Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 1 of 15
`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 1 of 15
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`EXHIBIT 10
`EXHIBIT 10
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`UNREDACTED VERSION OF
`UNREDACTED VERSION OF
`DOCUMENT SOUGHT TO BE
`DOCUMENT SOUGHT TO BE
`SEALED
`SEALED
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`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 2 of 15
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`
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`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Joshua Glucoft (SBN 301249)
`jglucoft@irell.com
`Casey Curran (SBN 305210)
`ccurran@irell.com
`Sharon Song (SBN 313535)
`ssong@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`Rebecca Carson (SBN 254105)
`rcarson@irell.com
`Kevin Wang (SBN 318024)
`kwang@irell.com
`840 Newport Center Drive, Suite 400
`Newport Beach, California 92660-6324
`Telephone: (949) 760-0991
`Facsimile: (949) 760-5200
`
`Attorneys for Defendant
`JUNIPER NETWORKS, INC.
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`SAN FRANCISCO DIVISION
`
`FINJAN, INC., a Delaware Corporation,
`
`
`Plaintiff,
`
`vs.
`
`
`
`
`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
`
`
`Defendant.
`
`
`
`
`Case No. 3:17-cv-05659-WHA
`
`DEFENDANT JUNIPER NETWORKS,
`INC.’S RESPONSE TO PLAINTIFF
`FINJAN, INC.’S FOURTH SET OF
`INTERROGATORIES
`
`HIGHLY CONFIDENTIAL—
`ATTORNEYS’ EYES ONLY
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10511051
`
`
`- 1 -
`
`JUNIPER’S RESPONSE TO
`FINJAN’S FOURTH SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 3 of 15
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`Pursuant to Federal Rules of Civil Procedure 26 and 33, Defendant Juniper, Inc.
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`(“Juniper”) hereby submits the following objections and responses (collectively, the “Responses”)
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`to the Fourth Set of Interrogatories (the “Interrogatories”) by Defendant Finjan, Inc. (“Finjan”).
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`PRELIMINARY STATEMENT
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`Juniper has not completed discovery in this action and has not completed preparation for
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`trial. These Responses, while based on diligent inquiry and investigation by Juniper, necessarily
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`reflect only the current state of Juniper’s knowledge, understanding, and belief based upon the
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`information reasonably available to Juniper at this time. Juniper anticipates that further facts and
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`information may be discovered. Without in any way obligating itself to do so, Juniper reserves the
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`right to modify, supplement, revise, or amend these Responses and to correct any errors or
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`omissions which may be contained herein in light of the information that Juniper may
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`subsequently obtain or discover. Furthermore, these Responses are provided without prejudice to
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`Juniper’s use or reliance on, at trial, hearing, or otherwise, subsequently discovered facts or
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`information or facts or information omitted from these responses. The following Responses are
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`given without prejudice to Juniper’s right to produce evidence of any subsequently discovered
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`fact. Juniper accordingly reserves the right to change any and all responses herein as additional
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`facts are ascertained, analyses are performed, legal research is completed, and contentions are
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`investigated. This introductory statement shall apply to each and every Response given herein and
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`shall be incorporated by reference as though set forth in each Response appearing below.
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`GENERAL OBJECTIONS
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`These objections are hereby incorporated, as though set forth in full, into the response to
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`each and every Interrogatory. Juniper reserves the right to make additional objections as may be
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`appropriate and nothing contained herein shall be in any way construed as a waiver of any such
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`objection. Juniper has not yet completed its investigation of the facts pertaining to this action, its
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`discovery, or its preparation for trial. Juniper’s objections and responses as set forth below are
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`made without prejudice to Juniper’s right to assert any additional or supplemental objections or
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`responses if Juniper discovers additional grounds for such objections or responses.
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10511051
`
`
`- 2 -
`
`JUNIPER’S RESPONSE TO
`FINJAN’S FOURTH SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
`
`

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`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 4 of 15
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`By making this response, Juniper does not concede that any of the requested information is
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`proportional to the needs of the case, relevant, properly discoverable, or admissible, and Juniper
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`reserves its right to object to discovery into the subject matter addressed in any information
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`produced and to the introduction of such information into evidence.
