`Case 3:17-cv-05659-WHA Document 410-2 Filed 03/28/19 Page 1 of 3
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`EXHIBIT B
`EXHIBIT B
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`Case 3:17-cv-05659-WHA Document 410-2 Filed 03/28/19 Page 2 of 3
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`1 IN THE UNITED STATES DISTRICT COURT
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`2 FOR THE NORTHERN DISTRICT OF CALIFORNIA
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`3 SAN FRANCISCO DIVISION
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` FINJAN, INC., a Delaware )
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`4 5
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`6 Corporation, ) Case No.
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`7 Plaintiff, ) 3:17-cv-05659-WHA
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`8 vs. )
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`9 JUNIPER NETWORKS, INC., a )
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`10 Delaware Corporation, )
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`11 Defendant. ) (Pages 1-326)
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`12 ---------------------------)
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`13 THIS TRANSCRIPT IS DEEMED
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`14 HIGHLY CONFIDENTIAL
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`15 OUTSIDE ATTORNEYS' EYES ONLY
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`16
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`17 REPORTER'S TRANSCRIPTION
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`18 OF THE VIDEOTAPED DEPOSITION OF
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`19 JOHN GARLAND
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`20 FRIDAY, NOVEMBER 2, 2018
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`21
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`22
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`23 TRANSCRIBED BY:
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`24 SUSAN NELSON
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`25 C.S.R. No. 3202
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`Case 3:17-cv-05659-WHA Document 410-2 Filed 03/28/19 Page 3 of 3
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`1 with notice that advanced security modules that use
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`2 security profiles infringe the '494 patent in
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`3 Finjan's view?
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`4 MR. KASTENS: Objection. Form.
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`5 THE WITNESS: I believe so.
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`6 BY MR. KAGAN:
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`7 Q. Okay. But you never mentioned security
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`8 profiles at all during the phone call.
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`9 Is that correct?
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`10 MR. KASTENS: Objection. Form.
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`11 THE WITNESS: I don't mention the security
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`12 profiles, but -- and Juniper had announced an
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`13 advanced malware subscription service -- it's called
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`14 Sky ATP -- in September. And we had analyzed that.
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`15 BY MR. KAGAN:
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`16 Q. You never mentioned security profiles on the
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`17 call. Is that correct?
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`18 A. I did not, yes.
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`19 Q. You never mentioned Sky ATP on the call.
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`20 Is that correct?
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`21 MR. KASTENS: Objection. Form.
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`22 THE WITNESS: I don't mention Sky ATP.
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`23 BY MR. KAGAN:
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`24 Q. Okay. Do you believe on the call you
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`25 provided notice that Juniper's UTM module infringes
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