`
`
`
`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 PLAINTIFF FINJAN, INC.’S
`ADMINISTRATIVE MOTION TO FILE
`DOCUMENTS UNDER SEAL
`
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`DECLARATION OF A. MANES 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 153-1 Filed 07/12/18 Page 2 of 3
`
`
`
`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 Finjan’s Administrative Motion to File
`
`Documents Under Seal.
`
`2.
`
`I have reviewed the following documents and confirmed that they contain information
`
`designated as “Confidential,” “Highly Confidential – Attorneys’ Eyes Only,” or “Highly
`
`Confidential – Source Code” by Juniper:
`
`Documents sought to be sealed
`
`Plaintiff Finjan Inc.’s Reply in Support of Its
`Motion for Summary Judgment of
`Infringement of Claim 10 of U.S. Patent No.
`8,677,494 (“Finjan’s Reply”)
`
`Declaration of Kristopher Kastens in Support
`of Finjan’s Reply to Its Motion for Summary
`Judgment (“Kastens Decl.”)
`Exhibits 4-6, 8, 11 and 13 to the Kastens
`Decl.
`
`
`
`Portions sought to be
`sealed
`Highlighted portions at
`Table of Contents, ll. 17-
`19; page 2, ll. 14-16; page
`6, ll. 21, 23-24; page 7, ll.
`1-6, 8-9, 11, 20; page 9, ll.
`1-9, 17-28; page 10, ll. 1,
`7-23; page 10, ll. 1-6, 8-
`28; page 11, ll. 1-7, 13-
`19; page 14, ll. 14-16.
`Page 1, l. 21; page 2, l. 2.
`
`Entirety
`
`Designating
`party
`Juniper
`
`Juniper
`
`Juniper
`
`3.
`
`The highlighted portions of Finjan’s Reply contain information designated as
`
`“Confidential,” “Highly Confidential – Attorneys’ Eyes Only,” or “Highly Confidential – Source
`
`Code” by Juniper.
`
`4.
`
`The Kastens Decl. contain information designated as “Confidential,” “Highly
`
`Confidential – Attorneys’ Eyes Only,” or “Highly Confidential – Source Code” by Juniper.
`
`5.
`
`Exhibits 4-6, 8, 11 and 13 to the Kastens Decl. contain information designated as
`
`“Confidential,” “Highly Confidential – Attorneys’ Eyes Only,” or “Highly Confidential – Source
`
`Code” by Juniper.
`
`1
`DECLARATION OF A. MANES IN SUPPORT OF FINJAN’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 153-1 Filed 07/12/18 Page 3 of 3
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`
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`I declare under penalty of perjury under the laws of the United States that the foregoing is true and
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`correct. Executed on July 12, 2018 in Menlo Park, California.
`
`
`
` /s/ Austin Manes
` Austin Manes
`
`
`
`
`
`
`
`
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`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
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`document has been obtained from any other signatory to this document.
`
`
`
`/s/ Kristopher Kastens
`Kristopher Kastens
`
`
`
`2
`DECLARATION OF A. MANES IN SUPPORT OF FINJAN’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
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