Case 3:17-cv-05659-WHA Document 244-1 Filed 11/23/18 Page 1 of 4
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`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
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`Attorneys for Plaintiff
`FINJAN, INC.
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCISCO DIVISION
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`FINJAN, INC., a Delaware Corporation,
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`Plaintiff,
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`v.
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`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
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`Defendant.
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`Case No.: 3:17-cv-05659-WHA
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`DECLARATION OF HANNAH LEE IN
`SUPPORT OF PLAINTIFF FINJAN, INC.’S
`ADMINISTRATIVE MOTION TO FILE
`DOCUMENTS UNDER SEAL
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`LEE DECL. IN SUPPORT OF FINJAN’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
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`CASE NO.: 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 244-1 Filed 11/23/18 Page 2 of 4
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`I, Hannah Lee, declare:
`1.
`2.
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`I have personal knowledge of the facts stated herein.
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`I am an attorney at Kramer Levin Naftalis & Frankel LLP, counsel of record for Finjan,
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`Inc. (“Finjan”). I make this declaration in support of Finjan’s Administrative Motion to File Documents
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`Under Seal in connection with its Reply Brief In Support of Its Motion to Exclude Opinions of Damages
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`Expert Dr. Keith R. Ugone (“Finjan’s Reply”), pursuant to Civil Local Rules 79-5(d)-(e).
`3.
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`I have reviewed the following documents and confirmed that they are designated as
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`“Highly Confidential – Attorneys’ Eyes Only” by Juniper Networks, Inc. (“Juniper”) or Finjan pursuant
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`to the stipulated protective order in this litigation. For certain documents, Finjan relies on Juniper’s
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`confidentiality designations.
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`Identification of Documents to be Sealed
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`Entity that Designated the
`Information to be
`Confidential
`Finjan or Juniper
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`Finjan’s Reply Brief In Support of Its Motion to Exclude
`Opinions of Damages Expert Dr. Keith R. Ugone (“Finjan’s
`Reply”) at page 1, lines 20-21, page 2, line 22, page 3, lines
`15-17, page 4, lines 9-10, 12, page 5, lines 3, 11-12, 16-21,
`page 6, lines 15-17, 23-27, page 7, lines 1-2, 4
`Declaration of Kristopher Kastens in Support of Finjan’s
`Reply (“Kastens Declaration”), Ex. 1
`Finjan
`Kasten Declaration, Ex. 3
`Juniper
`Kastens Declaration Ex. 4
`4.
`This Administrative Motion to File Documents Under Seal should be granted because
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`Finjan or Juniper
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`there are compelling reasons to seal the identified documents. Finjan seeks to seal only those documents
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`and portions of documents that it or Juniper identified as containing confidential information pursuant to
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`the Protective Order.
`5.
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`Finjan seeks to seal Finjan’s Reply at page 2, line 22, page 3, lines 15-17, and page 4,
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`lines 9-10, 12, because these portions contain information that Finjan has designated as “Highly
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`Confidential – Attorneys’ Eyes Only” and concerns its confidential licensing discussions and license
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`agreement with third party subject to a confidentiality agreement. For the remaining redactions, Finjan
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`relies on Juniper’s representations and confidentiality designations that such information is confidential
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`LEE DECL. IN SUPPORT OF FINJAN’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
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`Case 3:17-cv-05659-WHA Document 244-1 Filed 11/23/18 Page 3 of 4
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`and needs to be sealed.
`6.
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`Finjan seeks to seal Exhibit 1 to the Kastens Declaration because this document contains
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`information that Finjan has designated as “Highly Confidential – Attorneys’ Eyes Only.” Specifically,
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`page 170 of this transcript contains information related to a confidential license agreement with a third
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`party that is subject to third-party confidentiality obligations and Finjan maintains as confidential within
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`its business. Public disclosure of this information would prejudice Finjan’s ability to engage in future
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`licensing negotiations and be in violation of its confidentiality obligations to a third party. For the
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`remaining redactions, Finjan relies on Juniper’s representations and confidentiality designations.
`7.
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`Finjan seeks to seal Exhibit 3 to the Kastens Declaration because it contains information
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`that Finjan has designated as “Highly Confidential – Attorneys’ Eyes Only.” It is a confidential license
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`agreement with a third party that is subject to third-party confidentiality obligations and Finjan maintains
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`as confidential within its business. Public disclosure of this information would prejudice Finjan’s ability
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`to engage in future licensing negotiations and be in violation of its confidentiality obligations to a third
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`party.
`8.
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`Finjan seeks to seal Exhibit 4 to the Kastens Declaration because this document contains
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`information that Juniper has designated as “Highly Confidential – Attorneys’ Eyes Only.” Finjan relies
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`on Juniper’s representations and confidentiality designations that such information is confidential and
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`needs to be sealed.
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` I
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` declare under penalty of perjury under the laws of the United States of America that each of the
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`above statements is true and corrected. Executed on November 23, 2018, in San Francisco, California.
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`By: /s/ Hannah Lee
`Hannah Lee
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`LEE DECL. IN SUPPORT OF FINJAN’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
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`Case 3:17-cv-05659-WHA Document 244-1 Filed 11/23/18 Page 4 of 4
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`ATTESTATION
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`Pursuant to Civil Local Rule 5-1(i), the filer attests that concurrence in the filing of this
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`document has been obtained from the signatories above.
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`/s/ Kristopher Kastens
`Kristopher Kastens
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`LEE DECL. IN SUPPORT OF FINJAN’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
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