`
`IRELL & MANELLA LLP
`
`
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Joshua P. Glucoft (SBN 301249)
`jglucoft@irell.com
`Casey Curran (SBN 305210)
`ccurran@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`Rebecca L. 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
`)
`Case No. 3:17-cv-05659-WHA
`
`)
`DECLARATION OF JOSHUA GLUCOFT
`)
`IN SUPPORT OF DEFENDANT JUNIPER
`)
`NETWORKS, INC.’S OPPOSITION TO
`)
`MOTION TO COMPEL
`)
`
`)
`
`)
`Hon. William H, Alsup
`)
`
`
`FINJAN, INC.,
`
`Plaintiff,
`
`v.
`
`
`JUNIPER NETWORKS, INC.,
`
`Defendant.
`
`
`
`
`
`
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`
`L & MANELLA LLP
`stered Limited Liability
`
`10489751
`
`
`
`
`
`DEC. OF JOSHUA GLUCOFT ISO JUNIPER’S
`OPPOSITION TO MOTION TO COMPEL
`Case No. 3:17-cv-05659-WHA
`
`
`
`Case 3:17-cv-05659-WHA Document 53-1 Filed 04/13/18 Page 2 of 2
`
`DECLARATION OF JOSHUA GLUCOFT
`I, Joshua Glucoft, declare as follows:
`1.
`I am an attorney at the law firm of Irell & Manella LLP, counsel of record for Juniper
`Networks, Inc. in the above-captioned action. I am a member in good standing of the State Bar of
`California and have been admitted to practice before this Court. I have personal knowledge of the
`facts set forth in this Declaration and, if called as a witness, could and would testify competently to
`such facts under oath.
`2.
`I submit this declaration in support of Juniper Networks, Inc.’s (“Juniper”)
`opposition to Finjan, Inc.’s (“Finjan”) Motion to Compel (Dkt. No. 48).
`3.
`On March 19, 2018, Juniper produced its source code for the SRX, Sky ATP, and
`Space Security Director products. On March 7, 2018, Juniper produced more than 160,000 pages
`of technical documents related to these products.
`4.
`Juniper expects to produce by April 14, 2018 approximately 7,000 additional pages
`of highly confidential technical documents, including design and development documents for Sky
`ATP, and substantially all of Juniper’s production of design and development documents for SRX
`and Space Security Director.
`5.
`Juniper’s Sky ATP is a distinct product from the ATP Appliance. The source code
`that Juniper collected and produced for Sky ATP is different from the source code used in the ATP
`Appliance.
`Executed this 13th day of April, 2018, at Los Angeles, California.
`I declare under penalty of perjury under the laws of the United States of America that the
`foregoing is true and correct.
`
`/s/ Joshua Glucoft
`Joshua Glucoft
`
`
`
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`L & MANELLA LLP
`stered Limited Liability
`
`10489751
`
`
`
`- 1 -
`
`DEC. OF JOSHUA GLUCOFT ISO JUNIPER’S
`OPPOSITION TO MOTION TO COMPEL
`Case No. 3:17-cv-05659-WHA
`
`
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