Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 1 of 823
`
`Exhibit 5
`(FILED UNDER SEAL)
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 2 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`FINJAN, INC. V. JUNIPER NETWORKS, INC.
`
`CASE NO. 17-CV-5659-WHA
`
`Finjan, Inc.’s Amended May 14, 2019 Supplemental Privilege Log1
`
`May 17, 2019
`
`1 Plaintiff Finjan expressly reserves the right to amend this privilege log in the event that any documents covered by the attorney-client privilege, attorney work-product doctrine or any other applicable
`privilege are inadvertently produced and not identified herein at the time of production.
`
`1
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 3 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`LIST OF NAMES AND AFFILIATIONS
`
`Name
`
`Aber, David
`Abrams, William
`Aharoni-Yonas, Einav
`Ai, Bing
`Andre, Paul
`
`Arnheim, Buddy
`Arussy, Lior
`Ayal Shenhav & Co.
`Bardehle Pagenberg Dost Altenburg Geissler
`Barnes, Suzanne
`Bartels, Donald
`Baxter, Holly
`Ben-Itzhak, Yuval
`Benton, Gary
`Berger, Marc
`Bey, Dawn-Marie
`
`Bey & Cotropia PLLC
`Biram, Renana
`Blasik, Michele
`
`Company
`Finjan Software, Inc. and/or its subsidiaries
`Coudert Brothers LLP
`Ayal Shenhav & Co.
`Perkins Coie LLP
`Perkins Coie LLP
`King & Spalding LLP
`Kramer Levin Naftalis & Frankel LLP
`Perkins Coie LLP
`Finjan Software, Inc. and/or its subsidiaries
`Outside Counsel (Israel)
`Outside Counsel (Germany)
`Finjan Software, Inc. and/or its subsidiaries
`Coudert Brothers LLP
`Finjan Software, Inc. and/or its subsidiaries
`Finjan Software, Inc. and/or its subsidiaries
`Coudert Brothers LLP
`Finjan Software, Inc. and/or its subsidiaries
`King & Spalding LLP
`Bey & Cotropia PLLC
`Outside Counsel (United States)
`Finjan Software, Inc. and/or its subsidiaries
`King & Spalding LLP
`
`
`
`2
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 4 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`
`Bottomley, Christine
`Boyle, Brian
`Brainard, Charles
`branganathan@apex.com
`Brunch, Linda
`Brunell, Linda
`Cain, Marcus
`Carr, DeFilippo & Farrell LLP
`Carstairs, James
`Chinn, Daniel
`
`Chizek, Martin S.
`Colb, Sanford T.
`Colucci, Marcus
`Corbett, Krys
`Coudert Brothers LLP
`Cone, Dave
`Cowan, David
`
`Cruz, Kit
`Cummings, Adria
`Cummings, Susan
`Darby & Darby, P.C.
`
`Company
`Finjan Software, Inc. and/or its subsidiaries
`Kramer Levin Naftalis & Frankel LLP
`Kenyon & Kenyon LLP
`Apex Investment Fund, Finjan shareholder representative
`Eitan Law Group
`Eitan Law Group
`Finjan Software, Inc. and/or its subsidiaries
`Outside Counsel (United States)
`Forrester Ketley & Co.
`Israel Seed Partners
`Finjan Software, Inc. and/or its subsidiaries
`Graham & James LLP
`Sanford T. Colb & Co.
`Kramer Levin Naftalis & Frankel LLP
`Wilson Sonsini Goodrich & Rosati
`Outside Counsel (Worldwide)
`MSide (Translations)
`Bessemer Venture Partners – as holder of set on Finjan Board of
`Directors
`Coudert Brothers LLP
`Finjan Software, Inc. and/or its subsidiaries
`Finjan Software, Inc. and/or its subsidiaries
`Outside Counsel (United States)
`
`
`
`3
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 5 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`
`Dennison, Steve
`
`Dick, Marion
`Doss, Richard
`Dow, Annette
`Durdik, Paul A.
`Dycaico, Peter
`Eitan, Tally
`Elazer, Uri
`Elbaz, Limor
`Eitan Law Group
`Ettinger, Adam
`Fetherstonhaugh & Co.
`Feuer, Jeff
`Feigelson, Daniel
`Finjan K&S
`Forrester & Boehmert
`Forrester Ketley & Co.
