`
`
`
`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.
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`SAN FRANCISCO DIVISION
`
`FINJAN, INC., a Delaware Corporation,
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
`
`
`Defendant.
`
`
`
`Case No.: 3:17-cv-05659-WHA
`
`DECLARATION OF KRISTOPHER
`KASTENS IN SUPPORT OF PLAINTIFF
`FINJAN, INC.’S REPLY IN SUPPORT OF ITS
`SECOND MOTION FOR EARLY SUMMARY
`JUDGMENT, REGARDING
`INFRINGEMENT OF CLAIM 1 OF U.S.
`PATENT NO. 8,141,154
`
`Date:
`Time:
`Courtroom:
`Before:
`
`
`May 2, 2019
`8:00 a.m.
`Courtroom 12, 19th Floor
`Hon. William Alsup
`
`
`
`
`KASTENS DECL. IN SUPPORT OF FINJAN’S REPLY
`IN SUPPORT OF ITS MOT. FOR SUMMARY JUDGMENT
`
`CASE NO. 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 415-1 Filed 04/05/19 Page 2 of 2
`
`
`
`I, Kristopher Kastens, duly declare as follows:
`1.
`
`I am an attorney at Kramer Levin Naftalis & Frankel LLP, counsel of record for
`
`plaintiff Finjan Inc. (“Finjan”). I have personal knowledge regarding the statements below and can
`
`testify competently about these statements. I submit this declaration in support of Finjan’s Reply Brief
`
`in Support of Its Motion for Summary Judgment of Infringement of Claim 1 of U.S. Patent No.
`
`8,141,154 (“the ‘154 Patent”) (Dkt. No. 369).
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of pages 33, 125-126, 187, 189-
`
`190, 204-205, 216, 222, 231-232 from the deposition transcript of Aviel Rubin, taken on April 2, 2019.
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of page 12 of the Amendment
`
`and Response to Office Action, dated October 5, 2011, from the file history for the ‘154 Patent,
`
`produced by Finjan bates numbered FINJAN-JN 002041-608.
`4.
`
`Attached hereto as Exhibit 3 is a true and correct copy of page 1 of a web page titled
`
`“Sky Advanced Threat Protection License Types,” produced by Finjan bearing bates numbered
`
`FINJAN-JN 400271-72.
`5.
`
`Attached hereto as Exhibit 4 is a true and correct copy of pages 19, 23 and 24 from
`
`Defendant Juniper Networks, Inc.’s Second Supplemental Response to Plaintiff Finjan, Inc.’s First Set
`
`of Interrogatories, served on June 18, 2018.
`6.
`
`Attached hereto as Exhibit 5 is a true and correct copy of page 51 from U.S. Patent
`
`Application No. 11/298,475.
`
`I declare under penalty of perjury under the laws of the United States of America that each
`
`of the above statements is true and correct. Executed on April 5, 2019, in Menlo Park, California.
`
`/s/ Kristopher Kastens
`Kristopher Kastens
`
`ATTESTATION
`
`Pursuant to Civil Local Rule 5-1(i), the filer attests that concurrence in the filing of this
`
`document has been obtained from the signatories above.
`
`1
`KASTENS DECL. IN SUPPORT OF FINJAN’S REPLY
`IN SUPPORT OF ITS MOT. FOR SUMMARY JUDGMENT
`
`CASE NO. 3:17-cv-05659-WHA
`
`/s/ Lisa Kobialka
`Lisa Kobialka
`
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