Case 3:17-cv-05659-WHA Document 95-5 Filed 06/07/18 Page 1 of 3
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`DECLARATION OF REBECCA CARSON
`
`I, Rebecca Carson, declare as follows:
`
`1.
`
`I am a member in good standing of the State Bar of California and a partner at
`
`Irell & Manella LLP, counsel of record in this action for Defendant Juniper Networks, Inc.
`
`(“Juniper”). I have personal knowledge of the facts set forth in this declaration, and I could and
`
`would testify competently thereto if called upon to do so.
`
`2.
`
`Juniper produced sales information (JNPR-FNJN_29028_00472484) showing
`
`2017 revenues for SRX units and Sky ATP licenses.
`
`3.
`
`Attached as Exhibit 1 is a true and correct copy of U.S. Patent No. 6,804,780
`
`(“the ’780 Patent”) asserted by Plaintiff Finjan, Inc. (“Finjan”) in this matter and the subject of
`
`Juniper’s motion for summary judgment.
`
`4.
`
`Attached as Exhibit 2 is a true and correct copy of excerpts of the prosecution
`
`history of the ’780 Patent, which was downloaded from the USPTO website.
`
`5.
`
`Attached as Exhibit 3 is a true and correct copy of Exhibit B-1 to Finjan’s
`
`Infringement Contentions charting the ’780 Patent against the SRX alone and in combination
`
`with Sky ATP, served on March 8, 2018.
`
`6.
`
`Attached as Exhibit 4 is a true and correct copy of Exhibit B-2 to Finjan’s
`
`Infringement Contentions charting the ’780 Patent against Sky ATP, served on March 8, 2018.
`
`7.
`
`Attached as Exhibit 5 is a true and correct copy of excerpts of the May 24, 2018
`
`deposition transcript of John Garland. He served as Finjan’s Rule 30(b)(6) witness on the
`
`following topic: “All facts and circumstances regarding any efforts taken to comply with the
`
`marking and notice provisions of 35 U.S.C. § 287 with respect to the Asserted Patents, including
`
`any efforts by Finjan to ensure compliance by its licensees with said marking provisions.”
`
`8.
`
`Attached as Exhibit 6 is a true and correct copy of excerpts of the rough
`
`deposition transcript of Raju Manthena, Principal Engineer with Juniper, held on May 30, 2018.
`
`10520306
`
`- 1 -
`
`DECLARATION OF REBECCA CARSON ISO
`DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 95-5 Filed 06/07/18 Page 2 of 3
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`9.
`
`Attached as Exhibit 7 is a true and correct copy of excerpts of Juniper’s Notice of
`
`Specific Unmarked Products Under Artic Cat, Inc. v. Bombardier Recreational.
`
`10.
`
`Attached as Exhibit 8 is a true and correct copy of excerpts of Finjan’s Objections
`
`and Response to Juniper’s First Set of Interrogatories (Nos. 1-10).
`
`11.
`
`Attached as Exhibit 9 is a true and correct copy of excerpts of the Sky Advanced
`
`Threat Prevention Administration Guide (JNPR-FNJN_29006_00162061), substituted with a
`
`higher resolution, color version.
`
`12.
`
`Attached as Exhibit 10 is a true and correct copy of excerpts of the Sky ATP Data
`
`Sheet (JNPR-FNJN_29006_00162376), substituted with a higher resolution, color version.
`
`13.
`
`Attached as Exhibit 11 is a true and correct copy of the Sky ATP License Types
`
`(JNPR-FNJN_29031_00555803), substituted with a higher resolution, color version.
`
`14.
`
`Attached as Exhibit 12 is a true and correct copy of excerpts of the Junos OS User
`
`Access and Authentication Feature Guide, available at https://www.juniper.net/
`
`documentation/en_US/junos/information-products/pathway-pages/system-basics/user-access.pdf.
`
`15.
`
`Attached as Exhibit 13 is a true and correct copy of excerpts of Volume 3: Sorting
`
`and Searching from The Art of Computer Programming by Donald E. Knuth, published in 1973
`
`by Addison-Wesley Publishing Company, Inc.
`
`16.
`
`Attached as Exhibit 14 is a true and correct copy of excerpts of “Functional
`
`Requirements for Uniform Resource Names” by K. Sollins et al., submitted to the Internet
`
`Engineering Task Force’s Network Working Group in December 1994, available at
`
`https://web.archive.org/web/19991013104107/https://www.ietf.org/rfc/rfc1737.txt.
`
`17.
`
`Attached as Exhibit 15 is a true and correct copy of Location-Independent
`
`Naming for Virtual Distributed Software Repositories by Shirley Browne et al. (1995).
`
`18.
`
`Attached as Exhibit 16 is a true and correct copy of excerpts of the
`
`“Trojan.Dropper” description published by Symantec Corporation, available at
`
`https://www.symantec.com/security-center/writeup/2002-082718-3007-99.
`
`10520306
`
`- 2 -
`
`DECLARATION OF REBECCA CARSON ISO
`DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
`(Case No. 3:17-cv-05659-WHA)
`
`

`

`Case 3:17-cv-05659-WHA Document 95-5 Filed 06/07/18 Page 3 of 3
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`19.
`
`Attached as Exhibit 17 is a true and correct copy of excerpts of the trial transcript
`
`of Finjan Software Ltd. v. Secure Computing Corp., Case No. 06-469-GMS, available at Dkt.
`
`No. 228 (Mar. 4, 2008).
`
`20.
`
`Attached as Exhibit 18 is a true and correct copy of excerpts of the trial transcript
`
`of Finjan Software Ltd. v. Secure Computing Corp., Case No. 06-469-GMS, available at Dkt.
`
`No. 230 (Mar. 6, 2008).
`
`21.
`
`Attached as Exhibit 19 is a true and correct copy of excerpts of Plaintiff Finjan,
`
`Inc.’s First Supplemental Objections And Response To Defendant Juniper Networks, Inc.’s First
`
`Set Of Interrogatories (Nos. 3, 4, 6, 7).
`Executed this 7th day of June, 2018, at Newport Beach, California.
`I declare under penalty of perjury under the laws of the United States of America that the
`
`foregoing is true and correct.
`
`/s/ Rebecca Carson
`Rebecca Carson
`
`10520306
`
`- 3 -
`
`DECLARATION OF REBECCA CARSON ISO
`DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
`(Case No. 3:17-cv-05659-WHA)
`
`