`
`
`
`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
`
`FINJAN, INC., a Delaware Corporation,
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
`
`
`
`
`
`
`Defendant.
`
`
`Case No.: 3:17-cv-05659-WHA
`
`DECLARATION OF KRISTOPHER
`KASTENS IN SUPPORT OF DEFENDANT
`JUNIPER NETWORKS INC.’S
`ADMINISTRATIVE MOTION TO FILE
`DOCUMENTS UNDER SEAL
`
`
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`KASTENS DECL. IN SUPPORT OF DEF.
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
`
`
`
`Case 3:17-cv-05659-WHA Document 421 Filed 04/09/19 Page 2 of 2
`
`
`
`I, Kristopher Kastens, declare:
`1.
`2.
`
`I have personal knowledge of the facts stated herein.
`
`I am an attorney at Kramer Levin Naftalis & Frankel LLP, counsel of record for Finjan,
`
`Inc. (“Finjan”). I make this declaration in support of Defendant Juniper Network Inc.’s Motion to Seal
`
`its Reply in the Second Motion for Early Summary Judgment Regarding Infringement of Claim 9 of
`
`U.S. Patent No. 6,804,780, pursuant to Civil Local Rules 79-5(d)-(e).
`3.
`
`I have reviewed the following documents and confirmed that they contain information
`
`designated as “Highly Confidential – Attorneys’ Eyes Only” by Finjan and Juniper pursuant to the
`
`stipulated protective order in this litigation.
`
`
`
`Identification of Documents to be Sealed
`
`Highlighted Text in Pages 13:28; 14:2-4 of
`Juniper’s Reply Brief ISO Juniper’s MSJ regarding
`Claim 9 of the ’780 Patent.
`4.
`Juniper’s Motion to seal the portion identified above should be granted because good
`
`Entity that Designated the Information
`to be Confidential
`Finjan and Juniper
`
`cause and compelling reasons exist to seal such identified portion, and such request is narrowly tailored.
`
`Specifically, the portion that sought to sealed contains references to confidential email communications
`
`between Finjan and Juniper (which acquired Cyphort) regarding licensing and negotiation information,
`
`the public disclosure of which could harm Finjan’s business. Further, it is my understanding that these
`
`communications fall under the protection of the Nondisclosure Agreement between Finjan and
`
`Juniper/Cyphort.
`5.
`
`I declare under penalty of perjury under the laws of the United States of America that
`
`each of the above statements is true and corrected. Executed on April 9, 2019, in Menlo Park,
`
`California.
`
`
`
`
`
`
`
`By: /s/ Kristopher Kastens
`Kristopher Kastens
`
`
`
`
`
`KASTENS DECL. IN SUPPORT OF DEF.
`ADMIN. MOTION TO FILE DOCUMENTS UNDER SEAL
`
`1
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