Case 3:17-cv-05659-WHA Document 278 Filed 11/28/18 Page 1 of 4
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`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Joshua P. 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 L. 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
`)
`Case No. 3:17-cv-05659-WHA
`)
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`DECLARATION OF SHARON SONG ON
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`BEHALF OF DEFENDANT JUNIPER
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`NETWORKS, INC. IN SUPPORT OF
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`FINJAN, INC.’S ADMINISTRATIVE
`)
`MOTION TO FILE DOCUMENTS
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`UNDER SEAL (DKT. NO. 244)
`)
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`FINJAN, INC.,
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`Plaintiff,
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`vs.
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`JUNIPER NETWORKS, INC.,
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`Defendant.
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`L & MANELLA LLP
`stered Limited Liability
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`10125765
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`DECLARATION OF SHARON SONG ISO
`FINJAN’S ADMINISTRATIVE MOTION TO
` FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
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`Case 3:17-cv-05659-WHA Document 278 Filed 11/28/18 Page 2 of 4
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`DECLARATION OF SHARON SONG
`I, Sharon Song, declare as follows:
`1.
`I am an attorney at the law firm of Irell & Manella LLP, counsel of record for
`Juniper Networks, Inc. (“Juniper”) in the above-captioned matter. I am a member in good
`standing of the State Bar of California and have been admitted to practice before this Court. I
`have personal knowledge of the facts set forth in this Declaration and, if called as a witness, could
`and would testify competently to such facts under oath.
`2.
`I submit this declaration in support of Finjan, Inc.’s (“Finjan”) Administrative
`Motion to File Documents Under Seal (Dkt. No. 244), which moves the Court for an order to file
`under seal the following items related to Juniper:
`• Select portions of pages 1-7 of Finjan’s Reply Brief In Support of Its Motion to
`Exclude Opinions of Damages Expert Dr. Keith R. Ugone (“Finjan’s Reply”); and
`• Exhibits 1 and 4 to the Declaration of Kristopher Kastens in Support of Finjan’s
`Reply (“Kastens Decl.”).
`In this declaration, I explain why the material cited above is sealable pursuant to Civil Local Rule
`79-5 and provide additional facts in support of Finjan’s Administrative Motion to File Documents
`Under Seal to the extent that the administrative motion pertains to Juniper.
`1.
`Exhibit 1 to the Kastens Decl. described above is comprised of excerpts from the
`deposition transcript of Juniper’s damages expert Dr. Keith R. Ugone. These excerpts contain
`sealable confidential information that relate to the financial information concerning and the
`technical underpinnings and development of Juniper’s highly proprietary software—which
`includes much information that Juniper maintains as trade secrets. Juniper expends significant
`effort in maintaining the secrecy of its software architecture and development, including, for
`example, implementing strict screening procedures for visitors to its engineering campus. Public
`disclosure of essential nonpublic facts about Juniper’s software development could materially
`impair Juniper’s intellectual property rights and could cause serious competitive consequences to
`Juniper’s business positioning. Exhibit 1 also contains sealable confidential information that
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
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`10125765
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`- 1 -
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`DECLARATION OF SHARON SONG ISO
`FINJAN’S ADMINISTRATIVE MOTION TO
` FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`

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`Case 3:17-cv-05659-WHA Document 278 Filed 11/28/18 Page 3 of 4
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`relate to Juniper’s confidential licensing information that Juniper regularly treats as highly
`confidential within its business and makes substantial efforts not to disclose to the public.
`2.
`Exhibit 4 to the Kastens Decl. described above is comprised of excerpts from the
`deposition transcript of Juniper’s employee Raju Manthena. These excerpts contain confidential
`technical information relating to Juniper’s highly proprietary software—which includes much
`information that Juniper maintains as trade secrets. Juniper expends significant effort in
`maintaining the secrecy of its software architecture and development, including, for example,
`implementing strict screening procedures for visitors to its engineering campus. Public disclosure
`of essential nonpublic facts about Juniper’s software development could materially impair
`Juniper’s intellectual property rights and could cause serious competitive consequences to
`Juniper’s business positioning.
`3.
`The select portions of pages 1-7 of Finjan’s Reply described above paraphrase or
`refer to the information contained in Exhibits 1 and 4 to the Kastens Decl., which reflect financial
`information concerning and the technical underpinnings and development of Juniper’s highly
`proprietary software—which includes much information that Juniper maintains as trade secrets.
`Juniper expends significant effort in maintaining the secrecy of its software architecture and
`development, including, for example, implementing strict screening procedures for visitors to its
`engineering campus. Public disclosure of essential nonpublic facts about Juniper’s software
`development could materially impair Juniper’s intellectual property rights and could cause serious
`competitive consequences to Juniper’s business positioning. These select portions of Finjan’s
`Reply also contain sealable confidential information that relate to Juniper’s confidential licensing
`information that Juniper regularly treats as highly confidential within its business and makes
`substantial efforts not to disclose to the public.
`4.
`In light of the foregoing, there are compelling reasons to seal the documents
`described above.
`Executed on November 28, 2018 in Los Angeles, California.
`[Signature page to follow]
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10125765
`
`
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`DECLARATION OF SHARON SONG ISO
`FINJAN’S ADMINISTRATIVE MOTION TO
` FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
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`Case 3:17-cv-05659-WHA Document 278 Filed 11/28/18 Page 4 of 4
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`I declare under penalty of perjury under the laws of the United States of America that the
`foregoing is true and correct to the best of my knowledge.
`
` /s/ Sharon Song
`Sharon Song
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10125765
`
`
`
`- 3 -
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`DECLARATION OF SHARON SONG ISO
`FINJAN’S ADMINISTRATIVE MOTION TO
` FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`