`Case 3:17-cv-05659-WHA Document 500-2 Filed 05/30/19 Page 1 of 4
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`Case 3:17-cv-05659-WHA Document 500-2 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 500-2 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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`63
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`10:51 a.m.
` Please proceed, Counsel.
`BY MR. LEE:
` Q Do you recall earlier we were discussing why
`Sky ATP was added?
` A Yes. There was a question about that.
` Q And you mentioned that it was to give SRX this
`next-generation capability, correct?
` MR. KAGAN: Objection; form.
` A So -- so the -- the -- ATP is one of the
`functionalities of NG firewall, and one of the many
`functionalities of it has evolved. Since that piece was
`missing in SRX, the Sky ATP was developed.
` Q When you say that piece is missing, what do
`you mean?
` A The ATP, as a functionality, is missing in
`SRX.
` Q So does the ATP contribute to the
`next-generation capability at all?
` MR. KAGAN: Objection; form.
` A The ATP is one of the many functionalities in
`NG firewall. To that extent, the ATP functionality is
`missing.
` THE REPORTER: To...
` A To NG firewall, and to that extent, it's --
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`
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`Case 3:17-cv-05659-WHA Document 500-2 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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`it's a missing functionality.
` Q How does ATP contribute to the next-generation
`capability?
` MR. KAGAN: Objection; form.
` A So -- this is basically the market demands,
`right? There's no general definition of what an NG
`firewall is. So it all depends on what your competition
`offers in -- in NG firewall and what are all the various
`functionalities which are missing against the
`competition, and that is to the extent...
` Q What did SRX have before it had Sky ATP?
` MR. KAGAN: Objection; form.
` A So before Sky ATP -- before Sky ATP was added,
`there was a AV engine functionality in SRX, which --
`which is -- which detects malwares. But it -- it only
`detects known -- known malwares.
` Q What do you mean by it only detects known
`malware?
` A So whatever is known to the AV -- AV software
`we use, it detects those malwares.
` Q And Sky ATP detects unknown malware, right?
` A Sky ATP can -- can detect malwares which were
`not previously known to others.
` Q Is there a name for this AV software?
` A I -- I don't work in -- in that area, so
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`PLANET DEPOS
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