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`
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`Exhibit 3
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`
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`Case 3:17-cv-05659-WHA Document 360-4 Filed 01/24/19 Page 2 of 2
`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Kastens, Kris <KKastens@KRAMERLEVIN.com>
`Friday, March 30, 2018 10:05 AM
`Glucoft, Josh
`~Andre, Paul; ~Kobialka, Lisa; ~Hannah, James; Kagan, Jonathan; Carson, Rebecca;
`Wang, Kevin; Holland, Eileen; ~Manes, Austin; Curran, Casey; ~Manes, Austin; ~Lee,
`Michael
`RE: Meet and Confer
`
`Josh,
`We are available Tuesday afternoon to meet and confer. We suggest 3PM. You can reach me on my office line.
`
`
`To make sure there is no confusion, Finjan will meet and confer on the following topics:
`•
`Juniper’s failure to produce any confidential technical documents in the case, as outlined in my March 26 email.
`•
`Juniper’s failure to provide all relevant source code, and other issues with the source code I outlined in my
`March 26 email.
`Juniper’s refusal to produce material related to ATP Appliance or Spotlight Secure.
`Juniper’s request to deviate from the Court’s Order and to delay claim construction.
`
`•
`•
`
`
`
`Regarding Finjan’s production of materials confidential to third parties, as you are aware, we have been contacting
`multiple third parties daily. We have CCed you on those emails for Juniper. We will also start CCing Casey Curran as
`well, as from her recent correspondence she does not seem to be aware of the status of these negotiations.
`
`Contrary to our previous discussions, Juniper finally has agreed to the following narrowing of its document requests that
`impact third party confidential information as follows:
`
`
`Juniper is not seeking the following at this time: the Other Defendants’ discovery responses or any information or
`documentation produced by the Other Defendants in response to an interrogatory, RFP, or RFA; or deposition
`transcripts of employees of the Other Defendants. At this time, confidential infringement contentions and other
`documents that bear source code of the Other Defendants may be redacted to the extent that they contain
`information designated as “HIGHLY CONFIDENTIAL – SOURCE CODE.”
`
`
`
`We will inform those parties impacted by the narrowing of your requests. Based on past experience, we anticipate that
`even this is likely to draw objections from those third parties because of the breadth of Juniper’s requests. Finjan
`requests a succinct list of material that Juniper is requesting. Let us know if you can provide such a list that we can
`provide to impacted third parties. Furthermore, we would like to note that we do not see how any of this material will
`be relevant to the “shootout.” As envisioned by the Court, this procedure will focus on infringement by Juniper, which
`will be based on Juniper’s products and the patents.
`
`
`Sincerely,
`Kris
`
`
`
`
`Kris Kastens
`Associate
`
`
`Kramer Levin Naftalis & Frankel LLP
`
`1
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`
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