prevention with 148
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` Secintel Software Functional
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` Specification, Bates number
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` JNPR-FNJN_29002_00173383
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`Exhibit 35 SRX Space, Bates number 150
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` JNPR-FNJN_290717_00552579
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`Exhibit 36 SRX Series Services Gateways for the 167
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` VIDEOTAPED DEPOSITION OF RAJU MANTHENA, held at the
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`offices of Juniper Networks, Incorporated,
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`1133 Innovation Way, Building A, Sunnyvale, California
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` Pursuant to notice, before Charlotte Lacey,
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`Certified Shorthand Reporter, in and for the State of
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`California.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`

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`Case 3:17-cv-05659-WHA Document 390-12 Filed 03/14/19 Page 3 of 3
`HIGHLY CONFIDENTIAL SOURCE CODE - ATTORNEYS' EYES ONLY
`Transcript of Raju Manthena
`Conducted on May 30, 2018
`17
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`early software releases that was -- yeah -- that were
`running the AV that you mentioned.
` Q Are you aware of a term uniform -- or sorry
`UTM?
` A Yeah.
` Q And do you know what UTM stands for?
` A Unified threat management.
` Q And are you aware of how -- if there's a
`functionality related to the SRX Gateways that's
`referred to do as UTM?
` A Yeah. So UTM offers features such as AV
`integration and URL filtering.
` THE REPORTER: I'm sorry. "URL"...
` A It's called URL filtering.
` THE REPORTER: "Filtering"?
` A Yes.
` Q And how is the UTM sold?
` MS. CARSON: Objection; form.
` A I don't have definite information on that. I
`think it's better to contact PLM or sales.
` Q Is it like a software package you add to an
`SRX Gateway? Or is it a separate appliance?
` Just, like, what form would a customer acquire
`UTM?
` MS. CARSON: Objection; form.
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` A Okay. In general, yes. In general, this
`virtual product is equal to.
` Q Can the SRX --
` A Yeah, but I just want to make sure that --
`there are -- a virtual environment requires a
`different -- you know, a custom environment is needed.
` THE REPORTER: Can you repeat, please. I'm --
` A So the virtual products require a different
`platform environment.
` THE REPORTER: Thank you.
` Q Can the SRX Gateway scan for malware locally
`on the -- on the system?
` MS. CARSON: Objection; form.
` A We don't use the term "scan." Could you help
`me understand or elaborate with a specific --
` Q Yeah.
` A -- example of what the scan means?
` Q Does the SRX -- do the SRX Gateways have the
`capability to scan files that are seen on the network
`for viruses or malware?
` MS. CARSON: Objection; form.
` A No. SRX doesn't do any file analysis on the
`box -- on the SRX platform.
` Q Can the SRX Gateways have antivirus software
`installed on them?
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` A It's -- it's a software package that -- that
` MS. CARSON: Objection; form.
`gets installed on the SRX operating system. That's
` A So there is an AV, but it's -- it's not part
`Junos.
`of the Juniper developer software. We integrate with
` But the Sophos AV that I -- just to clarify,
`third-party company.
`the Sophos AV that I know of, it's a cloud-based
` Q What AV is currently offered on the SRX
`service. It's the -- when I talk about the third-party
`appliances?
`software labeling, that's only to enable communication
` A It's called Sophos AV.
`between SRX and then the actual Sophos cloud.
` Q Any other AV engines that are currently
` Q So the SRX Gateway with the Sophos AV doesn't
`offered on the SRX Gateways?
` A Not that -- I don't know. Not that I know of.
`do scanning on the box. So just sends information up to
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`the -- Sophos cloud; is that correct?
` Q Do you know if any other antivirus packages
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` MS. CARSON: Objection; form.
`were previously offered on the SRX Gateways?
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` A So that's right. That's right. It doesn't do
` MS. CARSON: Objection; form.
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`any file analysis on the SRX box.
` A No, I don't know.
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` Q Does it extract files?
` Q Are you aware if something called Express AV
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` MS. CARSON: Objection; form.
`was previously offered on the SRX Gateways?
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` A The Junos software extracts the file content
` A I don't have a lot of good information on that
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`and hands it off to the third party, literally.
`one because I haven't worked on that product.
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` Q Do you know if the file is sent to Sophos?
` Q What is your level of understanding of Express
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` MS. CARSON: Objection; form.
`AV?
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` A I'm not aware of that. So I haven't worked
` A I have -- I don't have any understanding on
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`deeply on that particular product. I'd have to consult
`Express AV.
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`the code or the team that actually worked on the
` Q Are you aware Kaspersky was offered as a
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`product.
`antivirus solution on the SRX Gateways?
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` A I don't have a lot of good information on the
` Q And how -- how does Junos extract the file
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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