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`I, Stefan BiihImann, hereby state the following underoath:
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`i
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`om
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`2,
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`4.
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`I live in Witterswil, Switzerland.
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`| am the General Managerof Joe Security LLC (“Joe Security”).
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`Joe Security is a Swiss entity located in Reinach, Switzerland.
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`Joe Security is in the computer security business. Specifically, Joe Security has
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`developed a malware analysis and detection system that enables to detect and analyze computer
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`viruses and malwarethreats.
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`3;
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`6.
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`i
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`I have been involved in computer security and malware detection for 15 years.
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`Joe Security’s malware analysis and detection system is named “Joe Sandbox.”
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`Wecarefully screen our customers and only license our product to reputable
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`governmental security agencies and select corporations. The total number of Joe Security
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`customersis limited. Our customerlist is confidential.
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`8.
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`All of our business and governmentalpartners agreeto strict confidentiality
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`restrictions as a condition of using our solution.
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`9.
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`Our customersinstall our solution into their computer infrastructure to help
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`protect against malwarethreats.
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`10.
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`Customers who purchase our malware program are provided our(a) Installation
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`Guide, (b) Interface Guide, and (c) User Guide.
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`11.
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`Our Installation Guide and our Interface Guide contain highly confidential trade
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`secrets including the password to our system, the otherwise secret IP and MAC addresses on
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`which the system runs,file names, network ports and network protocols.
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`
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`12...
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`Asacompanythat focuses on computer malware, we knowthatthe efficacy of
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`our product could be immediately, directly and completely compromisedif this informationis
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`made public. Hackers would be ableto use this information to modify their malware to
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`circumvent our malware detection and prevention system.
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`13.
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`We would preferthat no parts of our Installation Guide, Interface Guide or User
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`Guide be made public as they contain a roadmapto our product and we believe that making our
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`Guides public will compromise the efficacy of our malware prevention product.
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`14.
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`In the event that the Court declines to allow our Guides to remain shielded from
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`public view, we requestin the alternative that redacted versions of our Installation Guide and
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`Interface Guide be filed.
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`| have personally reviewed our Installation Guide and Interface Guide
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`and identified the specific references to our system access password, and the IP and MAC
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`addressesandthe file names, network ports and network protocols on which our system runs.
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`|
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`estimate that the specific items I identified for redaction constitute less than one percent of the
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`text of the Installation Guide and Interface Guide.
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`Signed underthe pains and penalties of perjury this | day of June, 2019.eeA
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`Stefan Biihlmann
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