throbber
Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 1 of 112
`
`Exhibit 6
`(FILED UNDER SEAL)
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 2 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`FINJAN, INC. V. JUNIPER NETWORKS, INC.
`
`CASE NO. 17-CV-05659-WHA
`
`Finjan, Inc.’s Amended May 14, 2019 Supplemental Redaction Log1
`May 17, 2019
`
`1 Plaintiff Finjan, Inc. expressly reserves the right to amend this redaction 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 523-2 Filed 06/07/19 Page 3 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`LIST OF NAMES AND AFFILIATIONS
`
`Name
`Aber, David
`ai@aipat.jp
`Anchell, Scott
`Andre, Paul
`arad@benchmark.com
`ATL Patent Docketing
`Avery, Stephen
`Ben-Itzhak, Yuval
`Benton, Gary
`Berger, Marc
`Bey, Dawn-Marie
`
`Bey Cotropia Docketing
`Blasik, Michele
`Boermeester, Ellen
`Bottomley, Christine
`Brandl, Sabine
`Brigaldino, Sylvia
`Brown, Nick
`Brunch, Linda
`Brunell, Linda
`
`Company
`Finjan Software, Inc. and/or its subsidiaries
`Ai Association of Patent and Trademark Attorneys
`Perkins Coie LLP
`King & Spalding LLP
`Benchmark Capital
`King & Spalding LLP
`Hoffmann Eitle
`Finjan Software, Inc. and/or its subsidiaries
`Coudert Brothers LLP
`Finjan Software, Inc. and/or its subsidiaries
`King & Spalding LLP
`Bey & Cotropia PLLC
`Bey & Cotropia PLLC
`King & Spalding LLP
`Eitan Law Group
`Finjan Software, Inc. and/or its subsidiaries
`Hoffmann Eitle
`Hoffmann Eitle
`Finjan Software, Inc. and/or its subsidiaries
`Eitan Law Group
`Eitan Law Group
`
`2
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 4 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`Byrne, Christopher
`Cain, Marcus
`Carr, DeFilippo & Ferrell LLP
`Castro, Sherry
`Chan, Mary
`Chin, Emily
`Clements, Julie
`Colb, Sanford T.
`colbpat@stc.co.il
`Conde, Sheema
`Cotropia, Christopher
`Coudert Brothers LLP
`danielle@finjan.com
`dc@bvp.com
`Dvornikova, Anna
`Dycaico, Peter
`Eitan, Tally
`Elazer, Uri
`Eitan Law Group
`Elbaz, Limor
`Evans, Terry
`Ferrell, John
`Feuer, Jeff
`
`Company
`Byrne, Christopher
`Finjan Software, Inc. and/or its subsidiaries
`Outside Counsel (United States)
`Perkine Coie LLP
`Perkins Coie LLP
`Landon-IP
`King & Spalding LLP
`Sanford T. Colb & Co.
`Sanford T. Colb & Co.
`CT Corporation System
`Bey & Cotropia PLLC
`Outside Counsel (Worldwide)
`Finjan Software, Inc. and/or its subsidiaries
`Bessemer Venture Partners
`Coudert Brothers LLP
`Coudert Brothers LLP
`Eitan Law Group
`Finjan Software, Inc. and/or its subsidiaries
`Outside Counsel (Israel)
`Finjan Software, Inc. and/or its subsidiaries
`King & Spalding LLP
`Carr, DeFilippo & Ferrell LLP
`Finjan Software, Inc. and/or its subsidiaries
`
`3
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`
`
`Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 5 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`Fine, Moshe
`Fipkin, Melanie
`Galvez, Byron
`Gassner, Tali
`Gibson, Carrie
`Gibson, Michael
`Gillis, Sally
`Goad, Terry
`Graham & James LLP
`Hannah, James
`Harris, Valerie
`Hite, Eppa
`Hoffmann, Martina
`Hunt, Amy
`Hunt-Grubbe, Henry
`Huylebroeck, Guy
`Iizuka, Yoshihito
`Iov, Rena
`Janikowski, Eileen
`King & Spalding LLP
`Kobialka, Lisa
`Kraitsman, Ron
`Levy, Jean
`
`Company
`Goldfarb, Levy, Eran & Co.