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`Juniper makes the following general objections (collectively, the “General Objections”) to
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`each Interrogatory contained within Finjan’s Interrogatories. The assertion of the same, similar, or
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`additional objections or the provision of responses to the requests does not constitute a waiver any
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`of Juniper’s objections as set forth below:
`1.
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`Juniper objects to the definition of “Accused Instrumentalities” as including all
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`“products and services identified in Finjan’s Infringement Contentions,” particularly Spotlight
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`Secure Threat Intelligence Platform. That product was not identified in the operative First
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`Amended Complaint and it is therefore not part of this case. See id.; see also Richtek Tech. Corp.
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`v. uPi Semiconductor Corp., 2016 WL 1718135, at *2 (N.D. Cal. Apr. 29, 2016) (Alsup, J.)
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`(“[T]he filing of a complaint sets the cut-off date for the scope of a case, subject to the possibility
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`of supplementation. Nevertheless, for some time, patent owners have made open-ended
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`allegations in their complaint that do not specifically identify the accused products and used
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`amendments to their infringement contentions to expand the scope of the case to encompass
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`products…without the need to file a supplemental complaint—essentially sneaking new products
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`into the case through the back door of infringement contentions.”). Juniper also objects to the
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`definition of “Accused Instrumentalities” to the extent that it includes the ATP Appliance. Juniper
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`will respond regarding the ATP Appliance in due course, as per the Court’s Order at Dkt. No. 85,
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`discovery regarding ATP Appliance was deemed served as of the filing date of the First Amended
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`Complaint, which was filed May 18, 2018. Juniper also objects to the definition of “Accused
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`Instrumentalities” to the extent that it purports to include previous or contemplated versions,
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`revision, releases, or continuations of any Juniper products or services other than those specifically
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`identified (including by model number) in Finjan’s Infringement Contentions and also in the
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`operative complaint. To the extent applicable, Juniper will interpret each and every Interrogatory
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`as limited to only those instrumentalities specifically identified in both the operative complaint
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10511051
`
`
`- 3 -
`
`JUNIPER’S RESPONSE TO
`FINJAN’S FOURTH SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 5 of 15
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`and Finjan’s Infringement Contentions and also made, used, sold, offered for sale, or imported
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`into the U.S. within the statutory damages period.
`2.
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`Juniper objects to the Interrogatories, including but not limited to the Instructions
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`and Definitions, to the extent they are inconsistent with, seek to impose obligations not required
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`by, or seek to expand the scope of permissible discovery under the Federal Rules of Civil
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`Procedure, the Federal Rules of Evidence, the Local Rules of the Northern District of California,
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`any Order of the Court, or any agreement between the parties, specifically including the parties’
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`agreement set forth in the Joint Case Management Statement and the (anticipated) stipulation
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`regarding discovery of ESI. Juniper will not identify the Interrogatory in response to which any
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`document is being produced for any Interrogatory. Juniper will furnish only information in the
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`direct possession, custody, or control of Juniper Networks, Inc. Juniper will not state if Juniper
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`cannot fully respond to the following Interrogatories after exercising due diligence to secure the
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`information requested; specify the portion of each Interrogatory that cannot be responded to fully
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`and completely; state what efforts were made to obtain the requested information or the facts
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`relied upon that support the contention that the Interrogatory cannot be answered fully and
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`completely; or state what knowledge, information, or belief Juniper has concerning the
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`unanswered portion of any such Interrogatory.
`3.
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`Juniper objects to the Interrogatories to the extent they seek information or
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`documents that are subject to the attorney-client privilege, that evidence or constitute attorney
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`work product, that are the subject of confidentiality agreements with third parties, that are the
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`subject of a protective order in any separate proceeding, or that otherwise are not discoverable or
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`are the subject of any other privilege, whether based upon statute or recognized at common law,
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`specifically including documents protected by the common interest privilege and/or joint defense
`agreements.1 Juniper further specifically objects to the Instructions in the Interrogatories as
`imposing an undue burden that is not proportional to the needs of the case with respect to the
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`1 Any production of privileged information (whether “inadvertent” or otherwise) is
`governed by the parties’ agreement set forth in the Joint Case Management Statement (see Dkt.
`No. 31 at p. 5-6) and as set forth in the parties’ stipulation regarding discovery of ESI (see Dkt.
`No. 75 at ¶ 14).
