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`Case 3:17-cv-05659-WHA Document 55 Filed 04/13/18 Page 1 of 2
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`IRELL & MANELLA LLP
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`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Joshua P. Glucoft (SBN 301249)
`jglucoft@irell.com
`Casey Curran (SBN 305210)
`ccurran@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
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`Rebecca L. Carson (SBN 254105)
`rcarson@irell.com
`Kevin Wang (SBN 318024)
`kwang@irell.com
`840 Newport Center Drive, Suite 400
`Newport Beach, California 92660-6324
`Telephone: (949) 760-0991
`Facsimile: (949) 760-5200
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`Attorneys for Defendant
`JUNIPER NETWORKS, INC.
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCISCO DIVISION
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`Case No. 3:17-cv-05659-WHA
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`NOTICE REGARDING STATUS OF
`PROTECTIVE ORDER
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`
`Hon. William H. Alsup
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`NOTICE REGARDING STATUS OF PROTECTIVE ORDER
`Case No. 3:17-cv-05659-WHA
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`FINJAN, INC.,
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`Plaintiff,
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`v.
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`JUNIPER NETWORKS, INC.,
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`Defendant.
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
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`10488399
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`
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`Case 3:17-cv-05659-WHA Document 55 Filed 04/13/18 Page 2 of 2
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`NOTICE REGARDING STATUS OF PROTECTIVE ORDER
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`Defendant Juniper Networks, Inc. (“Juniper”) respectfully provides this Notice to the Court
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`regarding the status of the parties’ negotiation of a stipulated Protective Order. Attached hereto is
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`the most recent version of the parties’ negotiated Protective Order. As of the filing of this Notice,
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`there are only three outstanding provisions with competing proposals: (i) Section 2.7 regarding the
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`definition of “Expert”; (ii) Section 2.9 regarding the definition of “source code”; and (iii) Section
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`8 regarding the prosecution bar. In each case, Juniper proposes adopting the Model Protective
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`Order while plaintiff Finjan, Inc. (“Finjan”) proposes deviating from the Model Protective Order.
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`This Notice is not a joint submission, as Finjan did not agree to submit the Protective
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`Order in its current state because Finjan indicated that it may have additional compromise
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`proposals. The parties will confer to try to reduce the number of outstanding issues and will notify
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`the Court if the parties are able to reach resolution. However, the parties have been conferring
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`regarding the Protective Order for nearly two months and the deadline by which the parties had
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`agreed to submit a proposed Protective Order has long since passed. See Dkt. No. 31 at p. 8 (“The
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`parties intend to file the stipulated Protective Order (with competing provisions if necessary) by
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`March 5, 2018.”). This Notice is therefore provided to keep the Court apprised of all relevant
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`By:
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`Respectfully submitted,
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`IRELL & MANELLA LLP
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`/s/ Joshua Glucoft
`Joshua Glucoft
`Attorneys for Defendant
`Juniper Networks, Inc.
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`information.
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`Dated: April 13, 2018
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
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`10488399
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`- 1 -
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`NOTICE REGARDING STATUS OF PROTECTIVE ORDER
`Case No. 3:17-cv-05659-WHA
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