Case 3:17-cv-05659-WHA Document 370-1 Filed 02/14/19 Page 1 of 3
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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
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`Attorneys for Defendant
`JUNIPER NETWORKS, INC.
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCISCO DIVISION
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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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`Case No. 3:17-cv-05659-WHA
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`DECLARATION OF KEVIN WANG IN
`SUPPORT OF JUNIPER NETWORKS,
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`INC.’S MOTION FOR
`ADMINISTRATIVE RELIEF TO FILE
`DOCUMENTS UNDER SEAL
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10125765
`
`
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`- 1 -
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`DECLARATION OF KEVIN WANG ISO JUNIPER’S
`MOTION FOR ADMINISTRATIVE RELIEF
`TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`

`

`Case 3:17-cv-05659-WHA Document 370-1 Filed 02/14/19 Page 2 of 3
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`DECLARATION OF KEVIN WANG
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`I, Kevvin Wang, declare as follows:
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`1.
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`I am an attorney at the law firm of Irell & Manella LLP, counsel of record for
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`Juniper Networks, Inc. (“Juniper”) in the above-captioned matter. I am a member in good
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`standing of the State Bar of California and have been admitted to practice before this Court. I
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`have personal knowledge of the facts set forth in this Declaration and, if called as a witness, could
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`and would testify competently to such facts under oath.
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`2.
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`I submit this declaration in support of Juniper’s February 14, 2019 Motion for
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`Administrative Relief to File Documents Under Seal, which asks the Court for an Order to file
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`under seal the following documents:
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` Juniper’s unredacted Motion for Summary Judgment for Claim 9 of U.S. Patent No.
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`6,804,780 (the “Brief”);
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` Exhibit 6 to the Brief (excerpts from the deposition transcript of Finjan employee John
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`Garland);
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` Unredacted Exhibit 8 to the Brief (excerpts from Finjan’s Objections and Responses to
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`Juniper’s First Set of Interrogatories);
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` Exhibit 9 to the Brief (excerpts from the deposition transcript of Finjan employee Julie
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`Mar-Spinola);
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` Unredacted Declaration of Aviel D. Rubin in support of the Brief.
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`3.
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`The sealed portions of the documents described above that Juniper seeks to file
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`under seal contain confidential information of Juniper and Finjan. In this declaration, I explain
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`why these materials are sealable pursuant to Civil Local Rule 79-5.
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`4.
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`Exhibit 6 to the Brief is excerpts of the deposition transcript of Finjan employee
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`John Garland that have been designated confidential by Finjan.
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`5.
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`The redacted portions of Exhibit 8 to the Brief are excerpts from Finjan’s
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`Objections and Responses to Juniper’s First Set of Interrogatories that have been designated
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`confidential by Finjan.
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`6.
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`Exhibit 9 to the Brief is excerpts from the deposition transcript of Finjan employee
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10125765
`
`
`
`- 2 -
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`DECLARATION OF KEVIN WANG ISO JUNIPER’S
`MOTION FOR ADMINISTRATIVE RELIEF
`TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`

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`Case 3:17-cv-05659-WHA Document 370-1 Filed 02/14/19 Page 3 of 3
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`Julie Mar-Spinola that have been designated confidential by Finjan.
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`7.
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`The redacted portions of the Declaration of Aviel D. Rubin in support of the Brief
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`include discussion of Juniper’s confidential technical information related to Juniper’s highly
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`proprietary software.
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`8.
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`The redacted portions of the Brief directly reference the confidential materials
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`discussed above. The redacted portions of the Brief have been designated confidential by Finjan.
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`9.
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`The redacted portions of the Declaration Aviel D. Rubin contain sealable
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`confidential information that relate to the technical underpinnings and development of Juniper’s
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`highly proprietary software—which includes much information that Juniper maintains as trade
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`secrets. Juniper expends significant effort in maintaining the secrecy of its software architecture
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`and development, including, for example, implementing strict screening procedures for visitors to
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`its engineering campus. Public disclosure of essential nonpublic facts about Juniper’s software
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`development could materially impair Juniper’s intellectual property rights and could cause serious
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`competitive consequences to Juniper’s business positioning.
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`10.
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`Exhibits 6 and 9, and the redacted portions of Exhibit 8 and the Brief were
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`designated confidential by Finjan.
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`11.
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`For these reasons, the documents described above should be filed under seal.
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`Executed on February 14, 2019 at Newport Beach, California.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct to the best of my knowledge.
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` /s/ Kevin Wang
` Kevin Wang
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10125765
`
`
`
`- 3 -
`
`DECLARATION OF KEVIN WANG ISO JUNIPER’S
`MOTION FOR ADMINISTRATIVE RELIEF
`TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`