`
`
`
`PAUL J. 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
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`FINJAN, INC., a Delaware Corporation,
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
`
`
`
`
`
`
`Defendant.
`
`
`Case No.: 3:17-cv-05659-WHA
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`DECLARATION OF KRISTOPHER
`KASTENS IN SUPPORT OF PLAINTIFF
`FINJAN, INC.’S RESPONSE TO ORDER
`TO SHOW CAUSE
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`KASTENS DECL. IN SUPPORT OF FINJAN’S
`RESPONSE TO ORDER TO SHOW CAUSE
`
`CASE NO.: 3:17-cv-05659-WHA
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`
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`Case 3:17-cv-05659-WHA Document 470-1 Filed 05/13/19 Page 2 of 3
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`
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`I, Kristopher Kastens, declare:
`1.
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`I am an attorney with the law firm Kramer Levin Naftalis & Frankel LLP, counsel of
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`record for Finjan, Inc. (“Finjan”). I have personal knowledge of the facts stated herein and can testify
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`competently to those facts. I make this declaration in support of Plaintiff Finjan, Inc.’s Response to
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`Order to Show Cause.
`2.
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`Attached hereto as Exhibit 1 is a true and correct copy of a webpage found at
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`https://fixmywp.com/blog/detect-clean-wordpress-malware-redirect.php on or about May 11, 2019.
`3.
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`Attached hereto as Exhibit 2 is a true and correct copy of a webpage found at
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`https://en.wikipedia.org/wiki/URL_redirection#Implementation on or about May 11, 2019..
`4.
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`Attached hereto as Exhibit 3 is a true and correct copy of an Administrative Guide for
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`Sky ATP produced by Finjan, bearing bates numbers FINJAN-JN 005246 – 371.
`5.
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`Attached hereto as Exhibit 4 is a true and correct copy of a webpage found at
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`https://en.wikipedia.org/wiki/Transport_Layer_Security on or about May 11, 2019..
`6.
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`Attached hereto as Exhibit 5 is a true and correct copy of pages 327, 377, 456, 547-548,
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`586-587, and 592 of printed source code that Juniper produced in this action.
`7.
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`Attached hereto as Exhibit 6 is a true and correct copy of a webpage found at
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`https://en.wikipedia.org/wiki/Data_compression on or about May 11, 2019.
`8.
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`Attached hereto as Exhibit 7 is a true and correct copy of a white paper produced by
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`Finjan, bearing bates numbers FINJAN-JN 045326 – 38.
`9.
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`Attached hereto as Exhibit 8 is a true and correct copy of a document produced by
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`Juniper, bearing bates numbers JNPR-FNJN_29018_00975646 – 92.
`10. Attached hereto as Exhibit 9 is a true and correct copy of a white paper produced by
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`Finjna, bearing bates numbers FINJAN-JN 045339 – 45.
`11.
`Exhibit 10 has been intentionally ommitted.
`12. Attached hereto as Exhibit 11 is a true and correct copy of a webpage found at
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`https://www.varonis.com/blog/what-is-a-proxy-server on or about May 11, 2019.
`13. Attached hereto as Exhibit 12 is a true and correct copy of a document produced by
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`KASTENS DECL. IN SUPPORT OF FINJAN’S
`RESPONSE TO ORDER TO SHOW CAUSE
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`1
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`CASE NO.: 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 470-1 Filed 05/13/19 Page 3 of 3
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`
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`Finjan, bearing bates numbers FINJAN-JN 045074 – 79.
`14. Attached hereto as Exhibit 13 is a true and correct copy of a document produced by
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`Juniper, bearing bates numbers JNPR-FNJN_29002_00173278 – 340.
`15. Attached hereto as Exhibit 14 is a true and correct copy of a document produced by
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`Juniper, bearing bates numbers JNPR-FNJN_29032_00590643 – 72.
`16. Attached hereto as Exhibit 15 is a true and correct copy of a document produced by
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`Juniper, bearing bates numbers JNPR-FNJN_29008_00528472 – 567.
`17. Attached hereto as Exhibit 16 is a true and correct copy of a document produced by
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`Juniper bearing bates numbers JNPR-FNJN_29018_00979461 – 63.
`18. Attached hereto as Exhibit 17 is a true and correct copy of a document produced by
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`Finjan, bearing bates numbers FINJAN-JN 044887 – 5068.
`19. Attached hereto as Exhibit 18 is a true and correct copy of a document produced by
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`Juniper bearing bates numbers JNPR-FNJN_29040_01194632 – 45.
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` I
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` declare under penalty of perjury under the laws of the United States of America that each of the
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`above statements is true and corrected. Executed on May 13, 2019, in Menlo Park, California.
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`/s/ Kristopher Kastens
`Kristopher Kastens
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`KASTENS DECL. IN SUPPORT OF FINJAN’S
`RESPONSE TO ORDER TO SHOW CAUSE
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`2
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`CASE NO.: 3:17-cv-05659-WHA
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