`
`
`Philip C. Swain (SBN 150322)
`pswain@foleyhoag.com
`FOLEY HOAG LLP
`155 Seaport Boulevard
`Boston MA 02210
`Telephone: 617-732-1000
`Facsimile: 617-832-7000
`
`Attorneys for Non-Party Joe Security, LLC
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`
`FINJAN, INC.
`
`
`
`
`Plaintiff,
`
`vs.
`
`JUNIPER NETWORKS, INC.
`
`Defendant.
`
`
`
`Case No. C 17-05659 WHA
`
`NON-PARTY JOE SECURITY, LLC’S
`SUBMISSION IN SUPPORT OF
`MOTION TO FILE UNDER SEAL (DKT
`513)
`
`
`
`
`
`
`Non-party Joe Security, LLC (“Joe Security”) hereby submits the attached Second
`
`Declaration of Stefan Buehlmann explaining the confidential nature and trade secret status of the
`
`Joe Security information included in the deposition of Khurrah Islah.1 Mr. Islah is a software
`
`developer at Juniper Networks who is familiar with Juniper’s use of the Joe Security’s Joe
`
`Sandbox system, a malware analysis and detection system. Mr. Islah’s deposition testimony
`
`describes the confidential and trade secret details of Joe Security’s Joe Sandbox product
`
`throughout the deposition. See Bühlmann Decl., ¶¶ 10, 11 (Exhibit 1 hereto).
`
`Joe Security respectfully requests that this Court allow the Islah deposition to be filed
`
`under seal. In the alternative, Joe Security requests that the Court allow Joe Security to redact
`
`
`
`1 Joe Security is not a party to this action and has no presence in California. Joe Security is appearing for the limited
`reason of establishing the trade secret status and highly confidential nature of its information in the Islah deposition,
`and expressly contests personal jurisdiction in this Court.
`
`_____________________________________________________________________________
`NON-PARTY JOE SECURITY’S SUBMISSION IN SUPPORT OF MOTION TO FILE UNDER SEAL – CASE
`NO. C17-05659 WHA
`
`
`
`B5000430.1
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`Case 3:17-cv-05659-WHA Document 524 Filed 06/07/19 Page 2 of 3
`
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`the most sensitive information from the transcript, which will likely be more than 50% of the
`
`transcript.
`
`CONCLUSION
`
`Joe Security submits that the foregoing presents “compelling reasons” sufficient to justify
`
`having the Islah transcript filed under seal, and respectfully request that the motion to file under
`
`seal be granted.
`
`Dated: June 7, 2019 Respectfully submitted,
`
`JOE SECURITY, LLC
`
`
`
`
`
`by its attorneys,
`
`_s/Philip C. Swain____
`Phillip C. Swain
`FOLEY HOAG LLP
`155 Seaport Boulevard
`Boston, MA 02210
`Tel: (617) 832-1000
`Fax: (617) 832-7000
`pswain@foleyhoag.com
`
`
`
`
`
`
`
`
`
`_____________________________________________________________________________
`NON-PARTY JOE SECURITY’S SUBMISSION IN SUPPORT OF MOTION TO FILE UNDER SEAL – CASE
`NO. C17-05659 WHA
`
`
`
`B5000430.1
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`Case 3:17-cv-05659-WHA Document 524 Filed 06/07/19 Page 3 of 3
`
`
`
`CERTIFICATE OF SERVICE
`
`I certify that this document filed through the ECF system will be sent electronically to
`the registered participants as identified on the Notice of Electronic Filing (NEF) and paper
`copies will be sent to those indicated as non-registered participants, if any, on this 7th day of
`June, 2019.
`
`/s/ Philip C. Swain
`
`_____________________________________________________________________________
`NON-PARTY JOE SECURITY’S SUBMISSION IN SUPPORT OF MOTION TO FILE UNDER SEAL – CASE
`NO. C17-05659 WHA
`
`
`
`B5000430.1
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