Case 3:17-cv-05659-WHA Document 375 Filed 02/19/19 Page 1 of 3
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`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
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`Attorneys for Plaintiff
`FINJAN, INC.
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCISCO DIVISION
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`FINJAN, INC., a Delaware Corporation,
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`Plaintiff,
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`v.
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`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
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`Defendant.
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`Case No.: 3:17-cv-05659-WHA
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`DECLARATION OF AUSTIN MANES IN
`SUPPORT OF DEFENDANT JUNIPER
`NETWORKS, INC.’S MOTION FOR
`ADMINISTRATIVE RELIEF TO FILE
`DOCUMENTS UNDER SEAL
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`[Re: Dkt. No. 370]
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`MANES DECL. IN SUPPORT OF JUNIPER’S ADMIN.
`MOTION TO FILE DOCUMENTS UNDER SEAL
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`Case No.: 17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 375 Filed 02/19/19 Page 2 of 3
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`I, Austin Manes, declare:
`1.
`2.
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`I have personal knowledge of the facts stated herein.
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`I am licensed to practice law in the State of California and am an attorney at Kramer
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`Levin Naftalis and Frankel LLP, counsel of record for Finjan, Inc. (“Finjan”). I make this declaration
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`in support of Defendant Juniper Networks, Inc.’s Motion to Seal (Dkt. 370) documents filed in support
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`of its Motion for Summary Judgment Re Claim 9 of U.S. Patent No. 6,804,780 (Dkt. 371) (“Juniper’s
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`Brief”), pursuant to Civil Local Rules 79-5(d)-(e).
`3.
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`I have reviewed the following documents and confirmed that they contain information
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`designated “Highly Confidential - Attorneys’ Eyes Only” by Finjan pursuant to the stipulated
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`protective order in this litigation.
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`Identification of the documents to be sealed
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`Juniper’s Brief at p. 24, ll. 15-16.
`Exhibit 6 to Juniper’s Brief at p. 48 ll. 2-25, and p. 49 ll. 1-19.
`Exhibit 9 to Juniper’s Brief at p. 88 ll. 3-4.
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`Entity that designated
`the information as
`confidential
`Finjan
`Finjan
`Finjan
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`4.
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`Juniper’s Brief at p. 24, ll. 15-16 discloses Finjan’s confidential business and licensing
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`practices – specifically the identification of Finjan’s licensing practices and negotiations. Finjan treats
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`its licenses as highly confidential within its business and makes substantial efforts not to disclose the
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`terms of its licenses to the public. If such provisions were made public, it could negatively impact
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`Finjan’s bargaining positions in future licensing negotiations with competitors and no public interest
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`will be served by disclosing this information publicly. A proposed redacted and unredacted version of
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`Juniper’s Brief is attached hereto.
`5.
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`Exhibit 6 to Juniper’s Brief at p. 48 ll. 2-25; and p. 49 ll. 1-19 disclose Finjan’s
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`confidential business and licensing practices – specifically the identification of Finjan’s licensing
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`practices and negotiations. Finjan treats its licenses as highly confidential within its business and
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`makes substantial efforts not to disclose the terms of its licenses to the public. If such provisions were
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`1
`MANES DECL. IN SUPPORT OF JUNIPER’S ADMIN.
`MOTION TO FILE DOCUMENTS UNDER SEAL
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`Case No.: 17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 375 Filed 02/19/19 Page 3 of 3
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`made public, it could negatively impact Finjan’s bargaining positions in future licensing negotiations
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`with competitors and no public interest will be served by disclosing this information publicly. A
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`proposed redacted and unredacted version of Exhibit 6 to Juniper’s Brief is attached hereto.
`6.
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`Exhibit 9 to Juniper’s Brief at p. 88 ll. 3-4 discloses Finjan’s confidential business and
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`licensing practices – specifically the identification of Finjan’s licensing practices and negotiations.
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`Finjan treats its licenses as highly confidential within its business and makes substantial efforts not to
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`disclose the terms of its licenses to the public. If such provisions were made public, it could negatively
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`impact Finjan’s bargaining positions in future licensing negotiations with competitors and no public
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`interest will be served by disclosing this information publicly. A proposed redacted and unredacted
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`version of Exhibit 9 to Juniper’s Brief is attached hereto.
`7.
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`In light of the foregoing, compelling reasons exist to seal the documents described
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`above.
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`I declare under penalty of perjury under the laws of the United States of America that each of
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`the above statements is true and correct. Executed on February 19, 2019, in Menlo Park, California.
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`/s/ Austin Manes
`Austin Manes
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`2
`MANES DECL. IN SUPPORT OF JUNIPER’S ADMIN.
`MOTION TO FILE DOCUMENTS UNDER SEAL
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`Case No.: 17-cv-05659-WHA
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