Case 3:17-cv-05659-WHA Document 48-1 Filed 04/06/18 Page 1 of 6
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`Exhibit 1
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`Case 3:17-cv-05659-WHA Document 48-1 Filed 04/06/18 Page 2 of 6
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`6.
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`The term “Accused Instrumentalities” shall include the following Juniper products and
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`services: Defendant’s SRX Gateways including the: SRX110; SRX220; SRX300; SRX550; SRX1400;
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`SRX1500; SRX3400; SRX3600; SRX4000; SRX5400; SRX5600; and SRX5800 gateway appliances,
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`as well as the vSRX Virtual Firewall and cSRX Container Firewall (collectively, “SRX Gateways”) as
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`described in the Complaint, including but not limited to at Exhibit 9 and paragraphs 43-52;
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`Defendant’s Sky Advanced Threat Protection or “Sky ATP” and Advanced Threat Protection
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`Appliance, as described in the Complaint, including but not limited to at Exhibit 10 and paragraphs 43-
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`52; Defendant’s Junos Space Security Director, as described in the Complaint, including but not
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`limited to at Exhibit 16 and paragraphs 43-52; and Defendant’s Contrail, as described in the
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`Complaint, including but not limited to at Exhibit 17 and paragraphs 43-52. The term “Accused
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`Instrumentalities” shall also include any and all previous or currently contemplated versions, revisions,
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`releases, or continuations of said Juniper products and services, and all additional products accused of
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`infringement by Finjan in this action in infringement contentions or similar pleadings.
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`7.
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`The term “person” or “entity” shall refer to any individual, corporation, proprietorship,
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`association, joint venture, company, partnership, or other business or legal entity, including
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`governmental bodies and agencies. The masculine includes the feminine and vice versa; the singular
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`includes the plural and vice versa.
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`8.
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`The term “document(s)” shall have the broadest meaning ascribed to it by Federal Rule
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`of Civil Procedure 34 and Federal Rule of Evidence 1001, and shall include within its meaning any and
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`all papers, videotapes or video recordings, photographs, films, recordings, memoranda, books, records,
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`accounts, letters, telegrams, correspondence, notes of meetings, notes of conversations, notes of
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`telephone calls, inter-office memoranda or written communications of any nature, recordings of
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`conversations either in writing or by means of any mechanical or electrical recording device, notes,
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`papers, reports, analyses, invoices, canceled checks or check stubs, receipts, minutes of meetings, time
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`sheets, diaries, desk calendars, ledgers, schedules, licenses, financial statements, telephone bills, logs,
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`and any differing versions of the foregoing whether denominated formal, informal, or otherwise, as
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`well as copies of the foregoing which differ in any way, including handwritten notations or other
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`2
`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
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`CASE NO. 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 48-1 Filed 04/06/18 Page 3 of 6
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`REQUEST FOR PRODUCTION NO. 10:
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`All documents, communications, or things related to Your reliance on the advice of counsel as a
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`defense to Finjan’s claim that You willfully infringed and continue to willfully infringe the Asserted
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`Patents.
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`REQUEST FOR PRODUCTION NO. 11:
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`All documents, communications, or things relating to the design, development, structure,
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`architecture, testing, research, updating or operation for each of the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 12:
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`All technical and marketing documents, communications, or things discussing or regarding the
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`components of the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 13:
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`All documents, communications, or things relating to any database or database schema relating
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`to, created for, referenced by, or used by any of the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 14:
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`All documents, communications, or things relating to any presentations, overviews, technical
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`overviews, power point slides, or briefing related to any of the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 15:
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`All documents, communications, or things relating to any API (Application Program Interface)
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`specifications, functional specifications, flow charts, architecture diagrams, or design documents related
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`to any of the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 16:
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`Copies of the source code for each of the Accused Instrumentalities, including but not limited
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`to, all past and present releases, versions, updates, or upgrades.
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`REQUEST FOR PRODUCTION NO. 17:
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`Working copies of the most recent version of each of the Accused Instrumentalities.
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`7
`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
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`CASE NO. 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 48-1 Filed 04/06/18 Page 4 of 6
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`REQUEST FOR PRODUCTION NO. 33:
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`Documents, communications, or things sufficient to show the process by which You detect new
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`malware or security threats or update the Accused Instrumentalities.
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`REQUEST FOR PRODUCTION NO. 34:
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`Documents, communications, or things sufficient to show the location where the Accused
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`Instrumentalities are developed, tested, manufactured, distributed, sold, updated and imported.