`Hoffmann Eitle
`Landon-IP
`Eitan Law Group
`Perkine Coie LLP
`King & Spalding LLP
`Eitan Law Group
`King & Spalding LLP
`Outside Counsel (United States)
`King & Spalding LLP
`Patents Ink
`Carr, DeFilippo & Ferrell LLP
`Hoffmann Eitle
`Landon-IP
`Hoffmann Eitle
`Finjan Software, Inc. and/or its subsidiaries
`Yoshihito Iizuka Patent and Trademark Attorney
`Perkins Coie LLP
`Squire, Sanders & Dempsey LLP
`Outside Counsel (United States)
`King & Spalding LLP
`Finjan Software, Inc. and/or its subsidiaries
`Sanford T. Colb & Co.
`
`4
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`
`
`Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 6 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`Liedtke, Laryssa
`Maack, Katrin
`Mahoney, Jennifer
`Malcolm, Gisela
`Martan, Oren
`Mayrhofer, Stefan
`Melcher, Esther
`michael@israelseed.com
`Milstein, Alex
`Moses, Joan
`Moshe, Louise
`Muller, Jasmin
`Oblon, Michael
`Offenbach, Jesse
`Paddison, Mandy
`Pammel, Celia
`Paolella-Bald, Jeanne
`
`Pavlovich, Relly
`Perkins Coie LLP
`Perkins Coie Client Intake
`Perkins Coie Docketing
`Pimenov, Yelena
`
`Company
`Hoffmann Eitle
`Hoffmann Eitle
`Perkins Coie LLP
`Hoffmann Eitle
`Finjan Software, Inc. and/or its subsidiaries
`Hoffmann Eitle
`Coudert Brothers LLP
`Israel Seed Partners
`Finjan Software, Inc. and/or its subsidiaries
`Wilson Sonsini Goodrich & Rosati
`Sanford T. Colb & Co.
`Hoffmann Eitle
`Perkins Coie LLP
`Perkins Coie LLP
`Hoffmann Eitle
`Perkins Coie LLP
`King & Spalding LLP
`Bey & Cotropia PLLC
`Kleinbendler & Halevy
`Outside Counsel (United States)
`Perkins Coie LLP
`Perkins Coie LLP
`Landon-IP
`
`5
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`
`
`Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 7 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`Polani, Asher
`Pruden, Andy
`Reisman, Sandy
`Richner, Matthew
`Roos, John
`Sanford T. Colb & Co.
`Schaab, Kate
`Schieber, Avihai
`Sears, Nick
`Sedlmayer, Elisabeth
`Shalom, Yaron
`Sherman, Vladimir
`Shippey, Dianne
`Siegert, Georg
`Smith, Jennifer
`Sockol, Marc
`
`Sophir, Eric
`Spilgies, Jan-Hendrik
`Sproston, David
`Stephan-Zelger, Brigitte
`Taylor, Marla
`Tersch, Glenn Von
`
`Company
`Finjan Software, Inc. and/or its subsidiaries
`The Walt Disney Company
`Perkins Coie LLP
`Perkins Coie LLP
`Wilson Sonsini Goodrich & Rosati
`Outside Counsel (Israel)
`Landon-IP
`Eitan Law Group
`Finjan Software, Inc. and/or its subsidiaries
`Hoffmann Eitle
`Finjan Software, Inc. and/or its subsidiaries
`Landon-IP
`Hoffmann Eitle
`Hoffmann Eitle
`Coudert Brothers LLP
`Squire, Sanders & Dempsey LLP
`Carr, DeFilippo & Ferrell LLP
`King & Spalding LLP
`Hoffmann Eitle
`Hoffmann Eitle
`Hoffmann Eitle
`Coudert Brothers LLP
`Perkins Coie LLP
`
`6
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`
`
`Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 8 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Name
`Tomeo, Charles
`Touboul, Shlomo
`Usoz, Linda Larson
`Warner, Tim
`Wiedemann, Peter
`Weisrose, Stuart
`Wininger, Aaron
`Yarborough, Sharon
`Yi, Sandra
`Yoshihito Iizuka Patent and Trademark Attorney
`Yusin, Robert
`
`Company
`Finjan Software, Inc. and/or its subsidiaries
`Finjan Software, Inc. and/or its subsidiaries
`Coudert Brothers LLP
`Finjan Software, Inc. and/or its subsidiaries
`Hoffmann Eitle
`Sanford T. Colb & Co.