`Forrester, Kent
`Franzen, Marie
`Gal, Nachshon
`Gassner, Tali
`Geraldine
`
`Company
`
`King & Spalding LLP
`Kramer Levin Naftalis & Frankel LLP
`Squire, Sanders & Dempsey L.L.P.
`Quinn Emanuel Urquhart Oliver & Hedges, LLP
`Wilson Sonsini Goodrich & Rosati
`Squire, Sanders & Dempsey L.L.P.
`Coudert Brothers LLP
`Eitan Law Group
`Finjan Software, Inc. and/or its subsidiaries
`Finjan Software, Inc. and/or its subsidiaries
`Outside Counsel (Israel)
`Coudert Brothers LLP
`Outside Counsel (Canada)
`Finjan Software, Inc. and/or its subsidiaries
`Sanford T. Colb & Co.
`King & Spalding LLP
`Outside Counsel (Germany)
`Outside Counsel (United Kingdom)
`King & Spalding LLP
`Squire, Sanders & Dempsey L.L.P.
`Finjan Software, Inc. and/or its subsidiaries
`Eitan Law Group
`Sanford T. Colb & Co.
`
`
`
`4
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 6 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`
`Gildea, Edward
`Gillis, Sally
`Goad, Terry
`Goldberg, Selwyn
`Graham & James LLP
`Green, Bruce M.
`Hameline, Joseph
`Hartstein, Phil
`Hannah, James
`
`Hannah, William
`Hernandez, Joseph
`Hernandez, Mona
`Hite, Eppa
`Hughes, Jamie
`Huylebroeck, Guy
`Hyman, Michael
`Iizuka, Yoshihito
`Israel Seed Partners
`Itnati, Michael
`Janikowski, Eileen
`jeff@finjan.com
`
`Company
`Finjan Software, Inc. and/or its subsidiaries
`Eitan Law Group
`King & Spalding LLP
`Wilson Sonsini Goodrich & Rosati
`Outside Counsel (United States)
`Oyen Wiggs Green & Mutala
`Mintz, Levin, Cohn, Ferris, Glorsky & Popeo P.C.
`Finjan, Inc. and/or its subsidiaries
`Perkins Coie LLP
`King & Spalding LLP
`Kramer Levin Naftalis & Frankel LLP
`Kramer Levin Naftalis & Frankel LLP
`Wise & Shepard LLP
`King & Spalding LLP
`Carr, DeFilippo & Ferrell LLP
`Perkins Coie LLP
`Finjan Software, Inc. and/or its subsidiaries
`Wilson Sonsini Goodrich & Rosati
`Yoshihito Iizuka Patent and Trademark Attorney
`Finjan shareholder
`Eitan Law Group
`Squire Sanders & Dempsey L.L.P.
`Finjan Software, Inc. and/or its subsidiaries
`
`
`
`5
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 7 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`
`Josephson, D.A.
`Josephson, Daryl C.
`Kane, Erik
`Kastens, Kristopher
`
`Kenny, John
`Kenyon & Kenyon LLP
`Kielia, Jeff
`King & Spalding LLP
`Kisylia, Jeff
`Klar, Hasida
`Kleinbendler & Halevy
`Kobialka, Lisa
`
`Kraitsman, Ron
`Kramer Levin Naftalis & Frankel LLP
`Label, Justin
`
`Lachman, Ilanit
`Lazarow, Mark
`Law Offices of Marsh & Pena
`Lee, Hannah
`
`Company
`Squire Sanders & Dempsey L.L.P.
`Squire Sanders & Dempsey L.L.P.
`Kenyon & Kenyon LLP
`King & Spalding LLP
`Kramer Levin Naftalis & Frankel LLP
`Kenyon & Kenyon LLP
`Outside Counsel (United States)
`Finjan Software, Inc. and/or its subsidiaries
`Outside Counsel (United States)
`Finjan Software, Inc. and/or its subsidiaries
`Squire Sanders & Dempsey L.L.P.
