`
`1 8 0 0 A V E N U E O F T H E S T A R S , S U I T E 9 0 0
`L O S A N G E L E S , C A 9 0 0 6 7 - 4 2 7 6
`T E L E P H O N E ( 3 1 0 ) 2 7 7 - 1 0 1 0
`F A C S I M I L E ( 3 1 0 ) 2 0 3 - 7 1 9 9
`
`
`I R E L L & M A N E L L A L L P
`
`A REGISTERED LIMITED LIABILITY LAW PARTNERSHIP
`INCLUDING PROFESSIONAL CORPORATIONS
`
`8 4 0 N E W P O R T C E N T E R D R I V E , S U I T E 4 0 0
`
`N E W P O R T B E AC H , C A L I F O R N I A 9 2 6 6 0 - 6 3 2 4
`
`T E L E P H O N E ( 9 4 9 ) 7 6 0 - 0 9 9 1
`F A C S I M I L E ( 9 4 9 ) 7 6 0 - 5 2 0 0
`W E B S I T E : w w w . i r e l l . c o m
`
`W R I T E R ' S D I R E C T
`
`T E L E P H O N E ( 9 4 9 ) 7 6 0 - 5 2 2 2
`R C a r s o n @ i r e l l . c o m
`
`February 28, 2019
`
`
`
`Hon. William Alsup
`
`U.S. District Court, Northern District of California
`Re:
`Finjan, Inc. v. Juniper Networks, Inc., Case No. 3:17-cv-05659-WHA
`
`
`
`
`Dear Judge Alsup:
`The parties respectfully request more time to meet and confer regarding the case
`management approaches proposed by the Court at the hearing last week.
`During the hearing on February 21, 2018, the Court suggested that it would certify the
`orders from the first phase of the “Patent Showdown” proceedings for appeal if the parties agreed
`that the outcome of the appeal would dispose of the entire case, including the other asserted patents.
`See Dkt. No. 378 (Transcript of proceedings held on 2/21/2019) at 28:11-23. The Court further
`indicated that it would provide the parties with one week to see if they could agree on the details
`of such a procedure. Id. at 31:1-4, 32:20-24. While both parties remain open to this strategy, the
`parties have not yet reached agreement on the issue. Accordingly, the parties respectfully request
`that the Court continue to defer its ruling on the issue of certification for interlocutory appeal for
`an additional week in order to provide the parties with more time to try to reach an agreement.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
` /s/ Rebecca L. Carson
`Rebecca L. Carson
`IRELL & MANELLA LLP
`Attorneys for Defendant
`Juniper Networks, Inc.
`
`
`
`
` /s/ Paul Andre
`Paul Andre
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`Attorneys for Plaintiff
`Finjan, Inc.
`
`
`
`
`10649225
`
`
`
`
`