`Squire, Sanders & Dempsey LLP
`Perkins Coie LLP
`Squire, Sanders & Dempsey LLP
`Outside Counsel (Japan)
`Finjan Software, Inc. and/or its subsidiaries
`
`7
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 9 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`
`
`Bates No.
`
`Date
`
`From
`
`To
`
`CC
`
`FINJAN-JN
`193996
`
`10/10/05 Yuval Ben-Itzhak
`
`Asher Polani
`
`FINJAN-JN
`340657
`
`11/10/11 Jeanne Paolella-
`Bald
`
`
`
`
`
`
`
`Description /
`Subject Matter / Purpose
`Email reflecting
`communications with
`counsel regarding Finjan’s
`patents.
`
`Memorandum regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`FINJAN-JN
`340658
`
`08/22/11 Yuval Ben-Itzhak
`
`Dawn-Marie Bey Marc Berger
`Jeanne Paolella-
`Bald
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`8
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client
`Work Product
`
`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.
`Attorney-Client 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.
`Attorney-Client 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.
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`
`
`Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 10 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Bates No.
`
`Date
`
`From
`
`To
`
`CC
`
`FINJAN-JN
`340659
`
`08/22/11 Dawn-Marie Bey
`
`Yuval Ben-Itzhak
`
`
`
`Description /
`Subject Matter / Purpose
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`FINJAN-JN
`340660
`
`12/21/10 Dawn-Marie Bey
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`Terry Goad
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`FINJAN-JN
`340661
`
`09/21/10 Eric Sophir
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`Terry Goad
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client 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.
`Attorney-Client 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.
`Attorney-Client 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.
`
`9
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`
`
`Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 11 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Bates No.
`
`Date
`
`From
`
`To
`
`CC
`
`FINJAN-JN
`340662
`
`12/11/09 Jeanne Paolella-
`Bald
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`
`Description /
`Subject Matter / Purpose
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`FINJAN-JN
`340663
`
`12/01/09 Dawn-Marie Bey
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`
`Email regarding
`assignment of patents and
`patent applications.
`
`FINJAN-JN
`340664
`
`10/07/09 Jeanne Paolella-
`Bald
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client 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.
`Attorney-Client 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.
`Attorney-Client 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.
`
`10
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`
`
`Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 12 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Bates No.
`
`Date
`
`From
`
`To
`
`CC
`
`FINJAN-JN
`340665
`
`07/23/09 Jeanne Paolella-
`Bald
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`
`Description /
`Subject Matter / Purpose
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`FINJAN-JN
`340666
`
`07/07/09 Eric Sophir
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`Terry Goad
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`FINJAN-JN
`340667
`
`07/07/09 Eric Sophir
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client 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.
`Attorney-Client 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.
`Attorney-Client 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.
`
`11
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`
`
`Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 13 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Bates No.
