`
`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
`Sharon Song (SBN 313535)
`ssong@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
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`Case No. 3:17-cv-05659-WHA
`
`DECLARATION OF SHARON SONG IN
`SUPPORT OF JUNIPER NETWORKS,
`INC.’S MOTION FOR
`ADMINISTRATIVE RELIEF TO FILE
`DOCUMENTS UNDER SEAL
`
`
`Judge: Hon. William Alsup
`
`FINJAN, INC.,
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`Plaintiff,
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`JUNIPER NETWORKS, INC.,
`
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`vs.
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`Defendant.
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`1012560
`
`
`
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`DECLARATION OF SHARON SONG ISO JUNIPER’S
`MOTION FOR ADMINISTRATIVE RELIEF
`TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`Case 3:17-cv-05659-WHA Document 112-1 Filed 06/22/18 Page 2 of 3
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`DECLARATION OF SHARON SONG
`
`I, Sharon Song, declare as follows:
`1.
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`I am an attorney at the law firm of Irell & Manella LLP, counsel of record for
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`Juniper Networks, Inc. (“Juniper”) in the above-captioned matter. I am a member in good
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`standing of the State Bar of California and have been admitted to practice before this Court. I
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`have personal knowledge of the facts set forth in this Declaration and, if called as a witness, could
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`and would testify competently to such facts under oath.
`2.
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`I submit this declaration in support of Juniper’s June 22, 2018 Motion for
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`Administrative Relief to File Documents Under Seal, which asks the Court for an Order to file
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`under seal the following documents:
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` Exhibit A to Juniper’s Opposition to Finjan’s Motion for Leave to File Second Amended
`Complaint (the “Brief”) (excerpt from Finjan’s Second Supplemental Objections and
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`Responses to Defendant Juniper’s First Set of Interrogatories (No. 6)); and
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` Exhibit C to the Brief (the claim charts for U.S. Patent No. 6,418,731 that were prepared
`by Finjan in 2015, and produced by Finjan to Juniper on May 22, 2018, bearing bates
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`numbers FINJAN-JN303455-FINJAN-JN303458).
`3.
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`The sealed portions of the documents described above that Juniper seeks to file
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`under seal contain confidential information of Finjan. In this declaration, I explain why these
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`materials are sealable pursuant to Civil Local Rule 79-5.
`4.
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`Exhibit A to the Brief is an excerpt from Finjan’s Second Supplemental Objections
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`and Responses to Defendant Juniper’s First Set of Interrogatories (No. 6) that has been designated
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`confidential by Finjan.
`5.
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`Exhibit C to the Brief are the claim charts for U.S. Patent No. 6,418,731 that were
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`prepared by Finjan in 2015, and produced by Finjan to Juniper on May 22, 2018, bearing bates
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`numbers FINJAN-JN303455-FINJAN-JN303458, that have been designated confidential by
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`Finjan.
`6.
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`
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`1012560
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`For these reasons, the documents described above should be filed under seal.
`
`- 1 -
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`DECLARATION OF SHARON SONG ISO JUNIPER’S
`MOTION FOR ADMINISTRATIVE RELIEF
`TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`
`
`Case 3:17-cv-05659-WHA Document 112-1 Filed 06/22/18 Page 3 of 3
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`Executed on June 22, 2018, at Los Angeles, California.
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`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 to the best of my knowledge.
`
`
`
` /s/ Sharon Song
` Sharon Song
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`1012560
`
`
`- 2 -
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`DECLARATION OF SHARON SONG ISO JUNIPER’S
`MOTION FOR ADMINISTRATIVE RELIEF
`TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`
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