`Case 3:17-cv-05659-WHA Document 129-26 Filed 06/28/18 Page 1 of 2
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`EXHIBIT 24
`EXHIBIT 24
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`Case 3:17-cv-05659-WHA Document 129-26 Filed 06/28/18 Page 2 of 2
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`From: Kobialka, Lisa
`Sent: Sunday, June 10, 2018 4:02 PM
`To: Glucoft, Josh (JGlucoft@irell.com)
`Cc: Carson, Rebecca (RCarson@irell.com); Kastens, Kris; Andre, Paul; Hannah, James; Lee, Michael H.;
`Manes, Austin; Nguyen, Stephanie
`Subject: RE: Finjan/Juniper
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`Josh,
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`We have received the final transcript of John Garland to the extent you want to discuss his testimony
`further.
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`Separately, I am confirming the concern I raised during our call on Friday, June 8, that Juniper has
`presented an issue regarding when damages can begin on summary judgment for which Juniper has
`failed to produce relevant, responsive discovery. On March 26, Juniper agreed to produce documents
`responsive to Request for Production Nos. 1, 2, and 3, which includes documents and communications
`relating to the Asserted Patents and notice to Juniper about Finjan’s patents, which goes to the damages
`issues raised in Juniper’s summary judgment motion. Scott Coonan and Meredith McKenzie were the
`two individuals that Finjan communicated with for years regarding a license to Finjan’s
`patents. However, as you confirmed, none of Mr. Coonan’s or Ms. McKenzie’s emails have been
`produced. In fact, you stated that Juniper is “taking steps to review the email” of Mr. Coonan and Ms.
`McKenzie. You stated that the holdup was due to Juniper’s concerns about ESI search terms and
`hits. As you well know and acknowledged to me, Judge Alsup’s standing order requires the parties to
`search for relevant, responsive emails and not necessarily wait for search terms to search emails. It is
`unclear at this time what other discovery Juniper has failed to produce in response to Finjan’s discovery
`requests, particularly as it relates to the parties’ summary judgment motions. Given Juniper’s discovery
`failings, Finjan reserves all rights to address this issue and resulting prejudice as appropriate.
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`Very truly yours,
`Lisa
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`From: Glucoft, Josh [mailto:JGlucoft@irell.com]
`Sent: Tuesday, June 05, 2018 2:34 PM
`To: Kobialka, Lisa; Kastens, Kris; Andre, Paul; Hannah, James; Kastens, Kris; Lee, Michael H.; Manes,
`Austin; Nguyen, Stephanie
`Cc: Carson, Rebecca
`Subject: [EXTERNAL] RE: Finjan/Juniper
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`Lisa,
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`I’ll call you then.
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`Thanks,
`Josh
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