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`REQUEST FOR PRODUCTION NO. 35:
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`Documents, communications, or things sufficient to show the operation, functionality, design,
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`development, testing, manufacturing, distribution, sale, updating and import of SRX Gateways (as
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`described in Finjan’s Complaint, including at Exhibit 9).
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`REQUEST FOR PRODUCTION NO. 36:
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`Documents, communications, or things sufficient to show the operation, functionality, design,
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`development, testing, manufacturing, distribution, sale, updating and import of Sky Advanced Threat
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`Protection (as described in Finjan’s Complaint, including at Exhibit 10).
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`REQUEST FOR PRODUCTION NO. 37:
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`Documents, communications, or things sufficient to show the operation, functionality, design,
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`development, testing, manufacturing, distribution, sale, updating and import of the malware inspection
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`pipeline in Sky Advanced Threat Protection (as described in Finjan’s Complaint, including at Exhibit
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`10).
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`REQUEST FOR PRODUCTION NO. 38:
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`Documents, communications, or things sufficient to show the operation, functionality, design,
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`development, testing, manufacturing, distribution, sale, updating and import of dynamic analysis
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`performed by the Sky Advanced Threat Protection (as described in Finjan’s Complaint, including at
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`Exhibit 10).
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`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
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`CASE NO. 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 48-1 Filed 04/06/18 Page 5 of 6
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`REQUEST FOR PRODUCTION NO. 39:
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`Documents, communications, or things sufficient to show the operation, functionality, design,
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`development, testing, manufacturing, distribution, sale, updating and import of static analysis performed
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`by the Sky Advanced Threat Protection (as described in Finjan’s Complaint, including at Exhibit 10).
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`REQUEST FOR PRODUCTION NO. 40:
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`Documents, communications, or things sufficient to show the operation, functionality, design,
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`development, testing, manufacturing, distribution, sale, updating and import of the cache in the malware
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`inspection pipeline of the Sky Advanced Threat Protection (as described in Finjan’s Complaint,
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`including at Exhibit 10).
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`REQUEST FOR PRODUCTION NO. 41:
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`Documents, communications, or things sufficient to show the operation, functionality, design,
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`development, testing, manufacturing, distribution, sale, updating and import of Junos Space Security
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`Director (as described in Finjan’s Complaint, including at Exhibit 16).
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`REQUEST FOR PRODUCTION NO. 42:
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`Documents, communications, or things sufficient to show to the operation, functionality,
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`design, development, testing, manufacturing, distribution, sale, updating and import of Contrail (as
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`described in Finjan’s Complaint, including at Exhibit 17).
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`REQUEST FOR PRODUCTION NO. 43:
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`Documents, communications, or things sufficient to show Your organizational structure with
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`respect to research, development, engineering, manufacture, assembly, testing, marketing, distribution,
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`sale, licensing, updating and importation of each of the Accused Instrumentalities, including
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`organizational charts.
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`REQUEST FOR PRODUCTION NO. 44:
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`All documents, communications, or things relating to the instant litigation.
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`REQUEST FOR PRODUCTION NO. 45:
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`All documents, communications, or things on which You intend to rely in support of or
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`opposition to any claim or defense in this litigation.
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`11
`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1–60)
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`CASE NO. 3:17-cv-05659-WHA
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`PROOF OF SERVICE
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`I, Steven D. Dennison, am employed in the Menlo Park, California office of Kramer Levin
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`Naftalis & Frankel LLP. I am over the age of 18 and not a party to the within action. My business
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`address is 990 Marsh Road, Menlo Park, California 94025. I am readily familiar with the firm's
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`practice of collecting and processing of mail for mailing with the U.S. Postal Service and overnight
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`delivery services.
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`On February 23, 2018, I caused the following document(s) to be served:
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`PLAINTIFF FINJAN, INC.'S FIRST SET OF REQUESTS FOR PRODUCTION OF
`DOCUMENTS TO DEFENDANT JUNIPER NETWORKS, INC. (NOS. 1-60)
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`1 0
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`by electronic mail, addressed as follows:
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`Joshua Popik Glucoft
`I re 11 & Manella LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067
`iglucoft@irell.com
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`Rebecca Lyn Carson
`Nima Hefazi
`I re 11 & Manella LLP
`840 Newport Center Dr., Suite 400
`Newport Beach, CA 92660
`rclifford@irell.com
`nhefazi@irell.com
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`I declare under penalty of perjury that the foregoing is/true and correct. Executed on February
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`23, 2018, in Menlo Park, California.
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`//.
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`Steven D. Dennison
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`15
`FINJAN'S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO JUNIPER NETWORKS (NOS. 1-60)
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`CASE NO. 3:17-cv-05659-WHA
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