`
`Date
`
`From
`
`To
`
`FINJAN-JN
`340668
`
`06/19/09 Eric Sophir
`
`Marc Berger
`
`Description /
`Subject Matter / Purpose
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`CC
`
`Yuval Ben-
`Itzhak
`Dawn-Marie
`Bey
`Terry Goad
`
`FINJAN-JN
`340669
`
`06/17/09 Eric Sophir
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`Terry Goad
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`FINJAN-JN
`340670
`
`06/13/09 Eric Sophir
`
`Marc Berger
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`Dawn-Marie
`Bey
`Terry Goad
`Yuval Ben-
`Itzhak
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client 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.
`Attorney-Client 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.
`Attorney-Client 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 523-2 Filed 06/07/19 Page 14 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Bates No.
`
`Date
`
`From
`
`To
`
`FINJAN-JN
`340670
`
`06/13/09 Marc Berger
`
`Eric Sophir
`
`Description /
`Subject Matter / Purpose
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`CC
`
`Dawn-Marie
`Bey
`Terry Goad
`Yuval Ben-
`Itzhak
`
`06/12/09 Eric Sophir
`
`FINJAN-JN
`340670-71;
`FINJAN-JN
`340672
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`Terry Goad
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`FINJAN-JN
`340673
`
`05/27/09 Eric Sophir
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`Terry Goad
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client 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.
`Attorney-Client 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.
`Attorney-Client 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 523-2 Filed 06/07/19 Page 15 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Bates No.
`
`Date
`
`From
`
`To
`
`FINJAN-JN
`340674
`
`05/07/09 Eric Sophir
`
`Marc Berger
`
`Description /
`Subject Matter / Purpose
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`CC
`
`Yuval Ben-
`Itzhak
`Dawn-Marie
`Bey
`Terry Goad
`
`FINJAN-JN
`340674
`
`05/07/09 Marc Berger
`
`Dawn-Marie Bey Yuval Ben-
`Itzhak
`Terry Goad
`Eric Sophir
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`FINJAN-JN
`340674-75
`
`05/06/09 Marc Berger
`
`Eric Sophir
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`Dawn-Marie
`Bey
`Yuval Ben-
`Itzhak
`Terry Goad
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client 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.
`Attorney-Client 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.
`Attorney-Client 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 523-2 Filed 06/07/19 Page 16 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Bates No.
`
`Date
`
`From
`
`To
`
`FINJAN-JN
`340675
`
`05/06/09 Eric Sophir
`
`Marc Berger
`
`Description /
`Subject Matter / Purpose
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`CC
`
`Dawn-Marie
`Bey
`Yuval Ben-
`Itzhak
`Terry Goad
`
`FINJAN-JN
`340675
`
`05/06/09 Marc Berger
`
`Dawn-Marie Bey Eric Sophir
`Terry Goad
`Yuval Ben-
`Itzhak
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`FINJAN-JN
`340676
`
`05/03/09 Dawn-Marie Bey
`
`Yuval Ben-Itzhak
`Marc Berger
`
`Dawn-Marie
`Bey
`Eric Sophir
`Terry Goad
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,079,086.
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client 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.
`Attorney-Client 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.
`Attorney-Client 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 523-2 Filed 06/07/19 Page 17 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Bates No.
`
`Date
`
`From
`
`To
`
`CC
`
`FINJAN-JN
`341583
`
`06/29/10 Terry Goad
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`Eric Sophir
`
`FINJAN-JN
`341584
`
`06/24/10 Michele Blasik
`
`FINJAN-JN
`341584
`
`06/24/10 Terry Goad
`
`
`
`
`
`Dawn-Marie Bey
`Eric Sophir
`Jeanne Paolella-
`Bald
`Terry Goad
`
`Dawn-Marie Bey
`Eric Sophir
`Jeanne Paolella-
`Bald
`
`Description /
`Subject Matter / Purpose
`Email regarding
`prosecution of U.S. Patent
`No. 8,141,154.
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,141,154.
`
`Email regarding
`prosecution of U.S. Patent
`No. 8,141,154.
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client 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.
`Attorney-Client 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.
`Attorney-Client 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 523-2 Filed 06/07/19 Page 18 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Bates No.
