`
`
`
`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 CRISTINA
`MARTINEZ IN SUPPORT OF
`DEFENDANT JUNIPER NETWORKS,
`INC.’S ADMINISTRATIVE MOTION TO
`FILE DOCUMENTS UNDER SEAL (DKT.
`NO. 246)
`
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`MARTINEZ 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 253 Filed 11/27/18 Page 2 of 3
`
`
`
`I, Cristina Martinez, 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 Juniper’s Administrative Motion to Seal its Reply
`
`in Support of Juniper’s Motion to Exclude Opinions of Damages Expert Mr. Kevin M. Arst and Exhibits
`
`1-3 thereto (Dkt. No. 246).
`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 Reply in Support of Juniper’s Motion to Exclude
`Opinions of Damages Expert Mr. Kevin M. Arst (“Juniper
`Reply”) at page 5, ll.5-7
`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 Reply 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.
`6.
`
`The remaining portions of Juniper’s Reply and Exhibits 1-3 thereto contain Juniper’s
`
`confidential financial, licensing, and/or technical information.
`
`///
`
`///
`
`///
`
`
`
`1
`MARTINEZ DECL. IN SUPPORT OF JUNIPER’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
`
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`Case 3:17-cv-05659-WHA Document 253 Filed 11/27/18 Page 3 of 3
`
`
`
`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 27, 2018, in New York, New York.
`
`
`
`
`
`
`
`
`
`By: /s/ Cristina Martinez
`Cristina Martinez
`
`ATTESTATION
`
`Pursuant to Civil Local Rule 5-1(i), the filer attests that concurrence in the filing of this
`
`document has been obtained from the signatories above.
`
`
`
`/s/ Kristopher Kastens
`Kristopher Kastens
`
`
`
`2
`MARTINEZ DECL. IN SUPPORT OF JUNIPER’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
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`
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