`
`
`
`PAUL J. ANDRE (State Bar No. 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (State Bar No. 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (State Bar No. 237978)
`jhannah@kramerlevin.com
`KRISTOPHER KASTENS (State Bar No. 254797)
`kkastens@kramerlevin.com
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`
`
`Case No.: 3:17-cv-05659-WHA-TSH
`
`PLAINTIFF FINJAN, INC.’S
`ADMINISTRATIVE MOTION TO FILE
`DOCUMENTS UNDER SEAL
`
`
`FINJAN, INC., a Delaware Corporation,
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
`
`
`
`
`
`
`Defendant.
`
`1 2 3 4 5 6 7 8 9
`
`10
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`
`FINJAN’S ADMIN. MOTION TO FILE CASE NO.: 3:17-cv-05659-WHA-TSH
`DOCUMENTS UNDER SEAL
`
`
`
`Case 3:17-cv-05659-WHA Document 531 Filed 06/14/19 Page 2 of 3
`
`
`
`I.
`
`INTRODUCTION
`Pursuant to Federal Rule of Civil Procedure 26(c), Civil Local Rules 7-11 and 79-5, Plaintiff,
`Finjan, Inc. (“Finjan”), brings this Administrative Motion to File Documents Under Seal for the
`documents identified below, which contain confidential information of Juniper. Specifically, there exist
`good cause and compelling reasons to file the following document under seal:
`
`
`Identification of Documents to be Sealed
`
`Exhibit A to the Joint Discovery Letter Related to Source
`Code Review Tools.
`
`
`
`Entity that Designated the
`Information to be
`Confidential
`Defendant Juniper Networks,
`Inc. (“Juniper”)
`
`II.
`
`ARGUMENT
`This Administrative Motion to File Documents Under Seal should be granted because good
`cause and compelling reasons exist to seal the documents identified above. Finjan seeks to seal only
`those documents and portions of documents that Juniper identified as containing confidential
`information pursuant to the Protective Order.
`Finjan seeks to seal Exhibits A to the Joint Discovery Letter Related to Source Code Review
`Tools, because this Exhibit contains information that Juniper has designated as “Highly Confidential –
`Attorneys’ Eyes Only.” Specifically, this information contains descriptions of Juniper’s financial
`information and technical data, the public disclosure of which Juniper claims could harm its business.
`Pursuant to Civil Local Rule 79-5, Finjan has filed publicly the relevant excerpts of information
`that are not confidential. Attached hereto are redacted and unredacted versions of the documents set
`forth above.
`III. CONCLUSION
`For the foregoing reasons, Finjan respectfully requests that the Court grant this Administrative
`Motion to File Documents Under Seal.
`
`
`1
`FINJAN’S ADMIN. MOTION TO FILE CASE NO.: 3:17-cv-05659-WHA-TSH
`DOCUMENTS UNDER SEAL
`
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`
`
`
`Case 3:17-cv-05659-WHA Document 531 Filed 06/14/19 Page 3 of 3
`
`
`
`
`
`Dated: June 14, 2019
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`By: /s/ Kristopher Kastens____________
`Paul J. Andre (State Bar No. 196585)
`Lisa Kobialka (State Bar No. 191404)
`James Hannah (State Bar No. 237978)
`Kristopher Kastens (State Bar No. 254797)
`KRAMER LEVIN NAFTALIS
`& FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`pandre@kramerlevin.com
`lkobialka@kramerlevin.com
`jhannah@kramerlevin.com
`kkastens@kramerlevin.com
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`
`
`
`
`
`
`2
`FINJAN’S ADMIN. MOTION TO FILE CASE NO.: 3:17-cv-05659-WHA-TSH
`DOCUMENTS UNDER SEAL
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
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`
`
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