`Outside Counsel (Israel)
`Perkins Coie LLP
`King & Spalding LLP
`Kramer Levin Naftalis & Frankel LLP
`Finjan Software, Inc. and/or its subsidiaries
`Outside Counsel (United States)
`Bessemer Venture Partners — as holder of set on Finjan Board of
`Directors
`Reinhold Cohn & Partners
`Perkins Coie LLP
`Outside Counsel (United States)
`King & Spalding LLP
`Kramer Levin Naftalis & Frankel LLP
`
`
`
`6
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 8 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`
`Lee, Michael
`Lempert, Marcio
`LeRoy
`Ludwig, S. Peter
`Lyons, Bill
`Maier, Gadi
`Marsh, Joel
`Masluk, Vered
`Maxwell, Bret
`McEnroe, Katherine L.
`Medrano, Roberto
`Meeker, Heather
`Melcher, Esther
`Michaelson, Jon
`Middlemas, George
`Mintz, Levin, Cohn, Ferris, Glorsky & Popeo P.C.
`Moore, Michele
`Moritz, Ron
`Morris, Gary
`Moses, Joan
`Ng, Chun
`Oblon, Michael
`Olson, Stephanie
`
`Company
`Kramer Levin Naftalis & Frankel LLP
`Finjan Software, Inc. and/or its subsidiaries
`Carr, DeFilippo & Farrell LLP (worked with Marc Sockol)
`Darby & Darby, P.C.
`Finjan Software, Inc. and/or its subsidiaries
`Finjan Software, Inc. and/or its subsidiaries
`Law Offices of Marsh & Pena
`Finjan Software, Inc. and/or its subsidiaries
`The Productivity Fund, Finjan shareholder representative
`Graham & James
`Finjan Software, Inc. and/or its subsidiaries
`Wilson Sonsini Goodrich & Rosati
`Coudert Brothers LLP
`Coudert Brothers LLP
`Apex Investment Fund, Finjan shareholder representative
`Outside Counsel (United States)
`Finjan Software, Inc. and/or its subsidiaries
`Finjan Software, Inc. and/or its subsidiaries
`Kenyon & Kenyon LLP
`Wilson Sonsini Goodrich & Rosati
`Perkins Coie LLP
`Perkins Coie LLP
`Perkins Coie LLP
`
`
`
`7
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 9 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`Oyen Wiggs Green & Mutala
`Pammel, Celia
`Paolella-Bald, Jeanne
`
`Pavlovich, Relly
`penny@finjan.com
`Perkins Coie LLP
`Pickrell, Greg
`Pillsbury Winthrop
`Polani, Asher
`Pruetz, Adrian
`Quinn Emanuel Urquhart Oliver & Hedges LLP
`Reinhold Cohn & Partners
`Ring, Scott
`
`robert@finjan.com
`Roos, John
`Rosenthal, Steve
`Rouach, Yael
`Rübel, Clemens
`Sabo, Itzy
`Sanford T. Colb & Co.
`Schendel, Elka
`
`Company
`
`Outside Counsel (Canada)
`Perkins Coie LLP
`King & Spalding LLP
`Bey & Cotropia PLLC
`Kleinbendler & Halevy
`Finjan Software, Inc. and/or its subsidiaries
`Outside Counsel (United States)
`Coudert Brothers LLP
`Outside Counsel (United States)
`Finjan Software, Inc. and/or its subsidiaries
`Quinn Emanuel Urquhart Oliver & Hedges LLP
`Outside Counsel (United States)
`Outside Counsel (Israel)
`Bessemer Venture Partners – as holder of set on Finjan Board of
`Directors
`Finjan Software, Inc. and/or its subsidiaries
`Wilson Sonsini Goodrich & Rosati
`Mintz, Levin, Cohn, Ferris, Glovsky and Popeo P.C.
`Eitan Law Group
`Bardehle Pagenberg Dost Altenburg Geissler
`Finjan Software, Inc. and/or its subsidiaries
`Outside Counsel (Israel)
`Finjan Software, Inc. and/or its subsidiaries
`
`
`
`8
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 10 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`
`Schieber, Avihai
`Sears, Nick
`Sexton, Sally
`Sfekas, James
`Shaked, Amit
`Shaked-Stadler, Netta
`
`Shalom, Yaron
`Shenhav, Ayal
`Shinn, John
`Shteinsky, Calit
`Sinder, Stuart
`Sirjani, Fariba
`Sockol, Marc
`
`Sofer, Ezra
`Sophir, Eric
`Squire, Sanders & Dempsey L.L.P.
