`
`
`
`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 FINJAN, INC.’S LETTER
`BRIEF FILED IN OPPOSITION TO
`JUNIPER NETWORKS, INC.’S MOTION
`TO AMEND THE PROTECTIVE ORDER
`(Dkt. 199)
`
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`DECL. OF A. MANES IN SUPPORT OF FINJAN’S OPPOSITION CASE NO.: 3:17-cv-05659-WHA
`TO JUNIPER’S MOTN. TO AMEND THE PROTECTIVE ORDER
`
`
`
`
`Case 3:17-cv-05659-WHA Document 205-1 Filed 10/09/18 Page 2 of 2
`
`
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`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 letter brief filed in Opposition
`
`to Defendant Juniper Networks, Inc.’s (“Juniper”) Motion to Amend the Protective Order (Dkt. No. 199)
`
`(“Juniper’s Motion”).
`
`2.
`
`Finjan actively protects information regarding its licensing practices and licensing
`
`negotiations as confidential and believes that disclosure of this information will harm its business.
`
`3.
`
`Exhibit 1 attached to Juniper’s Motion contains confidential information regarding
`
`Finjan’s licensing practices and licensing negotiations, including at page 5 lines 16-19 and 26-27, and at
`
`page 6 lines 1-6. Exhibit 1 also contains a quote from many of Finjan’s confidential licenses at page 5
`
`lines 17-19 and describes the terms of a license at page 6 lines 3-6.
`
`4.
`
`Most, if not all, of the licenses described and cited in Exhibit 1 contain confidentiality
`
`provisions that prohibit Finjan from disclosing the terms of the license or the underlying negotiations
`
`except in certain circumstances required by law and under appropriate confidentiality designations.
`
`5.
`
`Attached hereto as Exhibit A is a true and correct copy of the order issued in Jazz
`
`Pharmaceuticals, Inc. v. Amneal Pharmaceuticals, LLC, No. 13-cv-00391-ES-JAD (N.J.D.) on January
`
`22, 2016, ECF No. 211.
`
`
`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
`
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`1
`DECL. OF A. MANES IN SUPPORT OF FINJAN’S OPPOSITION CASE NO.: 3:17-cv-05659-WHA
`TO JUNIPER’S MOTN. TO AMEND THE PROTECTIVE ORDER
`
`
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