`
`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Joshua P. Glucoft (SBN 301249)
`jglucoft@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
`Ingrid M. H. Petersen (SBN 313927)
`ipetersen@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
`
`Attorneys for Defendant
`JUNIPER NETWORKS, INC.
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`
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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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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10664753
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`Case No. 3:17-cv-05659-WHA
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`DEFENDANT JUNIPER NETWORKS,
`INC.’S ADMINISTRATIVE MOTION TO
`FILE UNDER SEAL
`
`Judge: Hon. William Alsup
`
`
`JUNIPER’S ADMINISTRATIVE MOTION
`TO FILE UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`
`
`
`
`Case 3:17-cv-05659-WHA Document 434 Filed 04/12/19 Page 2 of 2
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`NOTICE OF MOTION AND MOTION
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`TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
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`PLEASE TAKE NOTICE THAT pursuant to Civil Local Rules 7-11 and 79-5, Defendant
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`Juniper Networks, Inc. (“Juniper”) respectfully moves to seal the following documents because third
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`party, Joe Security LLC (“Joe Security”), has designated the information in those documents as
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`confidential:
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`Portion to Be Sealed
`Document
`Juniper’s Opposition Highlighted Text
`within Section
`III.A.1.a
`Entire Exhibit
`
`Exhibit 1
`
`Exhibit 2
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`Entire Exhibit
`
`Exhibit 3
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`Entire Exhibit
`
`Exhibit 10
`
`Entire Exhibit
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`Exhibit 11
`
`Entire Exhibit
`
`Exhibit 12
`
`Entire Exhibit
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`Exhibit 13
`
`Entire Exhibit
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`Exhibit 14
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`Entire Exhibit
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`
`
`Basis for Sealing
`Third-Party
`Confidentiality
`
`Designating Party
`Joe Security
`
`Third-Party
`Confidentiality
`Third-Party
`Confidentiality
`Third-Party
`Confidentiality
`Third-Party
`Confidentiality
`Third-Party
`Confidentiality
`Third-Party
`Confidentiality
`Third-Party
`Confidentiality
`Third-Party
`Confidentiality
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`Joe Security
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`Joe Security
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`Joe Security
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`Joe Security
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`Joe Security
`
`Joe Security
`
`Joe Security
`
`Joe Security
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`Juniper seeks to seal only those documents and portions of documents that Joe Security has
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`identified as confidential information. Accordingly, the Court should grant this motion because
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`good cause and compelling reasons exist.
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`
`
`Dated: April 12, 2019
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`Respectfully submitted,
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`By:
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` /s/ Joshua Glucoft
`Joshua Glucoft
`Attorney for Defendant
`Juniper Networks, Inc.
`
`10664753
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`- 1 -
`
`
`JUNIPER’S ADMINISTRATIVE MOTION
`TO FILE UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`
`
`
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