`Steinmetz, Shimon
`Strong, Karen
`
`Sum, Theodore W.
`Tandon, Radika
`
`Company
`
`Eitan Law Group
`Finjan Software, Inc. and/or its subsidiaries
`King & Spalding LLP
`Perkins Coie LLP
`Finjan Software, Inc. and/or its subsidiaries
`Ayal Shenhav & Co.
`Eitan Law Group
`Finjan Software, Inc. and/or its subsidiaries
`Ayal Shenhav & Co.
`Finjan Software, Inc. and/or its subsidiaries
`Sanford T. Colb & Co.
`Kenyon & Kenyon LLP
`Squire, Sanders & Dempsey L.L.P.
`Squire, Sanders & Dempsey L.L.P.
`Carr, DeFilippo & Farrell LLP
`Finjan Software, Inc. and/or its subsidiaries
`King & Spalding LLP
`Outside Counsel (United States)
`Finjan Software, Inc. and/or its subsidiaries
`King & Spalding LLP
`Kramer Levin Naftalis & Frankel LLP
`Fetherstonhaugh & Co.
`Perkins Coie LLP
`
`
`
`9
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 11 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`
`Tas, Robert
`Taylor, Marla
`Tersch, Glenn Von
`Thoorseil, Cathi
`Tomeo, Charles
`Tong, Gladys
`
`Topper, Jonathan
`Touboul, Shlomo
`Uehlein, Sara
`Vigna, Giovanni
`Vigouroux, John
`Wallach, Etzion
`Weisrose, Stuart
`Wilson Sonsini Goodrich & Rosati
`Wininger, Aaron
`Winkler, Ellen
`Wise & Shepard LLP
`Yarborough, Sharon
`Yi, Sandra
`Yoshihito Iizuka Patent and Trademark Attorney
`Lisa Young
`yrc@star-ventures.com
`
`Company
`Finjan Software, Inc. and/or its subsidiaries
`Coudert Brothers LLP
`Perkins Coie LLP
`Squire Sanders & Dempsey L.L.P.
`Finjan Software, Inc. and/or its subsidiaries
`King & Spalding LLP
`Kramer Levin Naftalis & Frankel LLP
`Squire, Sanders & Dempsey L.L.P.
`Finjan Software, Inc. and/or its subsidiaries
`King & Spalding LLP
`Consultant
`Finjan Software, Inc. and/or its subsidiaries
`Finjan Software, Inc. and/or its subsidiaries
`Sanford T. Colb & Co.
`Outside Counsel (United States)
`Squire, Sanders & Dempsey L.L.P.
`Finjan Software, Inc. and/or its subsidiaries
`Outside Counsel (United States)
`Perkins Coie LLP
`Squire, Sanders & Dempsey L.L.P.
`Outside Counsel (Japan)
`Computer Packages, Inc.
`Star Ventures, Finjan shareholder representative
`
`
`
`10
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 12 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`
`Yusin, Robert
`Zeiti-Rosen, Sharon
`Zharnest, David
`Zielinski, Walt
`
`Company
`Finjan Software, Inc. and/or its subsidiaries
`Reinhold Cohn & Partners
`Finjan Software, Inc. and/or its subsidiaries
`Darby & Darby, P.C.
`
`
`
`11
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 13 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`
`
`
`Doc.
`No.
`1.
`
`Date
`
`From
`
`To
`
`CC
`
`Description
`
` 08/29/02 Aaron Wininger
`
`Shlomo Touboul
`
`
`
`Email regarding
`prosecution of U.S. Patent
`Application No.
`60/205,591.
`
`Type of
`Privilege
`Attorney-Client
`
`2.
`
` 08/29/02 Aaron Wininger
`
`Shlomo Touboul
`
`
`
`3.
`
` 08/29/02 Aaron Wininger
`
`Shlomo Touboul
`
`
`
`Letter regarding
`prosecution of U.S. Patent
`Application No.
`09/539,667.
`
`Attorney-Client
`
`Letter regarding
`prosecution of U.S. Patent
`Application No.
`09/539,667.
`
`Attorney-Client
`
`Location and Steps Taken For
`Confidentiality
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`
`
`
`12
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 14 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Doc.
`No.
`4.
`
`Date
`
`From
`
`To
`
`CC
`
`Description
`
` 10/03/02 Aaron Wininger
`
`Shlomo Touboul
`
`
`
`Email regarding
`prosecution of U.S. Patent
`Application No.
