`
`
`
`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 AUSTIN MANES IN
`SUPPORT OF PLAINTIFF FINJAN, INC.’S
`OPPOSITIONS TO DEFENDANT
`JUNIPER NETWORKS, INC.’S MOTIONS
`IN LIMINE NOS. 4-5
`
`December 4, 2018
`
`Date:
`9:00 a.m.
`Time:
`Courtroom: Courtroom 12, 19th Floor
`Before:
`Hon. William Alsup
`
`
`
`
`
`
`MANES DECL. IN SUPPORT OF FINJAN’S OPP.
`JUNIPER’S MOTIONS IN LIMINE NOS. 4-5
`
` 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 274-3 Filed 11/27/18 Page 2 of 2
`
`
`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
`
`
`
`I, Austin Manes, declare:
`
`1.
`
`I am licensed to practice law in the State of California and am an attorney at Kramer
`
`Levin Naftalis & Frankel LLP, counsel of record for Finjan, Inc. (“Finjan”). I have personal
`
`knowledge of the facts stated herein. I make this declaration in support of Plaintiff Finjan, Inc.’s
`
`Oppositions to Juniper Networks, Inc.’s (“Juniper”) Motions in Limine Nos. 4-5.
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of pages 115-117 from the
`
`transcript of the deposition of Dr. Eric B. Cole, taken on June 21, 2018 in the present action.
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of pages 37-38, 73-74, 148-149,
`
`161-164, and 181-182 from the transcript of the deposition of Dr. Eric B. Cole, taken on November 14,
`
`2018 in the present action.
`
`4.
`
`Attached hereto as Exhibit 3 is a true and correct copy of pages 97-98 from the
`
`transcript of the deposition of Kevin M. Arst, taken on November 9, 2018 n the present action.
`
`5.
`
`Attached hereto as Exhibit 4 is a true and correct copy page 506 from the Dictionary of
`
`Electrical and Computer Engineering, copyright 2003.
`
`6.
`
`Attached hereto as Exhibit 5 is a true and correct copy of page 743 from The American
`
`Heritage Dictionary, Fourth Edition, copyright 2001.
`
`7.
`
`Attached hereto as Exhibit 6 is a true and correct copy of pages 7 and 41 from the Final
`
`Written Decision, Paper No. 58, entered on March 15, 2017 by the Patent Trial and Appeal Board in
`
`Symantec Corp. v. Finjan, Inc., IPR2015-01892.
`
`8.
`Construction and Pre-Hearing Statement Pursuant to Patent Local Rule 4-3 from Finjan, Inc. v. Blue
`
`Attached hereto as Exhibit 7 is a true and correct copy of page 2 from the Joint Claim
`
`Coat Systems, Inc., Case No. 15-cv-03295-BLF (N.D. Cal. Aug. 12, 2016).
`
`
`I declare under penalty of perjury under the laws of the United States of America that each
`
`of the above statements is true and correct. Executed on November 26, 2018, in Menlo Park, CA.
`
`
`
`
`
`/s/ Austin Manes
`Austin Manes
`
`
`
`
`
`1
`MANES DECL. IN SUPPORT OF FINJAN’S OPP.
`JUNIPER’S MOTIONS IN LIMINE NOS. 4-5
`
` CASE NO.: 3:17-cv-05659-WHA
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
