Case 3:17-cv-05659-WHA Document 435-11 Filed 04/12/19 Page 1 of 3
`Case 3:17-cv-05659-WHA Document 435-11 Filed 04/12/19 Page 1 of 3
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`Case 3:17-cv-05659-WHA Document 435-11 Filed 04/12/19 Page 2 of 3
`HIGHLY CONFIDENTIAL SOURCE CODE - ATTORNEYS' EYES ONLY
`Transcript of Chandra Nagarajan
`Conducted on May 31, 2018
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` A P P E A R A N C E S
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`ON BEHALF OF PLAINTIFF FINJAN, INC.:
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` MICHAEL H. LEE, ESQUIRE
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` LINDA XU, ESQUIRE
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` KRAMER LEVIN NAFTALIS & FRANKEL LLP
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` 990 Marsh Road
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` Menlo Park, California 94025
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` (650) 752-1700
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`ON BEHALF OF DEFENDANT JUNIPER NETWORKS, INC.:
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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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`- - - - - - - - - - - - - - - - - -x
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`FINJAN, INC., a Delaware : Case No.
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`Corporation, : 3:17-cv-05659-WHA
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` Plaintiff, :
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`v. :
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`JUNIPER NETWORKS, INC., a :
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`Delaware Corporation, :
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` Defendant. :
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` HIGHLY CONFIDENTIAL SOURCE CODE - ATTORNEYS' EYES ONLY
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` VIDEOTAPED DEPOSITION OF CHANDRA NAGARAJAN
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` Sunnyvale, California
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` Thursday, May 31, 2018
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` 9:05 a.m.
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`Job No.: 189837
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`Pages: 1 - 245
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`Reported By: Charlotte Lacey, RPR, CSR No. 14224
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` JONATHAN S. KAGAN, ESQUIRE
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` IRELL & MANELLA LLP
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` 1800 Avenue of the Stars, Suite 900
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` Los Angeles, California 90067
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` (301) 277-1010
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`ALSO PRESENT:
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` John Torreano, Videographer
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` I N D E X
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` WITNESS PAGE
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` CHANDRA NAGARAJAN
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` Examination by Mr. Lee 10
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` I N D E X O F E X H I B I T S
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` EXHIBITS DESCRIPTION PAGE
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`Exhibit 41 Sprint Goals, Bates number 91
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` JNPR-FNJN_29017_00552598
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`Exhibit 42 Bates number 114
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` JNPR-FNJN_29030-00553835
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`Exhibit 43 Cloud-Delivered Security, Security 116
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` Summit April 2016, Bates number
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` JNPR-FNJN_29008-00522076
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`Exhibit 44 Argon Reporting/Dashboard Proposal, 131
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` Bates number
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` JNPR-FNJN_29017_00552784
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`Exhibit 45 Bates number 135
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` JNPR-FNJN_290032_00590572
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`Exhibit 46 Catalog of applications connecting 147
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` to the common database, Bates number
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` JNPR-FNJN_29017_00552771
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`Exhibit 47 IDB (Common DB), Bates number 150
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` JNPR-FNJN_29017_00552603
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` VIDEOTAPED DEPOSITION OF CHANDRA NAGARAJAN, held at
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`the offices of Juniper Networks, Incorporated,
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`1133 Innovation Way, Building A, Sunnyvale, California
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` Pursuant to notice, before Charlotte Lacey,
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`Certified Shorthand Reporter, in and for the State of
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`California.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Case 3:17-cv-05659-WHA Document 435-11 Filed 04/12/19 Page 3 of 3
`HIGHLY CONFIDENTIAL SOURCE CODE - ATTORNEYS' EYES ONLY
`Transcript of Chandra Nagarajan
`Conducted on May 31, 2018
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` P R O C E E D I N G S
` THE VIDEOGRAPHER: Good morning. We are now
`on the record. Here begins media number 1 in the
`videotaped deposition of Chandra Nagarajan in the matter
`of Finjan Incorporated versus Juniper Networks
`Incorporated, et al., held in the United States District
`Court, Northern District of California, San Francisco
`Division. Case number 3:17-CV-05659-WHA.
` Today's date is May 31st, 2018, and the time
`on the video monitor is 9:06 a.m.
` Your videographer today is John Torreano
`representing on behalf of Planet Depos.
` This video deposition is taking place at
`Juniper Networks Incorporated, street address
`1133 Innovation Way, Building A in Sunnyvale, California
`94089.
` Would counsel please voice identify themselves
`and state whom they represent in this action.
` MR. LEE: Michael Lee from Kramer Levin
`representing Finjan. And with me is Linda Xu from
`Kramer Levin as well.
` MR. KAGAN: Jonathan Kagan of Irell and
`Manella representing Juniper Networks.
` THE VIDEOGRAPHER: Your court reporter today
`is Charlotte Lacey representing on behalf of Planet
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`to be responsible for Junosphere, but that product is
`end of life right now.
` THE REPORTER: I'm sorry. "I was responsible
`for"...?
` THE WITNESS: Junosphere.
` THE REPORTER: Junosphere. Thank you.
` Q What is the name of the intrusion prevention
`product?
` A It's -- it's part of the SRX, but then I own
`the team which writes signatures to -- to stop the
`exploits.
` Q Is there a name for this intrusion prevention
`product?
` A It is -- there's a separate license in SRX for
`this. That's about it. It's called IPS.
` Q And that stands for Intrusion Prevention
`System?
` A That's right.
` Q You mentioned Sky ATP?
` A Uh-huh.
` Q What is Sky ATP?
` A Sky ATP is a cloud-delivered advanced threat
`prevention service. It -- it works directly with SRX
`and then try -- it tries to get files out of the
`network, whatever is going through the network and makes
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`a determination, to the best of its ability, what the
`Depos.
`threat level of those files are. And it's -- it's
` If there are no stipulations or comments from
`basically a SAS type of product where the most of the
`counsel, would the court reporter please swear in the
`functionalities reside in the cloud and the user itself
`witness.
`logs into the cloud and most of the input -- input on
` CHANDRA NAGARAJAN,
`the user interface is on the cloud site.
`the witness herein, having been first duly sworn, was
` Q What does Sky ATP stand for?
`examined and testified as follows:
` A Sky is, I guess, is just a brand name, and the
` EXAMINATION
`A. T. P. is for advanced threat prevention.
`BY MR. LEE:
` Q What is advanced threat prevention?
` Q Where do you work?
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` A What is advanced -- so the advanced threat
` A I work in Juniper Networks.
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`prevention, the name mainly comes because in the market,
` Q What's your position at Juniper Networks?
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`there are a lot of AVs which can detect if something
` A My position is a senior director in the
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`is -- is good or bad based on what they know. But
`security business group.
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`advanced threat prevention is something even if you get
` Q What are your responsibilities?
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`a file, which it doesn't know about, it tries to
` A I manage a team of engineers and -- I'm
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`evaluate to the best of its capability and determines
`responsible for the engineering delivery of the product.
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`the threat level.
`So I ensure we get the right specifications for the
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`product, and then we execute the schedule we come up
` Q So advanced threat prevention is for unknown
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`with for the features requested.
`threats?
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` MR. KAGAN: Objection; form.
` Q Which product?
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` A Advanced threat protection is both for known
` A There are a couple of products I'm responsible
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`threats and also for unknown threats.
`for. One is the Sky ATP. The other one is the -- we
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`have an intrusion detection prevention product, so I'm
` Q What are the key components of Sky ATP?
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`responsible for that. Previously, when I joined, I used
` MR. KAGAN: Objection; form.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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