`Case 3:17-cv-05659-WHA Document 113-3 Filed 06/22/18 Page 1 of 4
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`EXHIBIT B
`EXHIBIT B
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`Case 3:17-cv-05659-WHA Document 113-3 Filed 06/22/18 Page 2 of 4
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`From:
`To:
`Cc:
`Subject:
`Date:
`
`~Kastens, Kristopher
`Carson, Rebecca
`~Andre, Paul; ~Kobialka, Lisa; ~Hannah, James; Glucoft, Josh; Curran, Casey
`RE: Finjan/Juniper - missing documents
`Tuesday, May 22, 2018 5:38:59 PM
`
`Rebecca,
`
`We are producing the charts that were referenced in Finjan’s Response to Juniper’s Interrogatory
`No. 6 in a separate email which are bearing bates numbers FINJAN-JN 303431-468. While two of
`the charts include watermarks of “DRAFT – FOR INTERNAL REVIEW ONLY” or “DRAFT – ATTORNEY
`WORK PRODUCT,” these charts do not contain any attorney work product and were the final charts
`that are referred to in the interrogatory response. These watermarks were maintained, but would
`have been removed before being shared with Juniper around October 2015 as part of the parties’
`licensing discussions. We are producing the document as it was maintained and confirm that they
`are not drafts and do not contain any attorney work product.
`
`Sincerely,
`Kris
`
`
`
`Kris Kastens
`Associate
`
`Kramer Levin Naftalis & Frankel LLP
`990 Marsh Road, Menlo Park, California 94025
`T 650.752.1715 F 650.752.1815
`
`This communication (including any attachments) is intended solely for the recipient(s) named above and may contain
`information that is confidential, privileged or legally protected. Any unauthorized use or dissemination of this
`communication is strictly prohibited. If you have received this communication in error, please immediately notify the sender
`by return e-mail message and delete all copies of the original communication. Thank you for your cooperation.
`
`
`From: Kastens, Kris
`Sent: Tuesday, May 22, 2018 11:40 AM
`To: Carson, Rebecca
`Cc: Andre, Paul; Kobialka, Lisa; Hannah, James; Glucoft, Josh (JGlucoft@irell.com); Curran, Casey
`(ccurran@irell.com)
`Subject: RE: Finjan/Juniper - missing documents
`
`Rebecca,
`
`Regarding the email you attached, the attachment should be the next document in the production
`after the email (FINJAN-JN193518-520).
`
`We’re looking into your other requests.
`
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`Case 3:17-cv-05659-WHA Document 113-3 Filed 06/22/18 Page 3 of 4
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`Sincerely,
`Kris
`
`
`
`Kris Kastens
`Associate
`
`Kramer Levin Naftalis & Frankel LLP
`990 Marsh Road, Menlo Park, California 94025
`T 650.752.1715 F 650.752.1815
`kkastens@kramerlevin.com
`
`Bio
`
`This communication (including any attachments) is intended solely for the recipient(s) named above and may contain
`information that is confidential, privileged or legally protected. Any unauthorized use or dissemination of this
`communication is strictly prohibited. If you have received this communication in error, please immediately notify the sender
`by return e-mail message and delete all copies of the original communication. Thank you for your cooperation.
`
`From: Carson, Rebecca [mailto:RCarson@irell.com]
`Sent: Tuesday, May 22, 2018 11:30 AM
`To: #Finjan-KramerLevin [Ext]
`Cc: #Juniper/Finjan [Int]
`Subject: [EXTERNAL] Finjan/Juniper - missing documents
`
`Counsel:
`
`In Finjan’s supplemental response to Interrogatory No. 6, Finjan refers to “already prepared
`confidential claim charts on other Patents-in-Suit, including the ‘494 Patent.” Please identify the
`Bates number for these alleged claim charts, including the alleged claim chart for the ‘494 patent, or
`produce them by close of business today so that they can be used at Thursday’s deposition. We
`have not been able to find them in Finjan’s production.
`
`In addition, Finjan does not appear to have produced a complete copy of the attached email. It
`contains an attachment, and we have not been able to locate the attachment in Finjan’s production.
`Please produce a complete version of the email (with attachment) by close of business today so that
`it can be used at Thursday’s deposition.
`
`Regards,
`Rebecca
`
`
`PLEASE NOTE: This message, including any attachments, may include privileged,
`confidential and/or inside information. Any distribution or use of this communication by
`anyone other than the intended recipient(s) is strictly prohibited and may be unlawful. If you
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`Case 3:17-cv-05659-WHA Document 113-3 Filed 06/22/18 Page 4 of 4
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`are not the intended recipient, please notify the sender by replying to this message and then
`delete it from your system. Thank you.
`
`
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