`
`
`
`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
`
`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 HANNAH LEE IN
`SUPPORT OF DEFENDANT JUNIPER
`NETWORKS, INC.’S ADMINISTRATIVE
`MOTION TO FILE DOCUMENTS UNDER
`SEAL (DKT. NO. 236)
`
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`LEE DECL. IN SUPPORT OF JUNIPER’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
`
`
`
`Case 3:17-cv-05659-WHA Document 248 Filed 11/23/18 Page 2 of 2
`
`
`
`I, Hannah Lee, declare:
`1.
`2.
`
`I have personal knowledge of the facts stated herein.
`
`I am an attorney at Kramer Levin Naftalis & Frankel LLP, counsel of record for Finjan,
`
`Inc. (“Finjan”). I make this declaration in support of Finjan’s Administrative Motion to File Documents
`
`Under Seal in connection with Juniper’s Administrative Motion to Seal its Opposition to Finjan’s
`
`Motion to Exclude Opinions of Damages Expert Dr. Keith R. Ugone (Dkt. No. 236).
`3.
`
`I have reviewed the following documents and confirmed that they are designated as
`
`“Highly Confidential – Attorneys’ Eyes Only” by Finjan and contain Finjan’s confidential information
`
`pursuant to the stipulated protective order in this litigation.
`
`
`
`Identification of Documents to be Sealed
`
`Entity that Designated the
`Information to be
`Confidential
`
`Juniper’s Opposition to Finjan’s Motion to Exclude Opinions
`of Damages Expert Dr. Keith R. Ugone (“Juniper
`Opposition”) at page 2, ll. 19, 21, page 13, ll. 7-8, 19-21, 23-
`25, 28, page 14, ll.1-2, 5-6
`4.
`There are compelling reasons to seal the above-identified portions. Finjan seeks to seal
`
`Finjan
`
`only those portions that it identified as containing confidential information pursuant to the Protective
`
`Order and the Local Rules.
`5.
`
`The above-identified portions of Juniper’s Opposition concern confidential business
`
`information regarding Finjan’s licensing negotiations and license agreements with third parties subject to
`
`confidentiality agreements. Finjan maintains such information as confidential within its ordinary course
`
`of business. Public disclosure of this information would prejudice Finjan’s ability to engage in future
`
`licensing negotiations and be in violation of its confidentiality obligations to third parties.
`
`I declare under penalty of perjury under the laws of the United States of America that each of the
`
`above statements is true and corrected. Executed on November 23, 2018, in San Francisco, California.
`
`
`
`
`By: /s/ Hannah Lee
`Hannah Lee
`
`
`
`
`
`
`
`
`
`
`
`LEE DECL. IN SUPPORT OF JUNIPER’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
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