`Case 3:17-cv-05659-WHA Document 499-3 Filed 05/30/19 Page 1 of 4
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`Case 3:17-cv-05659-WHA Document 499-3 Filed 05/30/19 Page 2 of 4
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` UNITED STATES DISTRICT COURT
` NORTHERN DISTRICT OF CALIFORNIA
` SAN FRANCISCO DIVISION
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`FINJAN, INC., a Delaware : Case No.
`Corporation, : 3:17-cv-05659-WHA
` Plaintiff, :
`v. :
`JUNIPER NETWORKS, INC., a :
`Delaware Corporation, :
` Defendant. :
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` HIGHLY CONFIDENTIAL SOURCE CODE - ATTORNEYS' EYES ONLY
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` VIDEOTAPED DEPOSITION OF CHANDRA NAGARAJAN
` Sunnyvale, California
` Thursday, May 31, 2018
` 9:05 a.m.
`
`Job No.: 189837
`Pages: 1 - 245
`Reported By: Charlotte Lacey, RPR, CSR No. 14224
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`Case 3:17-cv-05659-WHA Document 499-3 Filed 05/30/19 Page 3 of 4
`HIGHLY CONFIDENTIAL SOURCE CODE - ATTORNEYS' EYES ONLY
`Transcript of Chandra Nagarajan
`Conducted on May 31, 2018
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`adapters determine the threat level for the file, which
`is the primary -- primary goal of this ATP product.
` Q Have you heard of something called Joe static?
` A That is a Joe static adapter also in the -- in
`the -- in the series of analysis.
` Q What does Joe static do?
` A The Joe static is -- is a -- we have -- we
`have a license and software from Joe Security, and then
`it does the static analysis as -- as -- the adapter does
`static analysis from the Joe Security product.
` Q Do you know how Joe static works?
` A I -- I don't know how Joe static works. We...
` Q Have you heard of something called Joe
`Sandbox?
` A The Joe Sandbox is also the -- is a -- is a
`dynamic analysis product from Joe Security, and we use
`that as part of your product for dynamic analysis.
` Q Do you know how does Joe Sandbox work?
` A So we -- we -- we have not developed this Joe
`Sandbox, so it's a licensed software. So I'm not fully
`aware of how it works. But the idea -- the main idea is
`to execute the file in the -- in an environment and
`capture all the behaviors once it runs, and -- and
`then -- and then capture all the behaviors, and based on
`that, determine the threat level.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Case 3:17-cv-05659-WHA Document 499-3 Filed 05/30/19 Page 4 of 4
`HIGHLY CONFIDENTIAL SOURCE CODE - ATTORNEYS' EYES ONLY
`Transcript of Chandra Nagarajan
`Conducted on May 31, 2018
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` So it's really an isolated environment where
`you're safe to execute a file and run a file and then
`watch its behaviors and -- in a very dynamic fashion.
` Q Is Joe Sandbox different from deception?
` A Joe Sandbox, it is -- it is -- it is one and
`the same. So what -- what we have done is there are --
`there are -- it's a third-party software. We have added
`one or two functionalities there to -- to -- in that --
`during the dynamic analysis to watch for. And it's
`really the same -- same -- same adapter. Deception
`and -- is -- deception is just a -- an adapter that this
`Joe Security runs.
` Q What are the one or two functionalities that
`are added?
` A So I, again, I can give a representative one
`or two, but it's a thing we should refer to the code to
`do -- to check all the things. For example, we try to
`insert a fake USB or something and see how the program
`will behave if there is a USB in a dynamic fashion. So
`that is one of the things that happen. I think there
`are six or seven more things which -- which is like
`that.
` Q Can you describe the six or more things?
` A I -- I can't -- I'm not able to recollect all
`the six things. The whatever -- the one thing which I
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`PLANET DEPOS
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