`
`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10511051
`
`
`- 4 -
`
`JUNIPER’S RESPONSE TO
`FINJAN’S FOURTH SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 6 of 15
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`stated demands for the contents of a privilege log, including because the Instructions demand
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`information not reasonably necessary for the purposes of assessing privilege, such as “the number
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`of pages in such document.” Documents withheld under such an objection will be listed on a
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`“privilege log” pursuant to anticipated agreement between the parties regarding the proper scope
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`of such logs. Pursuant to the parties’ agreement as set forth in the Joint Case Management
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`Statement, Juniper will not log any item created on or after September 29, 2017 (see Dkt. No. 31
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`at p. 5).
`4.
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`Juniper objects to the Interrogatories to the extent that they seek information that is
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`not reasonably accessible due to undue burden or cost, the search for which is not proportional to
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`the needs of the case. In particular, the parties have agreed in their stipulation regarding the
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`discovery of ESI that the following sources of information are not reasonably accessible: backup
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`media including disaster recovery systems, digital voicemail, instant messaging, systems no longer
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`in use, and automatically saved versions of documents. Additionally, Juniper will not search
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`through non-networked memory disks or drives, regardless of whether those drives are owned by
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`the company or personally by its employees and regardless of whether those drives are internal to
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`a computer or external, as such searches are not proportional to the needs of the case because such
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`searches are not reasonably accessible due to undue burden and cost and any information
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`contained therein is likely to be cumulative to and/or duplicative of information maintained on
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`active network servers. Additionally, Juniper will not search through hard copy files as such
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`searches are not proportional to the needs of the case because such searches are not reasonably
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`accessible due to undue burden and cost and any information contained therein is likely to be
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`cumulative to and/or duplicative of information maintained on active network servers.
`5.
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`Juniper objects to the Interrogatories to the extent that they are compound.
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`Compound interrogatories will accrue correspondingly against the limit set forth in Fed. R. Civ. P.
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`6.
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`Juniper objects to the Interrogatories to the extent that they seek information that
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`Juniper is contractually obligated not to disclose. Similarly, Juniper objects to the Interrogatories
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`to the extent that they seek trade secrets, proprietary information, or other confidential
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10511051
`
`
`- 5 -
`
`JUNIPER’S RESPONSE TO
`FINJAN’S FOURTH SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 7 of 15
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`information. As the parties are still negotiating the terms of an appropriate Protective Order,
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`Juniper provides these Responses subject to the terms of the Interim Model Protective Order.
`7.
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`Juniper objects to the Interrogatories to the extent that they require Juniper to
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`produce information not in the possession, custody, or control of Juniper. Juniper also objects to
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`the Interrogatories to the extent they seek information already in the possession of Finjan or an
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`affiliate of Finjan or reasonably accessible to Finjan or an affiliate of Finjan.
`8.
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`Juniper objects to these Interrogatories to the extent they are unreasonably
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`cumulative or duplicative and therefore unduly burdensome and harassing to Juniper.
`9.
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`Juniper objects to the Interrogatories to the extent they assume the existence of
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`facts that do not exist and the occurrence of events that did not take place and to the extent they
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`assert legal arguments or characterizations. Any response of Juniper to an individual Interrogatory
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`is not intended to be, and shall not be construed as, an admission that any factual or legal predicate
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`stated in the Interrogatory is accurate.
`10.
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`Juniper objects to the Interrogatories to the extent that the time frame for which
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`information is sought is vague and ambiguous. Juniper will limit its response at least to the
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`statutory patent damages period, or more recently, as appropriate for each Interrogatory.
`11.
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`Juniper objects to the Interrogatories, including but not limited to the Definitions
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`and Instructions, to the extent that they require legal conclusions, expert testimony, are premature,
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`and/or are more appropriately obtained through other discovery such as oral depositions.
`12.
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`Juniper objects to the definition of “You,” “Your,” and “Defendant” as overbroad,
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`unduly burdensome, oppressive, indefinite, vague and ambiguous. Juniper also objects to these
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`definitions to the extent that they purport to impose discovery obligations on persons or entities
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`other than the parties to this action. Juniper will construe the terms to mean “Juniper Networks,
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`Inc.”
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`13.
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`Juniper objects to the definition of “Complaint.” The original complaint in this
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`matter was filed no earlier than September 29, 2017 (see Dkt. No. 1), not August 16, 2017.
