Case 3:17-cv-05659-WHA Document 254-1 Filed 11/27/18 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 AUSTIN MANES IN
`SUPPORT OF PLAINTIFF FINJAN, INC.’S
`ADMINISTRATIVE MOTION TO FILE
`DOCUMENTS UNDER SEAL
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`MANES 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 254-1 Filed 11/27/18 Page 2 of 4
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`I, Austin Manes, 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 Motions in Limine Nos. 1-4 and Oppositions thereto, pursuant to Civil
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`Local Rules 79-5(d)-(e).
`3.
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`I have reviewed the following documents and confirmed with counsel for Juniper that
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`they should be sealed pursuant to the stipulated protective order in this litigation. Finjan relies on
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`Juniper’s confidentiality designations.
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`Identification of Documents to be Sealed
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`Entity that Designated the
`Information to be
`Confidential
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`Juniper
`Juniper
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`Finjan’s Motion in Limine (“MIL”) No. 1 in its entirety
`Exhibits 3, 4, 11, 13-15, 17 to Declaration of Kristopher
`Kastens in Support of Finjan’s Motions in Limine Nos. 1-4
`(“Kastens Declaration”) in their entirety
`Exhibit 6 to Kastens Declaration at ¶¶ 79-90, 93-168
`Juniper’s Opposition to Finjan’s MIL No. 1 at page 2, line 3;
`page 3, lines 8, 9, 13, and 18
`Juniper’s Opposition to Finjan’s MIL No. 4 at page 2, lines 9-
`10
`Exhibit 4 to Declaration of Josh Glucoft in Support of
`Juniper’s Oppositions to Motions in Limine Nos. 1-4
`(“Glucoft Declaration”) at page 1
`Exhibits 5 and 6 to Glucoft Declaration in their entirety
`Exhibit 8 to Glucoft Declaration at ¶¶ 100-101, 139-140, 158-
`59
`Juniper
`Exhibit 9 to Glucoft Declaration at ¶¶ 80-83, 85, 92-94
`4.
`Finjan seeks to seal only those documents and portions of documents that Juniper
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`Juniper
`Juniper
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`Juniper
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`Juniper
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`Juniper
`Juniper
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`identified as containing confidential information pursuant to the Protective Order.
`5.
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`Finjan steeks to seal Finjan’s Motion in Limine No. 1 in its entirety as these portions
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`contain information that Juniper has designated as “Highly Confidential – Attorneys’ Eyes Only.”
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`Finjan relies on Juniper’s representations and confidentiality designations.
`6.
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`Finjan seeks to seal Exhibits 3, 4, 11, 13-15, 17 to the Kastens Declaration because these
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`MANES DECL. IN SUPPORT OF FINJAN’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
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`Case 3:17-cv-05659-WHA Document 254-1 Filed 11/27/18 Page 3 of 4
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`documents contain information that Juniper has designated as “Highly Confidential – Attorneys’ Eyes
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`Only.” Finjan relies on Juniper’s representations and confidentiality designations.
`7.
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`Finjan seeks to seal Exhibit 6 to the Kastens Declaration at ¶¶ 79-90, and 93-168 because
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`these portions contain information that Juniper has designated as “Highly Confidential – Attorneys’ Eyes
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`Only.” Finjan relies on Juniper’s representations and confidentiality designations.
`8.
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`Finjan seeks to seal Juniper’s Opposition to Finjan’s Motion in Limine No. 1 at page 2,
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`line 3; page 3, lines 8, 9, 13, and 18 as these portions contain information that Juniper has designated as
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`“Highly Confidential – Attorneys’ Eyes Only.” Finjan relies on Juniper’s representations and
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`confidentiality designations.
`9.
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`Finjan seeks to seal Juniper’s Opposition to Finjan’s Motion in Limine No. 4 at page 2,
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`lines 9-10 as these portions contain information that Juniper has designated as “Highly Confidential –
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`Attorneys’ Eyes Only.” Finjan relies on Juniper’s representations and confidentiality designations.
`10.
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`Finjan seeks to seal Exhibit 4 to the Glucoft Declaration at page 1 as these portions
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`contain information that Juniper has designated as “Highly Confidential – Attorneys’ Eyes Only.”
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`Finjan relies on Juniper’s representations and confidentiality designations.
`11.
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`Finjan seeks to seal Exhibit 5 and 6 to the Glucoft Declaration because these documents
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`contain information that Juniper has designated as “Highly Confidential – Attorneys’ Eyes Only.”
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`Finjan relies on Juniper’s representations and confidentiality designations.
`12.
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`Finjan seeks to seal Exhibit 8 to Glucoft Declaration at ¶¶ 100-101, 139-140, 158-59 as
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`these portions contain information that Juniper has designated as “Highly Confidential – Attorneys’ Eyes
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`Only.” Finjan relies on Juniper’s representations and confidentiality designations.
`13.
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`Finjan seeks to seal Exhibit 9 to Glucoft Declaration at ¶¶ 80-83, 85, 92-94 as these
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`portions contain information that Juniper has designated as “Highly Confidential – Attorneys’ Eyes
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`Only.” Finjan relies on Juniper’s representations and confidentiality designations.
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`MANES DECL. IN SUPPORT OF FINJAN’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
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`Case 3:17-cv-05659-WHA Document 254-1 Filed 11/27/18 Page 4 of 4
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`I 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 27, 2018, in Menlo Park, California.
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`By: /s/ Austin Manes
`Austin Manes
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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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`MANES DECL. IN SUPPORT OF FINJAN’S
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
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