`Case 3:17-cv-05659-WHA Document 410-1 Filed 03/28/19 Page 1 of 3
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`EXHIBIT A
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`Case 3:17-cv-05659-WHA Document 410-1 Filed 03/28/19 Page 2 of 3
`HIGHLY CONFIDENTIAL - OUTSIDE ATTORNEYS EYES ONLY
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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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` --oOo--
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`FINJAN, Inc., a Delaware
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`corporation
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` Plaintiff,
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` vs. Case No. 3:17-cv-05659-WHA
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`JUNIPER NETWORKS, INC., a
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`Delaware corporation
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` Defendant.
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`_____________________________
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` HIGHLY CONFIDENTIAL, OUTSIDE ATTORNEYS EYES ONLY
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` 30(b)(6) VIDEOTAPED DEPOSITION OF
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` JOHN GARLAND
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` Thursday, May 24, 2018
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`Reported by:
`
`COREY W. ANDERSON
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`CSR No. 4096
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`Job No. 2923791
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`Pages 1 - 258
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`Veritext Legal Solutions
`866 299-5127
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`Case 3:17-cv-05659-WHA Document 410-1 Filed 03/28/19 Page 3 of 3
`HIGHLY CONFIDENTIAL - OUTSIDE ATTORNEYS EYES ONLY
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`legitimacy and come up with a format that would work 15:52:52
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`for both companies to allow this exchange. 15:52:56
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` And so for sure I can recall, you know, 15:53:00
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`sharing some information as a way, meaning patents 15:53:04
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`and specific products, as a way of convincing him 15:53:07
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`that we had legit analysis and we were willing to 15:53:10
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`share it. 15:53:12
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` BY MS. CARSON: 15:53:14
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` Q. Can you describe for me everything you 15:53:15
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`remember specifically about disclosing the '494 15:53:17
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`patent during your phonecall with Mr. Coonan? 15:53:21
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` MS. KOBIALKA: Objection to form. 15:53:24
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` THE WITNESS: So it would be the '494 and 15:53:28
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`it relates to the SRX gateways or Sky ATP, I don't 15:53:29
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`recall which it is, have to look at the claim chart, 15:53:33
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`and then the vice versa for the '154. The one was 15:53:38
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`mapped to SRX and one was mapped to the ATP. 15:53:43
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` BY MS. CARSON: 15:53:48
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` Q. Can you recall anything else that you 15:53:54
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`specifically told Mr. Coonan during your phone call 15:53:56
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`about the '494 or '154 patents? 15:54:00
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` MS. KOBIALKA: Objection, form. 15:54:03
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` THE WITNESS: No. As I stated, I knew 15:54:09
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`that I had those three ready to go, I knew I had 15:54:10
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`three more that were going to be converted to the 15:54:13
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`Page 217
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