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`“Complaint” as used herein will be construed to refer to the original complaint in this matter at
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10511051
`
`
`- 6 -
`
`JUNIPER’S RESPONSE TO
`FINJAN’S FOURTH SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 8 of 15
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`Dkt. No. 1 filed no earlier than September 29, 2017, and the First Amended Complaint in this
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`matter at Dkt. No. 88 filed on May 18, 2018.
`14.
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`Juniper also specifically objects to the extent that the Interrogatories seek
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`information related to any allegations that were dismissed in this matter. The Court has dismissed
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`with prejudice Finjan’s allegations regarding indirect and willful infringement, so, to the extent
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`applicable, Juniper will interpret each and every Interrogatory as not seeking information
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`regarding indirect or willful infringement.
`15.
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`Juniper objects to Finjan’s proposed definition of “document(s)” as overly broad
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`and unduly burdensome to the extent that it exceeds any definition provided in the Federal Rules
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`of Civil Procedure, the Federal Rules of Evidence, the Local Rules of the Northern District of
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`California, any Order of the Court, or any agreement between the parties. Juniper will respond to
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`these Interrogatories by treating “document(s)” as having the scope provided by the Federal Rules
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`of Civil Procedure, the Federal Rules of Evidence, the Local Rules of the Northern District of
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`California, any Order of the Court, or any agreement between the parties.
`16.
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`Juniper objects to the definition of “communication” as overly broad and unduly
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`burdensome to the extent that it exceeds any definition provided in the Federal Rules of Civil
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`Procedure, the Federal Rules of Evidence, the Local Rules of the Northern District of California,
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`any Order of the Court, or any agreement between the parties. Juniper will respond to these
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`Interrogatories by treating “communication” as having the scope provided by the Federal Rules of
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`Civil Procedure, the Federal Rules of Evidence, the Local Rules of the Northern District of
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`California, any Order of the Court, or any agreement between the parties.
`17.
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`Juniper objects to the definition of “relate to,” “reflecting,” “relating to,” and
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`“concerning” as overly broad, unduly burdensome, and not proportional to the needs of the case.
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`Juniper will respond to these Interrogatories by treating these terms as meaning “pertaining
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`directly to and reasonably accessible without undue burden.” Juniper also specifically objects to
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`the Interrogatories to the extent that they seek information regarding entities other than Juniper or
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`Finjan; Juniper’s production or non-production of information regarding other persons or entities
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`should not be construed as an explicit or implicit admission of any type.
`
`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10511051
`
`
`- 7 -
`
`JUNIPER’S RESPONSE TO
`FINJAN’S FOURTH SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 9 of 15
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`18.
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`Juniper objects to the Instructions related to responses in which Juniper asserts it
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`lacks the ability to comply, to the extent these Instructions purport to create a logging or response
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`obligation on the part of Juniper beyond that required by the Federal Rules of Civil Procedure, the
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`Federal Rules of Evidence, the Local Rules of the Northern District of California, any Order of the
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`Court, or any agreement between the parties and beyond the bounds of Juniper’s objections.
`19.
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`Juniper objects to the Instructions to the extent they specify a form for the
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`production of electronically stored information different than the form that the parties have or will
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`agree to produce documents in pursuant to the (anticipated) stipulation regarding discovery of ESI.
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`To the extent Juniper produces documents in response to these Interrogatories, Juniper will
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`produce such documents in the form or forms agreed upon by the parties in the (anticipated)
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`stipulation regarding discovery of ESI.
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`The General Objections set forth above are made without prejudice to and without waiver
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`of Juniper’s right to object on all appropriate grounds to the specific information sought by each
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`Interrogatory. These objections are hereby incorporated, as though set forth in full, into the
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`Response to each and every Interrogatory. Juniper reserves the right to make such additional
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`objections as may be appropriate and nothing contained herein shall be in any way construed as a
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`waiver of any such objection.
