Case 3:17-cv-05659-WHA Document 198 Filed 10/04/18 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
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`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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`Case No. 3:17-cv-05659-WHA
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`DEFENDANT JUNIPER NETWORKS,
`INC.’S MOTION FOR
`ADMINISTRATIVE RELIEF TO FILE
`DOCUMENTS UNDER SEAL
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`Judge: Hon. William Alsup
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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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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10544294
`
`
`
`
`JUNIPER’S MOTION FOR ADMINISTRATIVE RELIEF TO
`FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`

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`Case 3:17-cv-05659-WHA Document 198 Filed 10/04/18 Page 2 of 3
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`NOTICE OF MOTION AND MOTION
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`TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
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`PLEASE TAKE NOTICE THAT pursuant to Federal Rule of Civil Procedure 5.2(d) and
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`Civil Local Rules 7-11 and 79-5, Defendant Juniper Networks, Inc. (“Juniper”) respectfully moves
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`the Court for an Order instructing the Clerk of the Court to file under seal the following
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`documents:
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` Juniper’s unredacted discovery letter brief requesting that the Court issue an Order
`amending the Stipulated Protective Order, Dkt. No. 149 (the “Brief”); and
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` Exhibit 1 to the Brief (excerpts from Finjan’s First Supplemental Objections and
`Responses to Juniper’s First Set of Interrogatories).
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`This motion is based upon this Notice of Motion; the accompanying Memorandum of Points and
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`Authorities; the Declaration of Sharon Song (the “Sealing Declaration”); such other evidence and
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`arguments as the Court may consider; and all other matters of which the Court may take judicial
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`notice.
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`MEMORANDUM OF POINTS AND AUTHORITIES
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`Pursuant to Federal Rule of Civil Procedure 5.2(d) and Civil Local Rules 7-11 and 79-5,
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`Juniper hereby submits a request for an Order instructing the Clerk of the Court to file under seal
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`the unredacted documents described above.
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`Exhibit 1 to the Brief are excerpts of Finjan’s First Supplemental Objections and
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`Responses to Juniper’s First Set of Interrogatories that have been designated confidential by
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`Finjan. Juniper has challenged Finjan’s designation as being improper under the terms of the
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`Protective Order, as the responses do not contain “extremely sensitive ‘Confidential Information
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`or Items,’ disclosure of which to another Party or Non-Party would create a substantial risk of
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`serious harm that could not be avoided by less restrictive means.” See Dkt. No. 149 at 2 (Section
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`2.8). Further, the responses include “non-technical, purely financial or license information” that,
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`according to the Protective Order, is not properly designated as “Highly Confidential – Attorneys’
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`Eyes Only.” Id. As of the date of this letter, however, Finjan has refused to meet and confer with
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`Juniper on this issue. Thus, given that Juniper’s challenge to Finjan’s confidentiality designation
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10544294
`
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`- 1 -
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`JUNIPER’S MOTION FOR ADMINISTRATIVE RELIEF TO
`FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
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`

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`Case 3:17-cv-05659-WHA Document 198 Filed 10/04/18 Page 3 of 3
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`of Exhibit 1 is in progress yet not complete, Juniper seeks to respect the current confidential
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`designation by Finjan out of an abundance of caution but does not support it.
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`The redacted portions of the Brief reference or quote Exhibit 1.
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`This request is narrowly tailored to seal only that material for which compelling reasons to
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`seal have been established. The bases for this request are set forth in further detail in the
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`accompanying Sealing Declaration. On these grounds, Juniper respectfully requests that the Court
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`order sealed the documents described above.
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`Dated: October 4, 2018
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`Respectfully submitted,
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`IRELL & MANELLA LLP
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`By:
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` /s/ Sharon Song
`Sharon Song
`Attorneys for Defendant
`Juniper Networks, Inc.
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10544294
`
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`- 2 -
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`JUNIPER’S MOTION FOR ADMINISTRATIVE RELIEF TO
`FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
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