`
`
`
`PAUL J. ANDRE (State Bar No. 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (State Bar No. 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (State Bar No. 237978)
`jhannah@kramerlevin.com
`KRISTOPHER KASTENS (State Bar No. 254797)
`kkastens@kramerlevin.com
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`SAN FRANCISCO DIVISION
`
`FINJAN, INC., a Delaware Corporation,
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
`
`
`
`
`
`
`Defendant.
`
`
`Case No.: 3:17-cv-05659-WHA
`
`DECLARATION OF KRISTOPHER
`KASTENS IN SUPPORT OF PLAINTIFF
`FINJAN, INC.’S ADMINISTRATIVE
`MOTION TO FILE DOCUMENTS UNDER
`SEAL
`
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`KASTENS DECL. IN SUPPORT OF FINJAN’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
`
`
`
`Case 3:17-cv-05659-WHA Document 132-1 Filed 06/29/18 Page 2 of 3
`
`
`
`I, Kristopher Kastens, declare:
`1.
`I have personal knowledge of the facts stated herein.
`2.
`
`I am licensed to practice law in the State of California and am an attorney at Kramer
`
`Levin Naftalis & Frankel LLP, counsel of record for Finjan, Inc. (“Finjan”). I make this declaration in
`
`support of Finjan’s Administrative Motion to File Documents Under Seal in connection with its Reply in
`
`Support of Its Motion for Leave to File Second Amended Complaint, pursuant to Civil Local Rules 79-
`
`5(d)-(e).
`3.
`
`I have reviewed the following documents and confirmed that they are designated as
`
`“Highly Confidential – Attorneys’ Eyes Only” by Juniper Networks, Inc. (“Juniper”). Finjan relies on
`
`Juniper’s confidentiality designations.
`
`
`Identification of Documents to be Sealed
`
`Plaintiff Finjan Inc.’s Reply In Support of Its Motion for
`Leave to File Second Amended Complaint at page 2, lines 2,
`20, 22; page 4, line 18; page 5, lines 4-5
`Declaration of Kristopher Kastens in Support of Finjan’s
`Reply (“Kastens Reply Decl.”), Ex.1
`Kastens Decl., Ex. 2
`Kastens Decl., Ex. 3 (excerpts from deposition transcript of
`Mr. Raju Manthena)
`4.
`Finjan’s Reply in Support of Its Motion for Leave to File Second Amended Complaint
`
`Entity that Designated the
`Information to be
`Confidential
`
`Juniper
`
`Juniper
`
`Juniper
`Juniper
`
`redacted portions at page 2, lines 2, 20, 22; page 4, line 18; page 5, lines 4-5 concern Juniper’s highly
`
`confidential testimony that Juniper has designated as “Highly Confidential – Attorneys’ Eyes Only.”
`
`Finjan relies on Juniper’s representations and confidentiality designations that such information is
`
`confidential and needs to be sealed.
`5.
`
`Exhibits 1, 2, and 3 to the Kastens Declaration contain information that Juniper has
`
`designated as “Highly Confidential – Attorneys’ Eyes Only.” Finjan relies on Juniper’s representation
`
`that such information is confidential and needs to be sealed.
`
`
`
`
`
`
`
`KASTENS DECL. IN SUPPORT OF FINJAN’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
`
`1
`
`CASE NO.: 3:17-cv-05659-WHA
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`
`
`Case 3:17-cv-05659-WHA Document 132-1 Filed 06/29/18 Page 3 of 3
`
`
`
`I declare under penalty of perjury under the laws of the United States of America that each of the
`
`above statements is true and correct. Executed on June 29, 2018, in Menlo Park, California.
`
`
`
`
`
`
`
`By: /s/ Kristopher Kastens
` Kristopher Kastens
`
`
`
`
`
`
`
`
`KASTENS DECL. IN SUPPORT OF FINJAN’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
`
`2
`
`CASE NO.: 3:17-cv-05659-WHA
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