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`Subject to the General Objections outlined above and the more specific objections set forth
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`below, Juniper responds as follows:
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`RESPONSES TO INTERROGATORIES
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`INTERROGATORY NO. 11:
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`For each of the Accused Instrumentalities, identify and describe any and all Servers that are
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`owned, used, or operated, directly or indirectly, by Juniper, including Servers that Juniper operates as a
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`result of a contract with a third party, such as Amazon Web Services, Rackspace, Microsoft Azure or
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`other cloud computing platforms, and which host any portion, component, or module or an Accused
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`Instrumentality, or that provide support to the Accused Instrumentality, including through updates to
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`the software, rules, or definitions of the Accused Instrumentalities; such identification and description
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`should at least include what portion, component, or module of the Accused Instrumentality is hosted
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10511051
`
`
`- 8 -
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`JUNIPER’S RESPONSE TO
`FINJAN’S FOURTH SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
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`

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`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 10 of 15
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`on that Server, the function of the portion, component, or module of the Accused instrumentality, the
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`geographic location of the Server, and identification of whether the Server is operated by a third party,
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`and if so, the contract governing Juniper’s relationship with the that third party identified by document
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`production number.
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`RESPONSE TO INTERROGATORY NO. 11:
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`Juniper incorporates herein by reference all General Objections set forth above.
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`Juniper also specifically objects to this Interrogatory as unduly vague and ambiguous with
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`respect to the meaning of the term “provide support to the Accused Instrumentality, including
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`through updates to the software, rules, or definitions of the Accused Instrumentalities.” For
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`example, it is unduly vague and ambiguous whether this Interrogatory requires Juniper to
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`determine where updates to properly accused instrumentalities are pushed from. Such information
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`would be very difficult to obtain, and would make this Interrogatory unduly burdensome and not
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`proportional to the needs of this case. As further example, “provide support” is unduly vague and
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`ambiguous because it is not known what kind of support this Interrogatory is directed to and what
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`functionality of the properly accused instrumentalities the support is to be provided for. As further
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`example, “rules, or definitions” is unduly vague and ambiguous because those terms are very
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`broad and the Interrogatory does not specify what it means with the use of those terms.
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`Juniper also specifically objects to this Interrogatory as unduly vague and ambiguous with
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`respect to the meaning of the term “portion, component, or module.” Each properly accused
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`instrumentality has a substantial number of features powered by a substantial amount of hardware
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`and software, and this Interrogatory does not define the boundaries of a “portion, component, or
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`module” or even the differences between “portion,” “component,” and “module.”
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`Juniper also specifically objects to this Interrogatory as compound. This Interrogatory
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`constitutes at least two distinct questions—one related to “identify[ing] . . . any and all Servers”
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`and one related to “describ[ing] any and all Servers”—and will be treated as such with respect to
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`limits on interrogatories under Fed. R. Civ. P. 33(a).
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`Juniper also specifically objects to the definition of “Accused Instrumentalities” as
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`including all “products and services identified in Finjan’s Infringement Contentions,” particularly
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10511051
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`- 9 -
`
`JUNIPER’S RESPONSE TO
`FINJAN’S FOURTH SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 11 of 15
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`Spotlight Secure Threat Intelligence Platform. That product was not identified in the operative
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`First Amended Complaint, and it is therefore not part of this case. See id.; see also Richtek Tech.
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`Corp. v. uPi Semiconductor Corp., 2016 WL 1718135, at *2 (N.D. Cal. Apr. 29, 2016) (Alsup, J.).
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`Juniper also specifically objects to the definition of “Accused Instrumentalities” to the extent that
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`it includes the ATP Appliance. Juniper will respond regarding the ATP Appliance in due course,
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`as per the Court’s Order at Dkt. No. 85, this Interrogatory as it relates to ATP Appliance was
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`deemed to have been served May 18, 2018. Juniper also specifically objects to the definition of
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`“Accused Instrumentalities” to the extent that it purports to include previous or contemplated
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`versions, revision, releases, or continuations of any Juniper products or services other than those
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`specifically identified in Finjan’s Infringement Contentions and also in the operative complaint.
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`Juniper will interpret this Interrogatory as limited to only those instrumentalities specifically
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`identified in both the operative complaint and Finjan’s Infringement Contentions and also made,
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`used, sold, offered for sale, or imported into the U.S. within the statutory damages period.
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`Juniper also specifically objects to this Interrogatory to the extent that it seeks information
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`or documents that are subject to the attorney-client privilege, that evidence or constitute attorney
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`work product, or that otherwise are not discoverable or are the subject of any other applicable
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`privilege or immunity, whether based upon statute or recognized at common law, specifically
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`including documents protected by the common interest privilege and/or joint defense agreements.
