Case 3:17-cv-05659-WHA Document 432-14 Filed 04/11/19 Page 1 of 5
`
`Case 3:17-cv-05659-WHA Document 432-14 Filed 04/11/19 Page 1of5
`
`EXHIBIT 13
`
`

`

`Case 3:17-cv-05659-WHA Document 432-14 Filed 04/11/19 Page 2 of 5
`
`Case Clip(s) Detailed Report
`Tuesday, December 11, 2018, 10:33:32 PM
`
`Finjan v. Juniper
`
`Icasiano, Alexander (Vol. 01) - 11/30/2018
`1 CLIP (RUNNING 00:09:22.170)
`
`Plaintiff's Deposition Designations for Alexander Icasiano - Accepted Counters, Juniper's Counters,
`Finjan's Counters (11-30-18)
`
`22 SEGMENTS (RUNNING 00:09:22.170)
`AI1130-CC
`1. PAGE 6:05 TO 6:17 (RUNNING 00:00:24.485)
` 05 ALEXANDER ICASIANO,
` 06 called as a witness for the Plaintiff, having been duly
` 07 sworn, testified as follows:
` 08 THE WITNESS: I do.
` 09 THE VIDEOGRAPHER: Please proceed, Counsel.
` 10 EXAMINATION
` 11 BY MR. LEE:
` 12 Q. Please state your name for the record.
` 13 A. My name is Alexander Icasiano.
` 14 Q. Where do you work?
` 15 A. I work at Juniper Networks.
` 16 Q. What is your position at Juniper Networks?
` 17 A. I'm a manager of the DevOps team for Sky ATP.
`2. PAGE 6:18 TO 6:21 (RUNNING 00:00:14.080)
` 18 Q. What are your responsibilities?
` 19 A. My team deploys the Sky ATP code into
` 20 production, and we monitor and maintain the code that is
` 21 in production.
`3. PAGE 24:05 TO 24:11 (RUNNING 00:00:37.561)
` 05 Q. You said that you asked one of your colleagues
` 06 to run a report. Who is this colleague?
` 07 A. Khurram on the Sandbox Cloud Development
` 08 Dynamic Analysis team. He's the one who ran the report.
` 09 Q. Can you spell the name?
` 10 A. K-H-U-R-R-A-M. And I just remembered his last
` 11 name, I-S-L-A-H.
`4. PAGE 24:12 TO 24:12 (RUNNING 00:00:03.384)
` 12 Q. How do you pronounce the last name?
`5. PAGE 24:13 TO 24:15 (RUNNING 00:00:06.671)
` 13 A. I don't know actually. Sorry.
` 14 Q. I'll just refer to him as Khurram then.
` 15 A. Okay. Thank you.
`6. PAGE 31:10 TO 31:19 (RUNNING 00:00:42.122)
` 10 Q. You mentioned that Khurram, when he ran this
` 11 report to obtain the number that 40 percent of new
` 12 samples submitted by customers are sent to dynamic
` 13 analysis, this was limited to the time of January 2017
` 14 and before.
` 15 A. Yes. The request was to determine the number
` 16 of new samples submitted by customer devices --
` 17 determine the number of samples and constrain it by a
` 18 date of January 2017 and before, is what the request
` 19 came in for.
`
`CONFIDENTIAL
`
`page 1
`
`

`

`Case 3:17-cv-05659-WHA Document 432-14 Filed 04/11/19 Page 3 of 5
`
`Case Clip(s) Detailed Report
`Tuesday, December 11, 2018, 10:33:32 PM
`
`Finjan v. Juniper
`
`7. PAGE 33:15 TO 33:19 (RUNNING 00:00:20.204)
` 15 Q. When you say 40 percent of new samples are
` 16 sent to dynamic analysis, are you aware of what the
` 17 total number of files that this 40 percent is based on?
` 18 A. I was not given that number, so I'm not aware.
` 19 I don't know the total number.
`8. PAGE 33:20 TO 33:23 (RUNNING 00:00:14.084)
` 20 Q. You mentioned that Sky ATP does not keep track
` 21 of the total number of files received; correct?
` 22 A. Correct. We don't track the total number of
` 23 files received in Sky ATP.
`9. PAGE 42:18 TO 42:20 (RUNNING 00:00:08.747)
` 18 Q. Are there only certain Junos versions that are
` 19 compatible with Sky ATP Cloud?
` 20 A. Yes.
`10. PAGE 42:21 TO 42:23 (RUNNING 00:00:10.958)
` 21 Q. Which versions?
` 22 A. I -- off the top of my head I don't know which
` 23 versions are compatible with -- with the Sky ATP Cloud.
`11. PAGE 45:18 TO 46:07 (RUNNING 00:01:13.880)
` 18 Q. In order to use Sky ATP, a customer needs to
` 19 purchase a Sky ATP license; correct?
` 20 A. To use the premium and basic features, yes,
` 21 the customer has to purchase those. That's correct.
` 22 Q. Does a customer need to purchase a Sky ATP
` 23 license for each SRX device that it has in order to use
` 24 Sky ATP?
` 25 A. There is a unique license associated to each
` 00046:01 SRX. So they have to purchase a license for every
` 02 individual SRX they plan to use the Sky ATP license.
` 03 Q. Can there be multiple Sky ATP licenses for one
` 04 SRX device?
` 05 A. Not that I'm aware of. The license is a
` 06 one-to-one mapping. Otherwise it breaks the licensing
` 07 model for sales and purchasing.
`12. PAGE 52:18 TO 52:22 (RUNNING 00:00:21.156)
` 18 Q. You mentioned that the free license doesn't
` 19 have a SKU. Do you recall that?
` 20 A. Yes.
` 21 Q. Are the SKUs for the basic and premium Sky ATP
` 22 licenses listed on pages 18 to 21 of Exhibit Number 1?
`13. PAGE 52:23 TO 53:05 (RUNNING 00:00:43.555)
` 23 A. So these are the basic licenses and the
` 24 premium licenses. There is no SKU for -- again for free
` 25 licenses.
` 00053:01 Q. How can you tell which SKUs are basic license
` 02 and which are premium?
` 03 A. The license that has "ATP" in the SKU is the
` 04 premium license. The SKUs that have "THRTFFED"(sic),
` 05 for threat feed, is the basic license.
`14. PAGE 53:06 TO 53:08 (RUNNING 00:00:12.054)
` 06 Q. You mentioned that there's no SKU for free
` 07 license. Why is that?
` 08 A. I -- I don't know.
`
`CONFIDENTIAL
`
`page 2
`
`

