Case 3:17-cv-05659-WHA Document 390-3 Filed 03/14/19 Page 1 of 3
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`DECLARATION OF REBECCA CARSON
`I, Rebecca Carson, declare as follows:
`1.
`I am a member in good standing of the State Bar of California and a partner at Irell
`& Manella LLP, counsel of record in this action for Defendant Juniper Networks, Inc. (“Juniper”).
`I have personal knowledge of the facts set forth in this declaration, and I could and would testify
`competently thereto if called upon to do so.
`2.
`Attached as Exhibit A is a true and correct copy of U.S. Patent No. 8,141,154 (“the
`ʼ154 Patent”) asserted by Plaintiff Finjan, Inc. (“Finjan”) in this matter and the subject of Juniper’s
`opposition to Finjan’s motion for summary judgment.
`3.
`Attached as Exhibit B is a true and correct copy of excerpts of the March 4, 2019
`deposition transcript of Dr. Michael Mitzenmacher, Finjan’s expert with respect to its motion for
`summary judgment related to the ʼ154 Patent.
`4.
`Attached as Exhibit C is a true and correct copy of excerpts of the 10th Edition of
`the IBM Dictionary of Computing.
`5.
`Attached as Exhibit D is a true and correct copy of excerpts of Finjan’s Preliminary
`Claim Constructions Pursuant to Patent Local Rule 4-2, which cites the IBM Dictionary of
`Computing attached as Exhibit C.
`6.
`Attached as Exhibit E is a true and correct copy of excerpts of the 19th Edition of
`Newton’s Telecom Dictionary.
`7.
`Attached as Exhibit F is a true and correct copy of excerpts of the main page on
`Juniper’s website
`for
`the
`SRX
`Series
`Services Gateways,
`at
`available
`https://www.juniper.net/us/en/products-services/security/srx-series/.
`8.
`Attached as Exhibit G is a true and correct copy of excerpts of RFC 2616, the
`standard set forth by the Internet Engineering Task Force regarding Hypertext Transfer Protocol,
`available at https://www.ietf.org/rfc/rfc2616.txt.
`9.
`Attached as Exhibit H is a true and correct copy of excerpts of RFC 3986, the
`standard set forth by the Internet Engineering Task Force regarding Uniform Resource Identifiers,
`available at https://tools.ietf.org/html/rfc3986.
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`10654172
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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 390-3 Filed 03/14/19 Page 2 of 3
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`10.
`Attached as Exhibit I is a true and correct copy of excerpts of the May 30, 2018,
`deposition transcript of Raju Manthena.
`11.
`Attached as Exhibit J a true and correct copy of an excerpt of the source code
`produced by Juniper in this matter.
`12.
`Attached as Exhibit K is a true and correct copy of an excerpt of the page
`“Downloading and Running the Juniper Sky Advanced Threat Prevention Script” from Juniper’s
`website, available at https://www.juniper.net/documentation/en_US/release-independent/sky-
`atp/topics/task/installation/sky-atp-download.html.
`13.
`Attached as Exhibit L is a true and correct copy of excerpts from the prosecution
`history of the ʼ154 Patent.
`14.
`Attached as Exhibit M is a true and correct copy of a document produced by Juniper
`in this matter with starting Bates JNPR-FNJN_29017_00552908. Finjan attached an excerpt from
`this document as Exhibit 14 to its motion for summary judgment.
`15.
`Attached as Exhibit N is a true and correct copy of excerpts from Finjan’s First Set
`of Requests for Production of Documents.
`16.
`Attached as Exhibit O is a true and correct copy of excerpts of the February 7, 2019,
`deposition transcript of Khurram Isla.
`17.
`Attached as Exhibit P is a true and correct copy of excerpts of the Final Written
`Decision (Paper 62) from IPR2015-01979.
`18.
`Attached as Exhibit Q is a true and correct copy of an excerpt of the page “How Is
`Malware Analyzed And Detected?”
`from
`Juniper’s website,
`available
`at
`https://www.juniper.net/documentation/en_US/release-independent/sky-atp/topics/concept/sky-
`atp-malware-analyze.html#.
`19.
`Attached as Exhibit R is a true and correct copy of excerpts of the Patent Owner’s
`Preliminary Response (Paper 7) from IPR2019-00031.
`//
`//
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`10654172
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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 390-3 Filed 03/14/19 Page 3 of 3
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`Executed this 14th day of March, 2019, at Newport Beach, California.
`I declare under penalty of perjury under the laws of the United States of America that the
`foregoing is true and correct.
`
`/s/ Rebecca Carson
`Rebecca Carson
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`10654172
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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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`- 3 -
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