`
`
`
`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
`AUSTIN MANES (State Bar No. 284065)
`amanes@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 (Dkt. 198)
`
`
`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
`
`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 204 Filed 10/08/18 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”) Motion for Administrative Relief to File Documents Under Seal (Dkt. No. 198).
`2.
`
`I have reviewed the documents Juniper sought to file under seal and confirmed that they
`
`contain information Finjan maintains as confidential, as described below.
`3.
`
`The highlighted portions of Juniper’s unredacted discovery letter brief requesting that
`
`the Court issue an Order amending the Stipulated Protective Order (Dkt. No. 149), and Exhibit 1
`
`attached thereto (consisting of an excerpt from Finjan’s First Supplemental Objections and Responses
`
`to Juniper’s First Set of Interrogatories) both describe Finjan’s confidential licensing practices and
`
`license agreements with third-parties. Finjan treats its licenses and licensing practices as highly
`
`confidential within its business and makes substantial efforts not to disclose the terms of its licenses or
`
`licensing practices to the public. If such provisions were made public, it could negatively impact
`
`Finjan’s bargaining positions in future licensing negotiations with competitors. Further, these licenses
`
`themselves contain confidentiality provisions to protect the confidential information of third-party
`
`licensees. Finally, no public interest will be served by disclosing this information publicly.
`4.
`
`In light of the foregoing, compelling reasons exist to seal the documents described
`
`above.
`
`
`I declare under penalty of perjury under the laws of the United States that the foregoing is true
`
`and correct. Executed on October 8, 2018, in Menlo Park, California.
`
`
`
`
`
`
`
`
`
`
`
`
` /s/ Austin Manes
` Austin Manes
`
`
`
`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
`
`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