`

`Case 3:17-cv-05659-WHA Document 432-14 Filed 04/11/19 Page 4 of 5
`
`Case Clip(s) Detailed Report
`Tuesday, December 11, 2018, 10:33:32 PM
`
`Finjan v. Juniper
`
`15. PAGE 53:09 TO 53:16 (RUNNING 00:00:47.412)
` 09 Q. Is there any way to generate a record of the
` 10 number of SRX devices that have a free Sky ATP license?
` 11 A. So I asked one of my colleagues to run a
` 12 report in Sky ATP Cloud to determine the number of
` 13 compatible SRXs that connected -- enrolled in,
` 14 registered and connected to Sky ATP with a free license,
` 15 free service essentially. And we determined the number
` 16 to be 120.
`16. PAGE 53:17 TO 54:03 (RUNNING 00:00:59.265)
` 17 Q. Can you elaborate how this number was
` 18 determined?
` 19 A. In order to use the free service in Sky ATP,
` 20 the customer has to register and enroll their compatible
` 21 SRXs into the Sky ATP Cloud.
` 22 When they enroll their compatible SRX device
` 23 to Sky ATP Cloud, it initiates a connection to Sky ATP
` 24 Cloud and we can track the license type. It will say
` 25 free and that it's connected essentially.
` 00054:01 And so the report was run on -- on gathering
` 02 that information on the number of devices that have
` 03 connected with the free service.
`17. PAGE 89:18 TO 89:22 (RUNNING 00:00:14.498)
` 18 Q. Do you recall previously we were discussing
` 19 three different ways Juniper's customers can access
` 20 Sky ATP; one of them is a free service, a basic service,
` 21 and a premium one?
` 22 A. Yes.
`18. PAGE 89:23 TO 90:03 (RUNNING 00:00:16.270)
` 23 Q. For the premium version of Sky ATP, a
` 24 subscription license is required; correct?
` 25 A. Correct. A customer has to purchase a
` 00090:01 subscription license to use a premium license.
` 02 Q. For the free version of Sky ATP, no license is
` 03 required; correct?
`19. PAGE 90:05 TO 90:12 (RUNNING 00:00:27.416)
` 05 THE WITNESS: For the free license, the
` 06 customer has to enroll their device into the Sky ATP
` 07 Cloud and create an account in the Sky ATP Cloud.
` 08 BY MR. LEE:
` 09 Q. For the free version, this is what you
` 10 described earlier as you have to register an account
` 11 with Sky ATP Cloud and enroll your device; correct?
` 12 A. Correct.
`20. PAGE 112:12 TO 112:14 (RUNNING 00:00:16.121)
` 12 Does an SRX user have permission to use
` 13 Sky ATP, the free service, without registering for an
` 14 account?
`21. PAGE 112:17 TO 112:19 (RUNNING 00:00:16.100)
` 17 THE WITNESS: The SRX -- so customers who have
` 18 an SRX can use the free service in Sky ATP without a
` 19 license.
`22. PAGE 113:13 TO 113:20 (RUNNING 00:00:32.147)
` 13 If a SRX user hasn't created an account and
` 14 registered their device, are they able to access
`
`CONFIDENTIAL
`
`page 3
`
`

`

`Case 3:17-cv-05659-WHA Document 432-14 Filed 04/11/19 Page 5 of 5
`
`Case Clip(s) Detailed Report
`Tuesday, December 11, 2018, 10:33:32 PM
`
`Finjan v. Juniper
`
` 15 Sky ATP?
` 16 A. No, they're not able. They don't -- without
` 17 creating the account and enrolling the device in the
` 18 Sky ATP Cloud, they don't have authorization to even
` 19 connect or upload samples to Sky ATP Cloud, if I
` 20 understand your question correctly.
`
`TOTAL: 1 CLIP FROM 1 DEPOSITION (RUNNING 00:09:22.170)
`
`CONFIDENTIAL
`
`page 4
`
`