`60/205,591.
`
`Type of
`Privilege
`Attorney-Client
`
`5.
`
` 10/09/02 Aaron Wininger
`
`Shlomo Touboul
`
`
`
`6.
`
` 10/09/02 Aaron Wininger
`
`Shlomo Touboul
`
`
`
`Letter regarding
`prosecution of U.S. Patent
`Application No.
`09/539,667.
`
`Attorney-Client
`
`Letter regarding
`prosecution of U.S. Patent
`Application No.
`09/539,667.
`
`Attorney-Client
`
`Location and Steps Taken For
`Confidentiality
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`
`
`
`13
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 15 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Doc.
`No.
`7.
`
`Date
`
`From
`
`To
`
`CC
`
`Description
`
` 09/15/03 Aaron Wininger
`
`Marc Berger
`
`Shlomo Touboul
`
`Letter regarding
`prosecution of U.S. Patent
`Application No.
`09/861,229.
`
`Type of
`Privilege
`Attorney-Client
`
`8.
`
` 05/05/04 Aaron Wininger
`
`Marc Berger
`
`
`
`9.
`
` 06/17/04 Adam Ettinger
`
`David Aber
`
`Gary Benton
`
`Letter regarding
`prosecution of Israel
`Patent Application No.
`129,729.
`
`Attorney-Client
`
`Email forwarding and
`commenting on draft
`consulting agreement with
`attachment.
`
`Attorney-Client
`
`Location and Steps Taken For
`Confidentiality
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`
`
`
`14
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 16 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Doc.
`No.
`10.
`
`Date
`
`From
`
`To
`
`CC
`
`Description
`
` 06/17/04 Adam Ettinger
`
`David Aber
`
`Gary Benton
`
`Email regarding consulting
`agreement with
`attachment.
`
`Type of
`Privilege
`Attorney-Client
`
`11.
`
` 01/19/04 Amit Shaked
`
`Shlomo Touboul
`Uri Elazer
`Itzy Sabo
`
`12.
`
` 01/21/04 Amit Shaked
`
`David Aber
`
`
`
`
`
`Email correspondence
`with counsel regarding
`software license.
`
`Attorney-Client
`
`Email correspondence
`with counsel regarding
`software license.
`
`Attorney-Client
`
`Location and Steps Taken For
`Confidentiality
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`
`
`
`15
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 17 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Doc.
`No.
`13.
`
`Date
`
`From
`
`To
`
`CC
`
`Description
`
` 01/26/04 Amit Shaked
`
`David Aber
`
`Shlomo Touboul
`Uri Elazer
`
`Email correspondence
`with counsel regarding
`software license.
`
`Type of
`Privilege
`Attorney-Client
`
`14.
`
` 01/29/04 Amit Shaked
`
`Shlomo Touboul
`Uri Elazar
`Gary Benton
`
`David Aber
`
`Email correspondence
`with counsel regarding
`software license.
`
`Attorney-Client
`
`15.
`
` 12/29/05 Asher Polani
`
`Yuval Ben-Itzhak
`Limor Elbaz
`
`
`
`Email correspondence
`regarding Secure
`Computing
`
`Attorney-Client
`Work Product
`
`Location and Steps Taken For
`Confidentiality
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`
`
`
`16
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 18 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Doc.
`No.
`16.
`
`Date
`
`From
`
`To
`
`CC
`
`Description
`
` 05/04/06 Asher Polani
`
`Joseph Hameline
`Steve Rosenthal
`
`Yuval Ben-Itzhak
`Daniel Chinn
`
`Email correspondence
`regarding Webwasher.
`
`Type of
`Privilege
`Attorney-Client
`Work Product
`
`17.
`
` 08/07/06 Asher Polani
`
`Finjan Employees
`
`
`
`Email correspondence
`from CEO to all Finjan
`employees regarding
`lawsuit and sent at the
`direction of counsel.
`
`Attorney-Client
`Work Product
`
`18.
`
` 02/10/05 Avihai Schieber
`
`William Abrams
`
`Tally Eitan
`David Aber
`Shlomo Touboul
`
`Email correspondence
`regarding Microsoft
`license agreement.
