Case 3:17-cv-05659-WHA Document 125-1 Filed 06/28/18 Page 1 of 5
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`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
`
`FINJAN, INC.,
`
`
`Plaintiff,
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`
`
`
`JUNIPER NETWORKS, INC.,
`
`
`vs.
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`Defendant.
`
`
`
`
`
`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
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10125765
`
`
`- 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 125-1 Filed 06/28/18 Page 2 of 5
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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. (“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 28, 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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` Juniper’s unredacted Opposition to Finjan’s Motion for Summary Judgment of
`Infringement of Claim 10 of U.S. Patent No. 8,677,494 (the “Brief”);
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` Exhibit 2 to the Brief (excerpts from the deposition transcript of Finjan employee John
`Garland);
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` Unredacted Exhibit 3 to the Brief (excerpts from the deposition transcript of Juniper
`employee Yuly Tenorio);
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` Unredacted Exhibit 4 to the Brief (excerpts from the deposition transcript of Finjan’s
`expert Eric B. Cole);
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` Exhibit 7 to the Brief (excerpts from Juniper’s source code);
` Exhibit 8 to the Brief (excerpts from Finjan’s Objections and Responses to Juniper’s First
`Set of Requests for Admission);
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` Exhibit 9 to the Brief (excerpts from Finjan’s Objections and Responses to Juniper’s First
`Set of Interrogatories);
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` Exhibit 10 to the Brief (excerpts from Finjan’s First Supplemental Objections and
`Responses to Juniper’s First Set of Interrogatories);
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` Unredacted Declaration of Rebecca Carson in support of the Brief;
` Unredacted Declaration of Scott J. Coonan in support of the Brief, including Exhibit A
`attached thereto;
`
`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10125765
`
`
`- 2 -
`
`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 125-1 Filed 06/28/18 Page 3 of 5
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` Unredacted Declaration of Chandra Nagarajan in support of the Brief;
` Unredacted Declaration of Aviel D. Rubin in support of the Brief.
`3.
`The sealed portions of the documents described above that Juniper seeks to file
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`under seal contain confidential information of Juniper and Finjan. In this declaration, I explain
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`why these materials are sealable pursuant to Civil Local Rule 79-5.
`4.
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`Exhibit 2 to the Brief are excerpts of the deposition transcript of Finjan employee
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`John Garland that have been designated confidential by Finjan.
`5.
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`The redacted portions of Exhibit 3 to the Brief are excerpts of the deposition
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`transcript of Juniper employee Yuly Tenorio that include discussion of Juniper’s confidential
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`technical information related to Juniper’s highly proprietary software.
`6.
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`The redacted portions of Exhibit 4 to the Brief are excerpts of the deposition
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`transcript of Finjan’s expert Eric B. Cole that include discussion of Juniper’s confidential
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`technical information related to Juniper’s highly proprietary software.
`7.
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`Exhibit 7 to the Brief are excerpts from Juniper’s source code that include Juniper’s
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`confidential technical information related to Juniper’s highly proprietary software.
`8.
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`Exhibit 8 to the Brief are excerpts from Finjan’s Objections and Responses to
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`Juniper’s First Set of Requests for Admission that have been designated confidential by Finjan.
`9.
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`Exhibit 9 to the Brief are excerpts from Finjan’s Objections and Responses to
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`Juniper’s First Set of Interrogatories that have been designated confidential by Finjan.
`10.
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`Exhibit 10 to the Brief are excerpts from Finjan’s First Supplemental Objections
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`and Responses to Juniper’s First Set of Interrogatories that have been designated confidential by
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`Finjan.
`11.
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`The redacted portion of the Declaration of Rebecca Carson in support of the Brief
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`includes discussion of Juniper’s confidential financial information related to Juniper’s highly
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`proprietary software.
`12.
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`The redacted portions of the Declaration of Scott J. Coonan in support of the Brief,
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`including Exhibit A attached thereto, include discussion of Juniper and Finjan’s confidential
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`licensing and settlement negotiations.
`
`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10125765
`
`
`- 3 -
`
`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 125-1 Filed 06/28/18 Page 4 of 5
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`13.
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`The redacted portions of the Declaration of Chandra Nagarajan in support of the
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`Brief include discussion of Juniper’s confidential technical and financial information related to
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`Juniper’s highly proprietary software.
`14.
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`The redacted portions of the Declaration of Aviel D. Rubin in support of the Brief
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`include discussion of Juniper’s confidential technical information related to Juniper’s highly
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`proprietary software.
`15.
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`The redacted portions of the Brief directly reference the confidential materials
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`discussed above. The redacted portions of the Brief at 16:7-17:1 and 20:14-16 have been
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`designated confidential by Finjan. All other redacted portions of the Brief include discussion of
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`Juniper’s confidential technical and financial information related to Juniper’s highly proprietary
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`software, or Juniper’s confidential licensing and settlement negotiations with Finjan.
`16.
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`The redacted portions of Exhibits 3 and 4; Exhibit 7; the redacted portions of the
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`Declarations of Rebecca Carson, Chandra Nagarajan, and Aviel D. Rubin; and the redacted
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`portions of the Brief (excluding the redactions at 16:7-17:1 and 19:16-21:28) contain sealable
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`confidential information that relate to the technical underpinnings and development of Juniper’s
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`highly proprietary software—which includes much information that Juniper maintains as trade
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`secrets. Juniper expends significant effort in maintaining the secrecy of its software architecture
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`and development, including, for example, implementing strict screening procedures for visitors to
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`its engineering campus. Public disclosure of essential nonpublic facts about Juniper’s software
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`development could materially impair Juniper’s intellectual property rights and could cause serious
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`competitive consequences to Juniper’s business positioning.
`17.
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`The redacted portions of the Declaration of Scott J. Coonan and the redacted
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`portions of the Brief at 19:16-20:10 and 20:16-21:28 contain sealable confidential information that
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`relate to Juniper and Finjan’s confidential licensing and settlement negotiations that both parties
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`regularly treat as highly confidential within their businesses and make substantial efforts not to
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`disclose to the public.
`18.
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`Exhibits 2 and 8-10; and the redacted portions of the Brief at 16:7-17:1 and 20:14-
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`16 were designated confidential by Finjan.
`
`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10125765
`
`
`- 4 -
`
`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 125-1 Filed 06/28/18 Page 5 of 5
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`19.
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`For these reasons, the documents described above should be filed under seal.
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`Executed on June 28, 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
`
`10125765
`
`
`- 5 -
`
`DECLARATION OF SHARON SONG ISO JUNIPER’S
`MOTION FOR ADMINISTRATIVE RELIEF
`TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`