`
`
`
`Paul Andre
`Partner
`T 650-752-1700
`F 650-752-1800
`PAndre@KRAMERLEVIN.com
`
`November 9, 2018
`
`
`990 Marsh Road
`Menlo Park, CA 94025-1949
`T 650.752.1700
`F 650.752.1800
`
`Honorable William Alsup
`U.S. District Court, Northern District of California
`San Francisco Courthouse
`Courtroom 12 – 19th Floor
`450 Golden Gate Avenue
`San Francisco, CA 94102
`
`
`
`Re:
`
`Finjan, Inc. v. Juniper Networks, Inc., Case No. 3:17-cv-05659-WHA
`
`Dear Judge Alsup:
`
`Plaintiff Finjan, Inc. (“Finjan”) simply requests the same schedule with the same page
`limits that Juniper Networks, Inc. (“Juniper”) asked for and received for Daubert briefing.
`See Dkts. 215; 221. This schedule was Juniper’s proposal, not Finjan’s, and allowing both
`parties to proceed under it is fair and equitable.
`
`Finjan’s request should not be controversial. Finjan seeks to file a Daubert motion on Dr.
`Rubin’s “damages” rebuttal report because it uses an improper methodology based on
`invalidity arguments that are unsuitable for a damages opinion. Similarly, Finjan seeks to
`file a Daubert motion on Dr. Ugone’s report because it uses an unreliable methodology
`based on unsuitable facts. If Juniper disputes the content of these motions, it will be free
`to oppose them according to the same schedule that the Court granted Finjan. See Dkt.
`215. Thus, Finjan respectfully reiterates its request to file Daubert motions according to
`the same schedule and page limits granted to Juniper.
`
`Respectfully submitted,
`
`Paul Andre
`Counsel for Plaintiff Finjan, Inc.
`
`
`
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`
`
`
`
`
`
` SILICON VALLEY | NEW YORK | PARIS
`
`
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