`
`
`
`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
`
`FINJAN, INC., a Delaware Corporation,
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
`
`
`
`
`
`
`Defendant.
`
`
`Case No.: 3:17-cv-05659-WHA
`
`PLAINTIFF FINJAN, INC.’S
`ADMINISTRATIVE MOTION TO FILE
`DOCUMENTS UNDER SEAL
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`FINJAN’S ADMIN. MOTION TO FILE DOCUMENTS
`UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
`
`
`
`Case 3:17-cv-05659-WHA Document 90 Filed 05/31/18 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 Under Seal. The documents identified
`
`below contain confidential information of Juniper Networks, Inc. (“Juniper”). Finjan relies on Juniper’s
`
`confidentiality designation. Specifically, there exists good cause and compelling reasons to file the
`
`following documents under seal:
`
`
`Identification of Documents to be Sealed
`
`Plaintiff Finjan Inc.’s Motion for Leave to File Second
`Amended Complaint at page 3, lines 17-20; page 6, lines 1, 3
`Declaration of Kristopher Kastens (“Kastens Decl.”), Ex. 2
`(excerpts from deposition transcript of Ms. Yuly Tenorio) in
`its entirety.
`Kastens Decl., Ex. 1 (“Second Amended Complaint”) at
`¶¶132–136
`Kastens Decl., Ex. 5 (Redline of Second Amended
`Complaint) at ¶¶132–136.
`Exs. 33 and 34 to the Second Amended Complaint
`II.
`ARGUMENT
`
`Entity that Designated the
`Information to be
`Confidential
`
`Juniper
`
`Juniper
`
`Juniper
`
`Juniper
`
`Juniper
`
`This Administrative Motion to File Documents Under Seal should be granted because there is
`
`good cause and compelling reasons to seal the identified documents. Finjan seeks to seal only those
`
`documents and portions of documents that Juniper has identified as containing confidential information
`
`pursuant to the Interim Model Protective Order.
`
`Finjan seeks to seal Finjan’s Motion for Leave to File Second Amended Complaint redacted
`
`portions at page 3, lines 17-20 and page 6, lines 1, 3 because, as set forth in the accompanying
`
`declaration of Kristopher Kastens in Support of this Administrative Motion (“Kastens Sealing
`
`Declaration”), these portions contain information that Juniper has designated as “Highly Confidential –
`
`Attorneys’ Eyes Only.”
`
`Finjan seeks to seal Exhibits 1, 2, 5 to the Kastens Declaration and Exhibits 33 and 34 to the
`
`Second Amended Complaint because, as set forth in the accompanying Kastens Sealing Declaration,
`
`these documents contain information that Juniper has designated as “Highly Confidential – Attorneys’
`
`1
`FINJAN’S ADMIN. MOTION TO FILE DOCUMENTS
`UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
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`Case 3:17-cv-05659-WHA Document 90 Filed 05/31/18 Page 3 of 3
`
`
`
`Eyes Only” or “Highly Confidential – Source Code.”
`
`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 its Administrative
`
`Motion to File Documents Under Seal.
`
`
`
`Dated: May 31, 2018
`
`
`
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`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 DOCUMENTS
`UNDER SEAL
`
`CASE NO.: 3:17-cv-05659-WHA
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