Case 3:17-cv-05659-WHA Document 140 Filed 07/03/18 Page 1 of 3
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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.
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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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`FINJAN, INC.,
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`Plaintiff,
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`JUNIPER NETWORKS, INC.,
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`vs.
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`Defendant.
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`Case No. 3:17-cv-05659-WHA
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`DECLARATION OF SHARON SONG ON
`BEHALF OF DEFENDANT JUNIPER
`NETWORKS, INC. IN SUPPORT OF
`FINJAN, INC.’S ADMINISTRATIVE
`MOTION TO FILE DOCUMENTS
`UNDER SEAL (DKT. NO. 132)
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`Judge: Hon. William Alsup
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10088699
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`- 1 -
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`DECLARATION OF SHARON SONG ON BEHALF OF
`DEFENDANT JUNIPER ISO FINJAN’S ADMINISTRATIVE
`MOTION TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`

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`Case 3:17-cv-05659-WHA Document 140 Filed 07/03/18 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. (“Juniper”) in the above-captioned action. I am a member in good standing
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`of the State Bar of California and have been admitted to practice before this Court. I have
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`personal knowledge of the facts set forth in this Declaration and, if called as a witness, could and
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`would testify competently to such facts under oath.
`2.
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`I submit this declaration in support of Finjan, Inc.’s (“Finjan”) Administrative
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`Motion to File Documents Under Seal (Dkt. No. 132), which moves the Court for an order to file
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`under seal the following items related to Juniper’s confidential information:
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` Exhibit 1 to the Declaration of Kristopher Kastens in Support of Finjan’s Reply In
`Support of Its Motion for Leave to File Second Amended Complaint (“Kastens
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`Reply Decl.”);
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` Exhibit 2 to the Kastens Reply Decl.; and
` Exhibit 3 to the Kastens Reply Decl.
`In this declaration, I explain why the material cited above is sealable pursuant to Civil Local Rule
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`79-5 and provide additional facts in support of Finjan’s Administrative Motion to File Documents
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`Under Seal to the extent that the administrative motion pertains to Juniper.
`3.
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`Exhibits 1 and 2 to the Kastens Reply Decl. described above contain highly
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`confidential information produced by Juniper to Finjan. This information has never been made
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`public and is related to the technical underpinnings and development of Juniper’s highly
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`proprietary software—which includes much information that Juniper maintains as trade secrets.
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`Juniper expends significant effort in maintaining the secrecy of its software architecture and
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`development, including, for example, implementing strict screening procedures for visitors to its
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`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.
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10088699
`
`
`- 2 -
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`DECLARATION OF SHARON SONG ON BEHALF OF
`DEFENDANT JUNIPER ISO FINJAN’S ADMINISTRATIVE
`MOTION TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`

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`Case 3:17-cv-05659-WHA Document 140 Filed 07/03/18 Page 3 of 3
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`4.
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`Exhibit 3 to the Kastens Reply Decl. described above is comprised of excerpts from
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`the deposition transcript of Raju Manthena as Juniper’s corporate designee pursuant to a subpoena
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`served on Juniper by Finjan. The transcript reflects substantive discussion of the technical
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`underpinnings and development of Juniper’s highly proprietary software—which contains much
`
`information that Juniper maintains as trade secrets. Juniper expends significant effort in
`
`maintaining the secrecy of its software architecture and development, including, for example,
`
`implementing strict screening procedures for visitors to its engineering campus. Public disclosure
`
`of essential nonpublic facts about Juniper’s software development could materially impair
`
`Juniper’s intellectual property rights and could cause serious competitive consequences to
`
`Juniper’s business positioning.
`5.
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`In light of the foregoing, there are compelling reasons to seal the documents
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`described above.
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`Executed on July 3, 2018 in 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
`
`10088699
`
`
`- 3 -
`
`DECLARATION OF SHARON SONG ON BEHALF OF
`DEFENDANT JUNIPER ISO FINJAN’S ADMINISTRATIVE
`MOTION TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`