`Case 3:17-cv-05659-WHA Document 77-6 Filed 05/01/18 Page 1 of 3
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`Case 3:17-cv-05659-WHA Document 77-6 Filed 05/01/18 Page 2 of 3
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`Song, Sharon
`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`Attachments:
`
`~Kastens, Kristopher
`Monday, February 12, 2018 4:17 PM
`Glucoft, Josh
`~Andre, Paul; ~Kobialka, Lisa; ~Hannah, James; Kagan, Jonathan; Carson, Rebecca;
`Hefazi, Nima; ~Manes, Austin
`RE: Finjan v. Juniper - Draft CMC Statement
`Finjan Edits CMC Statement. to JUNIPER
`EDITS_Finjan_v_Juniper_-_Draft_CMC_Statement - local.VO-1.pdf; Finjan Edits CMC
`Statement.docx
`
`Josh,
`
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`Finjan’s edits to the CMC statement are attached. Regarding electronic service, we are unable to agree to a blind email
`alias because of confidentiality issues. Please list the email addresses you would like us to use instead. We will also
`review the E‐discovery order and will provide edits later in the week. Further, Finjan is not filing a motion to amend its
`complaint related to willfulness, making Juniper’s request to witness names and dates moot.
`
` am available tomorrow afternoon and Wednesday morning for a call if needed.
`
`
`Sincerely,
`Kris
`
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`
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`Kris Kastens
`Associate
`
`
`Kramer Levin Naftalis & Frankel LLP
`990 Marsh Road, Menlo Park, California 94025
`T 650.752.1715 F 650.752.1815
`
`This communication (including any attachments) is intended solely for the recipient(s) named above and may contain information that is
`confidential, privileged or legally protected. Any unauthorized use or dissemination of this communication is strictly prohibited. If you have received
`this communication in error, please immediately notify the sender by return e-mail message and delete all copies of the original communication.
`Thank you for your cooperation.
`
`
`
`From: Glucoft, Josh [mailto:JGlucoft@irell.com]
`Sent: Tuesday, February 06, 2018 2:29 PM
`To: Manes, Austin
`Cc: Andre, Paul; Kobialka, Lisa; Hannah, James; Kastens, Kris; Kagan, Jonathan; Carson, Rebecca; Hefazi, Nima;
`#Juniper/Finjan [Int]
`Subject: [EXTERNAL] RE: Finjan v. Juniper - Draft CMC Statement
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`Austin,
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` I
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`1
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`Case 3:17-cv-05659-WHA Document 77-6 Filed 05/01/18 Page 3 of 3
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`Attached please find a revised draft of the joint CMC statement, along with a PDF redline showing changes from your
`original draft to our revised version. Some changes were necessary because Judge Alsup does not conduct a separate
`claim construction hearing, so your two-step approach to narrowing asserted claims, for example, would not work.
`
`
`Attached please also find our proposed e-discovery order, which largely follows N.D. Cal.’s model e-discovery order for
`patent cases.
`
`
`Please let us know if you would like to discuss further.
`
`
`Best,
`Josh
`
`
`From: Manes, Austin [mailto:AManes@KRAMERLEVIN.com]
`Sent: Tuesday, January 30, 2018 9:22 AM
`To: Kagan, Jonathan; Glucoft, Josh; Carson, Rebecca; Hefazi, Nima
`Cc: Andre, Paul; Kobialka, Lisa; Hannah, James; Kastens, Kris
`Subject: Finjan v. Juniper - Draft CMC Statement
`
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`All,
`
`
`Please see the attached draft joint CMC statement and let us know if you have any edits.
`
`
`Thanks,
`Austin
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`
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`Austin Manes
`Associate
`
`
`Kramer Levin Naftalis & Frankel LLP
`990 Marsh Road, Menlo Park, California 94025
`T 650.752.1718
`amanes@kramerlevin.com
`
`
`Bio
`
`This communication (including any attachments) is intended solely for the recipient(s) named above and may contain information that is
`confidential, privileged or legally protected. Any unauthorized use or dissemination of this communication is strictly prohibited. If you have received
`this communication in error, please immediately notify the sender by return e-mail message and delete all copies of the original communication.
`Thank you for your cooperation.
`
`
`
`
`PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside
`information. Any distribution or use of this communication by anyone other than the intended recipient(s) is
`strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender by
`replying to this message and then delete it from your system. Thank you.
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