`
`Attorney-Client
`
`Location and Steps Taken For
`Confidentiality
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`
`
`
`17
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 19 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Doc.
`No.
`19.
`
`Date
`
`From
`
`To
`
`CC
`
`Description
`
` 06/2003 Ayal Shenhav
`
`
`
`
`
`Draft tender offer letter.
`
`Type of
`Privilege
`Attorney-Client
`
`20.
`
` 06/15/03 Ayal Shenhav
`
`David Aber
`
`Email forwarding draft
`tender offer.
`
`Attorney-Client
`
`Einav Aharoni-
`Yonas
`Netta Shaked-
`Stadler
`Gary Benton
`Shlomo Touboul
`
`21.
`
`
`
`Bey & Cotropia
`
`Finjan
`
`
`
`Draft abstract regarding
`prosecution of U.S. Patent
`No. 8,677,494.
`
`Attorney-Client
`
`Location and Steps Taken For
`Confidentiality
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its prosecution counsel have
`carefully maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s
`prosecution counsel’s file.
`
`
`
`18
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 20 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Date
`
`From
`
`To
`
`CC
`
`Description
`
`Doc.
`No.
`22.
`
` 07/22/98 Bill Lyons
`
`John Roos
`
`23.
`
` 07/22/98 Bill Lyons
`
`John Roos
`
`24.
`
` 07/22/98 Bill Lyons
`
`John Roos
`
`
`
`
`
`
`
`Email regarding monthly
`analysis with attachment.
`
`Type of
`Privilege
`Attorney-Client
`
`Analysis forwarded to
`counsel.
`
`Attorney-Client
`
`Summary corporate
`document forwarded to
`counsel.
`
`Attorney-Client
`
`Location and Steps Taken For
`Confidentiality
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`
`
`
`19
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 21 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Date
`
`From
`
`To
`
`CC
`
`Description
`
`Doc.
`No.
`25.
`
` 10/30/98 Bill Lyons
`
`John Roos
`
`26.
`
` 10/30/98 Bill Lyons
`
`John Roos
`
`27.
`
` 12/08/98 Bill Lyons
`
`John Roos
`
`
`
`
`
`
`
`Email forwarding monthly
`corporate analysis.
`
`Type of
`Privilege
`Attorney-Client
`
`Analysis forwarded to
`counsel.
`
`Attorney-Client
`
`Email forwarding monthly
`corporate analysis to
`counsel.
`
`Attorney-Client
`
`Location and Steps Taken For
`Confidentiality
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`
`
`
`20
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 22 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Date
`
`From
`
`To
`
`CC
`
`Description
`
`Doc.
`No.
`28.
`
` 12/08/98 Bill Lyons
`
`John Roos
`
`29.
`
` 05/25/99 Bill Lyons
`
`John Roos
`George
`Middlemas
`Bret Maxwell
`yrc@star-ventures
`.combranganathan
`@apex.com
`
`
`
`
`
`Type of
`Privilege
`Attorney-Client
`
`Analysis forwarded to
`counsel.
`
`Email forwarding analysis. Attorney-Client
`
`Location and Steps Taken For
`Confidentiality
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`Finjan and its counsel have carefully
`maintained the confidentiality of this
`communication and have not publicly divulged
`its contents. This document is maintained in a
`password protected location. Given the strict
`controls in place for accessing the document,
`Finjan and its prosecution counsel are not
`aware of any unauthorized person having
`access to it. Collected from Finjan’s archive.
`
`30.
`
` 03/20/12 Brian Boyle
`
`Marcus Colucci
`
`
`
`Email regarding
`reexamination no.
`90/001,836.
`
`Attorney-Client
`
`
`
`21
`
`
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Doc.
`No.
`31.
`
` 05/03/99 Bruce M. Green
`
`Marc Sockol
`
`32.
`
` 06/04/99 Bruce M. Green
`
`Graham & James
`LLP
`
`33.
`
` 06/30/99 Bruce M. Green
`
`Katherine L.
`McEnroe
`
`
`
`
`
`
`
`Case 3:17-cv-05659-WHA Document 523-1 Filed 06/07/19 Page 23 of 823
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Date
`
`From
`
`To
`
`CC
`
`Description
`
`Type of
`Privilege
`Attorney-Client
`
`Letter regarding
`prosecution of Canadian
`Patent Application No.
`2275