`
`
`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
`
`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 TO DEFENDANT
`JUNIPER NETWORKS, INC.’S LETTER
`TO COURT RE DKT. NO. 459
`
`
`
`
`
`
`
`
`KASTENS DECL. IN SUPPORT OF FINJAN’S REPLY
`TO JUNIPER’S LETTER TO COURT RE DKT. NO. 459
`
` CASE NO.: 3:17-cv-05659-WHA
`
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`Case 3:17-cv-05659-WHA Document 480-1 Filed 05/16/19 Page 2 of 3
`
`
`
`I, Kristopher Kastens, declare:
`1.
`I am an attorney with the law firm Kramer Levin Naftalis & Frankel LLP, counsel of
`record for Finjan, Inc. (“Finjan”). I have personal knowledge of the facts stated herein and can testify
`competently to those facts. I make this declaration in support of Plaintiff Finjan, Inc.’s Reply to
`Defendant Juniper Networks, Inc.’s Letter to Court regarding Dkt. No. 459.
`2.
`Attached hereto as Exhibit 1 is a true and correct copy of a Juniper Networks, Inc.
`(“Juniper”) document entitled “Security Intelligence Enforcement on SRX” produced by Juniper,
`bearing bates numbers JNPR-FNJN_29002_00172622 – 56.
`3.
`Attached hereto as Exhibit 2 is a true and correct copy of a Juniper document entitled
`“Junos OS” produced by Juniper, bearing bates numbers JNPR-FNJN_29007_00009506 – 07.
`4.
`Attached hereto as Exhibit 3 is a true and correct copy of page 19 from the transcript of
`the deposition of Yuly Tenorio, taken on May 9, 2018.
`5.
`Attached hereto as Exhibit 4 is a true and correct copy of pages 15 and 22 from the
`transcript of the deposition of Chandra Nagarajan, taken on May 31, 2018.
`6.
`Attached hereto as Exhibit 5 is a true and correct copy of a presentation entitled “Sky
`ATP Advanced Threat Protection Juniper’s Sky IS the limit!” produced by Finjan, bearing bates
`numbers FINJAN-JN 044832 – 53.
`7.
`Attached hereto as Exhibit 6 is a true and correct copy of a datasheet entitled “Juniper
`Sky Advanced Threat Prevention” produced by Finjan, bearing bates numbers FINJAN-JN 005438 –
`42.
`
`8.
`Attached hereto as Exhibit 7 is a true and correct copy of a manual entitled “Sky
`Advanced Threat Prevention Guide” produced by Finjan, bearing bates numbers FINJAN-JN 044744 –
`99.
`
`9.
`Attached hereto as Exhibit 8 is a true and correct copy of a Juniper document produced
`by Juniper, bearing bates numbers JNPR-FNJN_29017_00553620 – 75.
`
`1
`KASTENS DECL. IN SUPPORT OF FINJAN’S REPLY
`TO JUNIPER’S LETTER TO COURT RE DKT. NO. 459
`
` CASE NO.: 3:17-cv-05659-WHA
`
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`Case 3:17-cv-05659-WHA Document 480-1 Filed 05/16/19 Page 3 of 3
`
`
`
`10.
`Attached hereto as Exhibit 9 is a true and correct copy of a Juniper document entitled
`“SRX Advance Integration with JATP” produced by Juniper, bearing bates numbers JNPR-
`FNJN_29018_00962784 – 98.
`
`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 May 16, 2019, in Menlo Park, California.
`
`
`
`
`
`
`/s/ Kristopher Kastens
` Kristopher Kastens
`
`
`
`ATTESTATION PURSUANT TO L.R. 5-1(I)
`
`In accordance with Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this
`
`document has been obtained from any other signatory to this document.
`
`/s/ Lisa Kobialka
` Lisa Kobialka
`
`
`
`
`
`2
`KASTENS DECL. IN SUPPORT OF FINJAN’S REPLY
`TO JUNIPER’S LETTER TO COURT RE DKT. NO. 459
`
` CASE NO.: 3:17-cv-05659-WHA
`
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