`
`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Joshua 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 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.
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCISCO DIVISION
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10535054
`
`
`FINJAN, INC., a Delaware Corporation,
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`Plaintiff,
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`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
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`vs.
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`Defendant.
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`Case No. 3:17-cv-05659-WHA
`
`DECLARATION OF SHARON SONG IN
`SUPPORT OF DEFENDANT JUNIPER
`NETWORKS, INC.’S OPPOSITION TO
`MOTION TO COMPEL (Dkt. No. 114)
`
`
`
`
`DECL. OF SHARON SONG ISO JUNIPER’S
`OPPOSITION TO MOTION TO COMPEL
`Case No. 3:17-cv-05659-WHA
`
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`Case 3:17-cv-05659-WHA Document 117-1 Filed 06/26/18 Page 2 of 3
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`DECLARATION OF SHARON SONG
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`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. in the above-captioned action. I am a member in good standing of the
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`State Bar of California. I have personal knowledge of the facts set forth in this Declaration and, if
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`called as a witness, could and would testify competently to such facts under oath.
`2.
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`I submit this declaration in support of Juniper Networks, Inc.’s (“Juniper”)
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`opposition to Finjan, Inc.’s (“Finjan”) Motion to Compel (Dkt. No. 114).
`3.
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`Attached as Exhibit A to Juniper’s Opposition to Finjan’s Motion to Compel is a
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`true and correct copy of excerpts from the transcript of proceedings on August 15, 2017 for
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`Fraunhofer-Gesellschaft Zur Forderung Der Angewandten Forschung E.V. v. Sirius XM Radio
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`Inc., Case No. 17-148-JFB-SRF (D. Del.), where an attorney from Kramer Levin Naftalis &
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`Frankel LLP (the firm representing Finjan in this case), acting as defense counsel, states to the
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`Court that “[i]f [Plaintiffs] want litigation counsel to review our confidential information, they are
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`going to have to have different counsel be involved in the post grant proceedings.” Id. at 62.
`4.
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`On May 30, 2018, I met and conferred with Finjan’s counsel over the language
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`regarding the patent prosecution bar in this district’s Interim Model Protective Order (“Model
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`PO”). With regard to Finjan’s proposed changes to the language regarding the patent prosecution
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`bar in the Model PO, I asked Finjan’s counsel how it would be possible for any individual
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`assisting in defending a patent in an inter partes review proceeding to also not be “directly or
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`indirectly drafting, amending, advising, or otherwise affecting the scope of patent claims.”
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`Finjan’s counsel did not provide a response to this question, and the parties did not reach an
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`agreement during this meet and confer.
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`[Signature page to follow]
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10535054
`
`
`- 1 -
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`DECL. OF SHARON SONG ISO JUNIPER’S
`OPPOSITION TO MOTION TO COMPEL
`Case No. 3:17-cv-05659-WHA
`
`
`
`Case 3:17-cv-05659-WHA Document 117-1 Filed 06/26/18 Page 3 of 3
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`Executed this 26th day of June, 2018, at Los Angeles, 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.
`
` /s/ Sharon Song
`
` Sharon Song
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
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`10535054
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`- 2 -
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`DECL. OF SHARON SONG ISO JUNIPER’S
`OPPOSITION TO MOTION TO COMPEL
`Case No. 3:17-cv-05659-WHA
`
`
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