`
`
`
`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
`
`SECOND DECLARATION OF STEFAN
`BUEHLMANN IN SUPPORT OF
`MOTION TO FILE UNDER SEAL (DKT
`513)
`
`
`
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`
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`
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`I, Stefan Buehlmann, hereby state the following under oath:
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`2.
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`3.
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`4.
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`5.
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`I live in Witterswil, Switzerland.
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`I am the General Manager of Joe Security LLC ("Joe Security").
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`Joe Security is a Swiss entity located in Reinach, Switzerland.
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`I have been involved in computer security and malware detection for 15 years.
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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, called the Joe Sandbox system that enables users
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`to detect and analyze computer viruses and malware threats.
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`6. We carefully 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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`customers is limited. Our customer list is confidential.
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`7.
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`All of our business and governmental partners agree to strict confidentiality
`
`restrictions as a condition of using our solution.
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`Case 3:17-cv-05659-WHA Document 524-1 Filed 06/07/19 Page 2 of 2
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`8.
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`Our customers install our solution into their computer infrastructure to help protect
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`against malware threats.
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`9.
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`Juniper Networks, the defendant in this case, is one of our customers.
`
`10.
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`In his deposition dated February 7, 2019, Khurram Islah, a software developer for
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`Juniper Networks described the technical details of Joes Security’s Joe Sandbox system. The
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`testimony and descriptions of the Joe Sandbox system in the Islah deposition are trade secrets and
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`highly confidential information of Joe Security.
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`11. As a company that focuses on computer malware, we know that the efficacy of our
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`product could be immediately, directly and completely compromised if the information in the Islah
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`deposition is made public. Hackers would be able to use this information to modify their malware to
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`circumvent our malware detection and prevention system.
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`12. We would prefer that no part of the Islah deposition be made public. Public disclosure
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`of the descriptions and technical details in the deposition would compromise the efficacy of our
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`malware prevention product.
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`13.
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`In the event that the Court declines to allow the deposition sealed in its entirety, we
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`would request the opportunity to redact the confidential references (although I estimate the redactions
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`would be substantially more than 50% of the deposition transcript).
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`I declare under the pains and penalties of perjury that the foregoing is true and correct this 7th day of
`June, 2019.
`
`Stefan Buehlmann
`
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