`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Case 3:17-cv-05659-WHA Document 273-1 Filed 11/27/18 Page 1 of 3
`
`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Joshua Glucoft (SBN 301249)
`jglucoft@irell.com
`Casey Curran (SBN 305210)
`ccurran@irell.com
`Sharon Song (SBN 313535)
`ssong@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`Rebecca Carson (SBN 254105)
`rcarson@irell.com
`Kevin Wang (SBN 318024)
`kwang@irell.com
`840 Newport Center Drive, Suite 400
`Newport Beach, California 92660-6324
`Telephone: (949) 760-0991
`Facsimile: (949) 760-5200
`
`Attorneys for Defendant
`JUNIPER NETWORKS, INC.
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`FINJAN, INC., a Delaware Corporation,
`)
`Case No. 3:17-cv-05659-WHA
`
`)
`
`DECLARATION OF KEVIN WANG IN
`Plaintiff,
`)
`SUPPORT OF DEFENDANT JUNIPER
`
`)
`NETWORKS, INC.’S MOTIONS IN
`vs.
`
`)
`LIMINE NOS. 1-5
`
`)
`JUNIPER NETWORKS, INC., a Delaware
`)
`
`Corporation,
`)
`Date:
`
`December 4, 2018
`
`)
`Time:
`9:00 a.m.
`Courtroom: Courtroom 12, 19th Floor
`)
`Hon. William Alsup
`Before:
`)
`
`
`
`
`Defendant.
`
`
`
`
`
`
`DECLARATION OF KEVIN WANG ISO
`JUNIPER’S MOTIONS IN LIMINE NOS. 1-5
`Case No. 3:17-cv-05659-WHA
`
`
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Case 3:17-cv-05659-WHA Document 273-1 Filed 11/27/18 Page 2 of 3
`
`
`
`DECLARATION OF KEVIN WANG
`I, Kevin Wang, declare as follows:
`1.
`I am a member in good standing of the State Bar of California and an associate at
`Irell & Manella LLP, counsel of record in this action for Defendant Juniper Networks, Inc.
`(“Juniper”). I have personal knowledge of the facts set forth in this declaration, and I could and
`would testify competently thereto if called upon to do so. I make this declaration in support of
`Juniper’s Motions in Limine Nos. 1-5.
`2.
`Attached as Exhibit 1 is a true and correct copy of excerpts from the Expert Report
`of Dr. Eric Cole, dated September 10, 2018.
`3.
`Attached as Exhibit 2 is a true and correct copy of excerpts from the Expert Report
`of Kevin M. Arst, dated September 11, 2018.
`4.
`Attached as Exhibit 3 is a true and correct copy of excerpts from the Expert
`Rebuttal Report of Dr. Alessandro Orso, dated October 11, 2018.
`5.
`Attached as Exhibit 4 is a true and correct copy of excerpts from Appendix C of the
`Expert Rebuttal Report of Dr. Alessandro Orso, dated October 11, 2018.
`6.
`Attached as Exhibit 5 is a true and correct copy of excerpts from the 30(b)(6)
`deposition of John Garland, taken on May 24, 2018.
`7.
`Attached as Exhibit 6 is a true and correct copy of an excerpt from Finjan’s Trial
`Exhibit List, dated November 9, 2018.
`8.
`Attached as Exhibit 7 is a true and correct copy of an excerpt from the Transcript of
`Proceedings on July 5, 2018, in the above captioned matter.
`9.
`Attached as Exhibit 8 is a true and correct copy of an excerpt from Finjan’s Reply
`in Support of Its Motion for Summary Judgment of Infringement of Claim 10 of U.S. Patent No.
`8,677,494, dated July 12, 2018.
`10.
`Attached as Exhibit 9 is a true and correct copy of excerpts from Finjan’s Response
`Letter Brief regarding Motion to Compel, dated July 13, 2018.
`
`
`
`
`
`
`- 1 -
`
`DECLARATION OF KEVIN WANG ISO
`JUNIPER’S MOTIONS IN LIMINE NOS. 1-5
`Case No. 3:17-cv-05659-WHA
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Case 3:17-cv-05659-WHA Document 273-1 Filed 11/27/18 Page 3 of 3
`
`Attached as Exhibit 10 is a true and correct copy of excerpts from the deposition of
`11.
`Julie Mar-Spinola, taken on October 30, 2018.
`12.
`Attached as Exhibit 11 is a true and correct copy of the Declaration of Scott J.
`Coonan in Support of Juniper’s Motion in Limine to Exclude the Recordings of the November 24,
`2015 Call Between the Parties and Any Reference to Who Made the Recording, dated November
`14, 2018.
`Attached as Exhibit 12 is a true and correct copy of excerpts from IPR2015-01892,
`13.
`Patent Owner’s Response.
`Attached as Exhibit 13 is a true and correct copy of an excerpt from IPR2016-
`14.
`00159, Patent Owner’s Response.
`Attached as Exhibit 14 is a true and correct copy of excerpts from the deposition of
`15.
`Dr. Eric B. Cole, taken on June 21, 2018.
`16.
`Attached as Exhibit 15 is a true and correct copy of excerpts from the deposition of
`Dr. Eric. B. Cole, taken on November 14, 2018.
`17.
`Attached as Exhibit 16 is a true and correct copy of excerpts from the deposition of
`Harry Bims, Ph.D., taken on November 7, 2018.
`18.
`Attached as Exhibit 17 is a true and correct copy of excerpts from the deposition of
`Kevin M. Arst, taken on November 9, 2018.
`
`Attached as Exhibit 18 is a true and correct copy of the Memorandum and Order
`19.
`from Orthoarm, Inc. v. Forestadent USA, Inc., et al., Case No. 4:06-CV-730-CAS.
`
`Dated: November 19, 2018
`
`Respectfully submitted,
`IRELL & MANELLA LLP
`
`By: /s/ Kevin Wang
`Kevin Wang (SBN 318024)
`kwang@irell.com
`840 Newport Center Drive, Suite 400
`Newport Beach, California 92660-6324
`Telephone: (949) 760-0991
`Facsimile: (949) 760-5200
`Attorneys for Defendant
`JUNIPER NETWORKS, INC.
`
`- 2 -
`
`DECLARATION OF KEVIN WANG ISO
`JUNIPER’S MOTIONS IN LIMINE NOS. 1-5
`Case No. 3:17-cv-05659-WHA
`
`