`
`Date
`
`From
`
`To
`
`CC
`
`FINJAN-JN
`341584
`
`06/24/10 Terry Goad
`
`
`
`Michele Blasik
`Dawn-Marie Bey
`Eric Sophir
`Jeanne Paolella-
`Bald
`
`Description /
`Subject Matter / Purpose
`Email regarding
`prosecution of U.S. Patent
`No. 8,141,154.
`
`FINJAN-JN
`342425
`
`12/01/09 Dawn-Marie Bey
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`
`Email regarding
`assignment of patents and
`patent applications.
`
`FINJAN-JN
`342743
`
`12/01/09 Dawn-Marie Bey
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie Bey
`
`Email regarding
`assignment of patent
`applications and patents.
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client 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.
`Attorney-Client 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.
`Attorney-Client 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 523-2 Filed 06/07/19 Page 19 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`
`
`Bates No.
`
`Date
`
`From
`
`FINJAN-JN
`342744
`
`05/26/09 Dawn-Marie Bey
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client 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.
`Attorney-Client 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.
`Attorney-Client 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.
`
`To
`
`CC
`
`Description /
`Subject Matter / Purpose
`Yuval Ben-Itzhak Dawn-Marie Bey Email regarding
`reexamination of Patent
`No. 6,092,194.
`
`FINJAN-JN
`342744
`
`06/01/09 Dawn-Marie Bey
`
`Yuval Ben-Itzhak Paul Andre
`Lisa Kobialka
`Dawn-Marie Bey
`Marc Berger
`
`Email regarding
`reexamination of Patent
`No. 6,092,194.
`
`FINJAN-JN
`342744
`
`06/02/09 Dawn-Marie Bey
`
`Terry Goad
`
`
`
`Email regarding
`reexamination of Patent
`No. 6,092,194.
`
`18
`
`UNREDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
`
`

`

`
`
`Case 3:17-cv-05659-WHA Document 523-2 Filed 06/07/19 Page 20 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Bates No.
`
`Date
`
`From
`
`To
`
`CC
`
`FINJAN-JN
`342744-45
`
`05/24/09 Yuval Ben-Itzhak Dawn-Marie Bey
`
`
`
`Description /
`Subject Matter / Purpose
`Email regarding
`reexamination of Patent
`No. 6,092,194.
`
`FINJAN-JN
`342746
`
`01/27/09 Dawn-Marie Bey
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie Bey
`Jeanne Paolella-
`Bald
`
`Email regarding
`reexamination of Patent
`No. 6,092,194.
`
`FINJAN-JN
`342746
`
`01/29/09 Dawn-Marie Bey
`
`Terry Goad
`Jeanne Paolella-
`Bald
`
`
`
`Email regarding
`reexamination of Patent
`No. 6,092,194.
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client 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.
`Attorney-Client 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.
`Attorney-Client 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 523-2 Filed 06/07/19 Page 21 of 112
`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`Bates No.
`
`Date
`
`From
`
`FINJAN-JN
`343313
`
`06/24/10 Jeanne Paoella-
`Bald
`
`To
`
`Terry Goad
`
`CC
`
`Dawn-Marie
`Bey
`
`Description /
`Subject Matter / Purpose
`Email regarding
`prosecution of U.S. Patent
`No. 7,757,289.
`
`FINJAN-JN
`343314
`
`05/28/10 Jeanne Paoella-
`Bald
`
`Yuval Ben-Itzhak Marc Berger
`Dawn-Marie
`Bey
`
`Email regarding
`prosecution of U.S. Patent
`No. 7,757,289.
`
`FINJAN-JN
`343315
`
`05/27/10 Dawn-Marie Bey
`
`Jeanne Paoella-
`Bald
`
`
`
`Email regarding
`prosecution of U.S. Patent
`No. 7,757,289.
`
`Location and Steps Taken For Confidentiality
`
`Type of
`Privilege
`Attorney-Client Finjan and its co

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