`
`
`
`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
`
`
`Case No.: 3:17-cv-05659-WHA
`
`PLAINTIFF FINJAN, INC.’S
`ADMINISTRATIVE MOTION TO FILE
`DOCUMENTS UNDER SEAL
`
`
`FINJAN, INC., a Delaware Corporation,
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
`
`
`
`
`
`
`Defendant.
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`FINJAN’S ADMIN. MOTION TO FILE
`DOCUMENTS UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
`
`
`
`Case 3:17-cv-05659-WHA Document 351 Filed 01/10/19 Page 2 of 3
`
`
`
`I.
`
`INTRODUCTION
`
`Pursuant to Federal Rule of Civil Procedure 26(c), Civil Local Rules 7-11 and 79-5, Plaintiff,
`
`Finjan, Inc. (“Finjan”), brings this Administrative Motion to File Under Seal. The documents identified
`
`below contain confidential information of Juniper. Specifically, there exist good cause and compelling
`
`reasons to file the following document under seal:
`
`
`Identification of Documents to be Sealed
`
`Finjan’s Motion for Judgement as a Matter of Law under
`Rule 50(b), for a New Trial under Rule 59, and for Immediate
`Certification for Appeal in the Alternative, at the following
`page:line numbers: 5:26; 6:6, 17; 7:1-5; 10:23; 18:16; and
`19:4-7.
`
`
`Exhibits 3-7, 10-12, 14, and 16 to the Kastens Declaration
`filed in support of Finjan’s Motion for Judgement as a Matter
`of Law under Rule 50(b), for a New Trial under Rule 59, and
`for Immediate Certification for Appeal in the Alternative,
`ARGUMENT
`
`II.
`
`Entity that Designated the
`Information to be
`Confidential
`
`Juniper
`
`Juniper
`
`This Administrative Motion to File Documents Under Seal should be granted because good
`
`cause and compelling reasons exist to seal the documents identified above. Finjan seeks to seal only
`
`those documents and portions of documents that Juniper identified as containing confidential
`
`information pursuant to the Protective Order.
`
`Finjan seeks to seal Finjan’s Motion for Judgement as a Matter of Law under Rule 50(b), for a
`
`New Trial under Rule 59, and for Immediate Certification for Appeal in the Alternative at the following
`
`page:line numbers: 5:26; 6:6, 17; 7:1-5; 10:23; 18:16; and 19:4-7, and Exhibits 3-7, 10-12, 14, and 16
`
`to the Kastens Declaration filed in support of the same as set forth in the accompanying declaration of
`
`Austin Manes in Support of this Administrative Motion (“Manes Sealing Declaration”), because these
`
`portions contain information that Juniper has designated as “Highly Confidential – Attorneys’ Eyes
`
`Only” or “Highly Confidential – Attorneys’ Eyes Only – Source Code.” Specifically, this information
`
`contains descriptions or quotes from Juniper’s technical documents or source code, or Juniper’s
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`FINJAN’S ADMIN. MOTION TO FILE
`DOCUMENTS UNDER SEAL
`
`1
`
`CASE NO.: 3:17-cv-05659-WHA
`
`
`
`Case 3:17-cv-05659-WHA Document 351 Filed 01/10/19 Page 3 of 3
`
`
`
`financial and sales information, the public disclosure of which Juniper claims could harm its business.
`
`Pursuant to Civil Local Rule 79-5, Finjan has filed publicly the relevant excerpts of information
`
`that are not confidential. Attached hereto are redacted and unredacted versions of the documents set
`
`forth above.
`III. CONCLUSION
`For the foregoing reasons, Finjan respectfully requests that the Court grant this Administrative
`
`Respectfully submitted,
`
`By: /s/ Lisa Kobialka____________
`Paul J. Andre (State Bar No. 196585)
`Lisa Kobialka (State Bar No. 191404)
`James Hannah (State Bar No. 237978)
`Kristopher Kastens (State Bar No. 254797)
`KRAMER LEVIN NAFTALIS
`& FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`pandre@kramerlevin.com
`lkobialka@kramerlevin.com
`jhannah@kramerlevin.com
`kkastens@kramerlevin.com
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`
`
`
`
`
`
`2
`
`CASE NO.: 3:17-cv-05659-WHA
`
`
`
`FINJAN’S ADMIN. MOTION TO FILE
`DOCUMENTS UNDER SEAL
`
`Motion to File Documents Under Seal.
`
`
`
`
`Dated: January 10, 2018
`
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