`
`
`
`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 AUSTIN MANES IN
`SUPPORT OF JUNIPER NETWORKS,
`INC.’S MOTION FOR ADMINISTRATIVE
`RELIEF TO FILE DOCUMENTS UNDER
`SEAL
`
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`DECL. OF A. MANES IN SUPPORT OF JUNIPER’S MTN.
`FOR ADMIN. RELIEF TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
`
`
`
`
`Case 3:17-cv-05659-WHA Document 138 Filed 07/02/18 Page 2 of 2
`
`
`
`I, Austin Manes, declare and state as follows:
`
`1.
`
`I am an attorney with the law firm Kramer Levin Naftalis & Frankel LLP, counsel for
`
`Plaintiff Finjan, Inc. (“Finjan”). I have personal knowledge of the facts stated herein and can testify
`
`competently to those facts. I make this declaration in support of Defendant Juniper Networks, Inc.’s
`
`(“Juniper”) Administrative Relief to File Documents Under Seal (Dkt. No. 125).
`
`2.
`
`I have reviewed the documents Juniper sought to file under seal and confirmed certain of
`
`those documents contain information Finjan’s third party licensees treat confidential as described below.
`
`3.
`
`The highlighted portions of the Defendant Juniper’s Opposition to Finjan’s Motion for
`
`Summary Judgment (“Opposition”) at 16: 7-16, 21-28, 17: 1 contain confidential terms in
`
`license/settlement agreements between Finjan and Finjan’s third party licensees that Finjan’s third party
`
`licensees require Finjan to maintain confidential.
`
`4.
`
`The Exhibit 2, 8 and 10 to the Declaration of Rebecca Carson in support of the
`
`Opposition contain discussion of confidential terms in license/settlement agreements between Finjan and
`
`Finjan’s third party licensees that Finjan’s third party licensees require Finjan to maintain confidential.
`
`
`I declare under penalty of perjury under the laws of the United States that the foregoing is true and
`
`correct. Executed on July 2, 2018 in Menlo Park, California.
`
`
`
`
`
`
`
` /s/ Austin Manes
` Austin Manes
`
`
`
`
`
`
`
`
`
`
`
`
`ATTESTATION PURSUANT TO L.R. 5-1(I)
`
`In accordance with Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this
`
`document has been obtained from any other signatory to this document.
`
`
`
`/s/ Kristopher Kastens
`Kristopher Kastens
`
`
`
`1
`DECL. OF A. MANES IN SUPPORT OF JUNIPER’S MTN.
`FOR ADMIN. RELIEF TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
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