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`Exhibit N
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`Case 3:17-cv-05659-WHA Document 390-17 Filed 03/14/19 Page 2 of 6
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`
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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
`
`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)
`
`CASE NO. 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 390-17 Filed 03/14/19 Page 3 of 6
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`Plaintiff Finjan, Inc. (“Finjan”), by counsel, and pursuant to Federal Rule of Civil Procedure
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`33, hereby requests that Defendant Juniper Networks Inc. (“Juniper”) produce the following
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`documents for inspection and copying within thirty (30) days of the date of service of these requests at
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`the offices of Kramer Levin Naftalis & Frankel LLP, 990 Marsh Road in Menlo Park, California
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`94025, in accordance with the following Definitions and Instructions. These requests impose a
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`continuing duty upon Juniper to supplement promptly in accordance with Federal Rule of Civil
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`Procedure 26(e) and the Local Rules of the Northern District of California as Juniper becomes aware
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`of, generates, or acquires additional knowledge or information responsive to these requests.
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`DEFINITIONS
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`1.
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`The terms “You,” “Your,” and “Defendant” shall mean Juniper Networks Inc., Your
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`present and former directors, officers, employees, parent organization(s), subsidiary organization(s),
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`predecessors in interest, successors in interest, divisions, servants, agents, attorneys, consultants,
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`partners, associates, investigators, representatives, accountants, financial advisors, distributors and any
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`other person acting on Your behalf, pursuant to Your authority or subject to Your control, including
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`any and all joint ventures or other legal entities of any type whatsoever in which You own or owned
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`any interest, receive or received any payments, and/or participated or now participate in any manner.
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`2.
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`The term “Finjan” shall mean Finjan, its present and former directors, officers,
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`employees, parent organization(s), subsidiary organization(s), predecessors in interest, successors in
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`interest, divisions, servants, agents, attorneys, consultants, partners, associates, investigators,
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`representatives, accountants, financial advisors, distributors and any other person acting on its behalf,
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`pursuant to its authority or subject to its control.
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`3.
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`The term “third party” shall mean any person or entity other than Finjan or Defendant.
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`4.
`case, filed on September 29, 2017, and any subsequently filed amended complaints. See Dkt. No. 1.
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`The term “Complaint” shall refer to Finjan’s Complaint for Patent Infringement in this
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`5.
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`The term “Asserted Patents” shall mean U.S. Patent Nos.: 6,154,844 (“the ‘844
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`Patent”); 6,804,780 (“the ‘780 Patent”), 7,613,926 (“the ‘926 Patent”); 7,613,633 (“the ‘633 Patent”);
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`8,141,154 (“the ‘154 Patent”), and 8,677,494 (“the ‘494 Patent”), collectively.
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`1
`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
`
`CASE NO. 3:17-cv-05659-WHA
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`
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`Case 3:17-cv-05659-WHA Document 390-17 Filed 03/14/19 Page 4 of 6
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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 390-17 Filed 03/14/19 Page 5 of 6
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`written or printed matter of any nature, from the original. The foregoing specifically includes the
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`information stored in any form, including electronic form, on a computer or in a computer database or
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`otherwise, including electronic mail. Moreover, the term “document” shall also include all “technical
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`documents,” such as source code, specifications, schematics, flow charts, artwork, drawings, pictures,
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`pictorial representations, formulas, troubleshooting guides, service bulletins, technical bulletins,
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`production specification sheets, white papers, operator manuals, operation manuals, and instruction
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`manuals.
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`9.
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`The term “communication” shall mean, including its usual and customary meaning, any
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`transmission, conveyance or exchange of a word, statement, fact, thing, idea, document, instruction,
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`information, demand, or question by any medium, whether by written, oral, or other means, including,
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`but not limited to, electronic communications and electronic mail.
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`10.
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`11.
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`The term “thing” shall mean any tangible object, other than a document.
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`The terms “relate to,” “reflecting,” “relating to,” “concerning,” or any variations
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`thereof, shall mean relating to, referring to, concerning, mentioning, reflecting, regarding, pertaining
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`to, evidencing, involving, describing, discussing, commenting on, embodying, responding to,
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`supporting, contradicting, or constituting (in whole or in part), or are between (as in the context of
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`communications), as the context makes appropriate.
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`12.
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`13.
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`The term “including” shall mean including but not by way of limitation.
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`The words “and” and “or” shall be construed conjunctively or disjunctively in a manner
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`making the request inclusive rather than exclusive.
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`14.
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`15.
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`The term “any” shall mean “any and all” and the term “all” shall mean “any and all.”
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`The singular of any word or phrase shall include the plural of such word or phrase, and
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`the plural of any word or phrase shall include the singular of such word or phrase.
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`INSTRUCTIONS
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`1.
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`In answering the following requests, please furnish all available information including
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`information in the possession, custody, or control of any of Defendant’s attorneys, directors, officers,
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`agents, employees, representatives, associates, investigators, divisions, affiliates, partnerships, parents,
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`3
`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
`
`CASE NO. 3:17-cv-05659-WHA
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`
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`Case 3:17-cv-05659-WHA Document 390-17 Filed 03/14/19 Page 6 of 6
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`REQUEST FOR PRODUCTION NO. 10:
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`All documents, communications, or things related to Your reliance on the advice of counsel as a
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`defense to Finjan’s claim that You willfully infringed and continue to willfully infringe the Asserted
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`Patents.
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`REQUEST FOR PRODUCTION NO. 11:
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`All documents, communications, or things relating to the design, development, structure,
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`architecture, testing, research, updating or operation for each of the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 12:
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`All technical and marketing documents, communications, or things discussing or regarding the
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`components of the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 13:
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`All documents, communications, or things relating to any database or database schema relating
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`to, created for, referenced by, or used by any of the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 14:
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`All documents, communications, or things relating to any presentations, overviews, technical
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`overviews, power point slides, or briefing related to any of the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 15:
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`All documents, communications, or things relating to any API (Application Program Interface)
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`specifications, functional specifications, flow charts, architecture diagrams, or design documents related
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`to any of the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 16:
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`Copies of the source code for each of the Accused Instrumentalities, including but not limited
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`to, all past and present releases, versions, updates, or upgrades.
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`REQUEST FOR PRODUCTION NO. 17:
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`Working copies of the most recent version of each of the Accused Instrumentalities.
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`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
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