`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`DECLARATION OF REBECCA CARSON
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`I, Rebecca Carson, declare as follows:
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`1.
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`I am a member in good standing of the State Bar of California and a partner at
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`Irell & Manella LLP, counsel of record in this action for Defendant Juniper Networks, Inc.
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`(“Juniper”). I have personal knowledge of the facts set forth in this declaration, and I could and
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`would testify competently thereto if called upon to do so.
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`2.
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`Juniper produced sales information (JNPR-FNJN_29028_00472484) showing
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`2017 revenues for SRX units and Sky ATP licenses.
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`3.
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`Attached as Exhibit 1 is a true and correct copy of U.S. Patent No. 6,804,780
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`(“the ’780 Patent”) asserted by Plaintiff Finjan, Inc. (“Finjan”) in this matter and the subject of
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`Juniper’s motion for summary judgment.
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`4.
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`Attached as Exhibit 2 is a true and correct copy of excerpts of the prosecution
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`history of the ’780 Patent, which was downloaded from the USPTO website.
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`5.
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`Attached as Exhibit 3 is a true and correct copy of Exhibit B-1 to Finjan’s
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`Infringement Contentions charting the ’780 Patent against the SRX alone and in combination
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`with Sky ATP, served on March 8, 2018.
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`6.
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`Attached as Exhibit 4 is a true and correct copy of Exhibit B-2 to Finjan’s
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`Infringement Contentions charting the ’780 Patent against Sky ATP, served on March 8, 2018.
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`7.
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`Attached as Exhibit 5 is a true and correct copy of excerpts of the May 24, 2018
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`deposition transcript of John Garland. He served as Finjan’s Rule 30(b)(6) witness on the
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`following topic: “All facts and circumstances regarding any efforts taken to comply with the
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`marking and notice provisions of 35 U.S.C. § 287 with respect to the Asserted Patents, including
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`any efforts by Finjan to ensure compliance by its licensees with said marking provisions.”
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`8.
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`Attached as Exhibit 6 is a true and correct copy of excerpts of the rough
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`deposition transcript of Raju Manthena, Principal Engineer with Juniper, held on May 30, 2018.
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`DECLARATION OF REBECCA CARSON ISO
`DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
`(Case No. 3:17-cv-05659-WHA)
`
`
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`Case 3:17-cv-05659-WHA Document 96-4 Filed 06/07/18 Page 2 of 3
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`9.
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`Attached as Exhibit 7 is a true and correct copy of excerpts of Juniper’s Notice of
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`Specific Unmarked Products Under Artic Cat, Inc. v. Bombardier Recreational.
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`10.
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`Attached as Exhibit 8 is a true and correct copy of excerpts of Finjan’s Objections
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`and Response to Juniper’s First Set of Interrogatories (Nos. 1-10).
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`11.
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`Attached as Exhibit 9 is a true and correct copy of excerpts of the Sky Advanced
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`Threat Prevention Administration Guide (JNPR-FNJN_29006_00162061), substituted with a
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`higher resolution, color version.
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`12.
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`Attached as Exhibit 10 is a true and correct copy of excerpts of the Sky ATP Data
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`Sheet (JNPR-FNJN_29006_00162376), substituted with a higher resolution, color version.
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`13.
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`Attached as Exhibit 11 is a true and correct copy of the Sky ATP License Types
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`(JNPR-FNJN_29031_00555803), substituted with a higher resolution, color version.
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`14.
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`Attached as Exhibit 12 is a true and correct copy of excerpts of the Junos OS User
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`Access and Authentication Feature Guide, available at https://www.juniper.net/
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`documentation/en_US/junos/information-products/pathway-pages/system-basics/user-access.pdf.
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`15.
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`Attached as Exhibit 13 is a true and correct copy of excerpts of Volume 3: Sorting
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`and Searching from The Art of Computer Programming by Donald E. Knuth, published in 1973
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`by Addison-Wesley Publishing Company, Inc.
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`16.
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`Attached as Exhibit 14 is a true and correct copy of excerpts of “Functional
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`Requirements for Uniform Resource Names” by K. Sollins et al., submitted to the Internet
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`Engineering Task Force’s Network Working Group in December 1994, available at
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`https://web.archive.org/web/19991013104107/https://www.ietf.org/rfc/rfc1737.txt.
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`17.
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`Attached as Exhibit 15 is a true and correct copy of Location-Independent
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`Naming for Virtual Distributed Software Repositories by Shirley Browne et al. (1995).
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`18.
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`Attached as Exhibit 16 is a true and correct copy of excerpts of the
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`“Trojan.Dropper” description published by Symantec Corporation, available at
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`https://www.symantec.com/security-center/writeup/2002-082718-3007-99.
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`10520306
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`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 96-4 Filed 06/07/18 Page 3 of 3
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`19.
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`Attached as Exhibit 17 is a true and correct copy of excerpts of the trial transcript
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`of Finjan Software Ltd. v. Secure Computing Corp., Case No. 06-469-GMS, available at Dkt.
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`No. 228 (Mar. 4, 2008).
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`20.
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`Attached as Exhibit 18 is a true and correct copy of excerpts of the trial transcript
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`of Finjan Software Ltd. v. Secure Computing Corp., Case No. 06-469-GMS, available at Dkt.
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`No. 230 (Mar. 6, 2008).
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`21.
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`Attached as Exhibit 19 is a true and correct copy of excerpts of Plaintiff Finjan,
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`Inc.’s First Supplemental Objections And Response To Defendant Juniper Networks, Inc.’s First
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`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
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`foregoing is true and correct.
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`/s/ Rebecca Carson
`Rebecca Carson
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`10520306
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`DECLARATION OF REBECCA CARSON ISO
`DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
`(Case No. 3:17-cv-05659-WHA)
`
`