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`Juniper also specifically objects to this Interrogatory as seeking discovery that is not
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`proportional to the needs of the case, considering the importance of the issues at stake in the
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`action, the amount in controversy, the parties’ relative access to relevant information, the parties’
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`resources, the importance of the discovery in resolving the issues, and whether the burden or
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`expense of the proposed discovery outweighs its likely benefit.
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`Juniper also specifically objects to this Interrogatory on the grounds that it is overbroad,
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`unduly burdensome, oppressive, vague and ambiguous, not proportional to the needs of the case,
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`and seeking irrelevant information.
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`Subject to these specific objections and the general objections incorporated herein, Juniper
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`responds as follows:
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10511051
`
`
`- 10 -
`
`JUNIPER’S RESPONSE TO
`FINJAN’S FOURTH SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 12 of 15
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`Juniper uses Amazon Web services (“AWS”) for much of the Sky ATP analysis conducted
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`in the US West, EU West, APAC, and Canada regions. A demo version of the Space Security
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`Director is also available on AWS, primarily used to demonstrate the functionality of the Space
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`Security Director to potential customers.
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`For Joe Sandbox, Juniper uses Servers from (1) Iweb in Canada, Santa Clara (United
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`States), and Amsterdam (European Union) and (2) IBM in Tokyo, Japan.
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`INTERROGATORY NO. 12:
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`For each of the Accused Instrumentalities, identify and describe all Databases that are
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`incorporated or used, either directly or indirectly, by the Accused Instrumentalities; such identification
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`and description should at least include the type of database, what type and category of information the
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`Database stores, where geographically the Database is located, any code or internal names for the
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`Database, and a description of how the Database is organized.
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`RESPONSE TO INTERROGATORY NO. 12:
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`Juniper incorporates herein by reference all General Objections set forth above.
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`Juniper also specifically objects to this Interrogatory as unduly vague and ambiguous with
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`respect to the meaning of the term “Database,” which is defined as including “all systems,
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`components, or modules that are ‘a collection of interrelated data organized according to a
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`database schema to serve one or more applications’ and to avoid any doubt, and irrespective of
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`Juniper’s interpretation of ‘Database,’ includes, but is not limited to, the following: relational
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`databases, RDBMS, SQL, MySQL, SQLite, PostgresSQL, DB2, Oracle Database, Microsoft SQL
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`server, NoSQL, key-value stores, REDIS, DynamoDB, wide column stores, Cassandra, Scylla,
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`HBase, document stores, MongoDB, Couchbase, search engine databases, JSON stores,
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`Elasticsearch, Splunk, and data stores.” The definition provided by the Interrogatory describes a
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`“Database” as “organized according to a database schema.” However, the majority of the
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`examples of a “Database” provided by the Interrogatory are not “organized according to a
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`database schema.” For example, NoSQL; NoSQL database implementation types, such as key-
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`value stores, wide column stores, or document stores; and NoSQL databases, such as REDIS,
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`DyanmoDB, Cassandra, Scylla, HBase, MongoDB, and Couchbase, are not organized according
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10511051
`
`
`- 11 -
`
`JUNIPER’S RESPONSE TO
`FINJAN’S FOURTH SET OF INTERROGATORIES
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 499-2 Filed 05/30/19 Page 13 of 15
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`to a database schema. As a further example, Elasticsearch is a cloud provider of search and
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`analytics that is not a database organized according to a database schema. As further example,
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`Splunk is a tool used for monitoring network traffic that uses databases not organized according to
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`a database schema. As further example, search engine databases, JSON stores, and data stores are
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`unduly vague and ambiguous to the extent that it is unclear what database these categories are
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`referring to. Juniper will interpret this Interrogatory as limited to only those databases that are
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`“organized according to a database schema.”
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`Juniper also specifically objects to this Interrogatory as overly broad and unduly
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`burdensome to the extent it seeks all Databases that are incorporated or used by SRX Gateways.
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`SRX Gateways is a very large product that uses a wide range of databases, several of which are
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`not accused because they are not related to infringement, even under Finjan’s contentions. Juniper
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`will interpret this Interrogatory as limited to only those databases “organized according to a
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`database schema” that are related to Finjan’s infr