Case 3:17-cv-05659-WHA Document 95-1 Filed 06/07/18 Page 1 of 4
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`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Joshua P. Glucoft (SBN 301249)
`jglucoft@irell.com
`Casey Curran (SBN 305210)
`ccurran@irell.com
`Sharon Song (SBN 313535)
`ssong@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`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
`
`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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`FINJAN, INC.,
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`Plaintiff,
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`Case No. 3:17-cv-05659-WHA
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`DECLARATION OF SHARON SONG IN
`SUPPORT OF JUNIPER NETWORKS,
`INC.’S MOTION FOR
`ADMINISTRATIVE RELIEF TO FILE
`DOCUMENTS UNDER SEAL
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`
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`DECLARATION OF SHARON SONG ISO JUNIPER’S
`MOTION FOR ADMINISTRATIVE RELIEF
`TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
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`JUNIPER NETWORKS, INC.,
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`vs.
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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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`10125765
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`
`

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`Case 3:17-cv-05659-WHA Document 95-1 Filed 06/07/18 Page 2 of 4
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`DECLARATION OF SHARON SONG
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`I, Sharon Song, declare as follows:
`1.
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`I am an attorney at the law firm of Irell & Manella LLP, counsel of record for
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`Juniper Networks, Inc. (“Juniper”) in the above-captioned matter. I am a member in good
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`standing of the State Bar of California and have been admitted to practice before this Court. I
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`have personal knowledge of the facts set forth in this Declaration and, if called as a witness, could
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`and would testify competently to such facts under oath.
`2.
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`I submit this declaration in support of Juniper’s June 7, 2018 Motion for
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`Administrative Relief to File Documents Under Seal, which asks the Court for an Order to file
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`under seal the following documents:
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` Juniper’s unredacted Motion for Summary Judgment Regarding Claim 1 of U.S. Patent
`No. 6,804,780 (the “Brief”);
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` Exhibit 5 to the Brief (excerpts from the deposition transcript of Finjan employee John
`Garland);
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` Unredacted Exhibit 6 to the Brief (excerpts from the deposition transcript of Juniper
`employee Raju Manthena);
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` Unredacted Exhibit 7 to the Brief (excerpts from Juniper’s Notice of Specific Unmarked
`Products under Arctic Cat, Inc. v. Bombardier Recreational);
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` Exhibit 8 to the Brief (excerpts from Finjan’s Objections and Responses to Juniper’s First
`Set of Interrogatories);
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` Exhibit 19 to the Brief (excerpts from Finjan’s First Supplemental Objections and
`Responses to Juniper’s First Set of Interrogatories);
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` Unredacted Declaration of Ariel D. Rubin in support of the Brief;
` Unredacted Declaration of Rebecca Carson in support of the Brief;
` Unredacted Declaration of Yuly Nerida Becerra Tenorio in support of the Brief.
`3.
`The sealed portions of the documents described above that Juniper seeks to file
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`under seal contain confidential information of Juniper and Finjan. In this declaration, I explain
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`why these materials are sealable pursuant to Civil Local Rule 79-5.
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10125765
`
`
`- 1 -
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`DECLARATION OF SHARON SONG ISO JUNIPER’S
`MOTION FOR ADMINISTRATIVE RELIEF
`TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`

`

`Case 3:17-cv-05659-WHA Document 95-1 Filed 06/07/18 Page 3 of 4
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`4.
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`Exhibit 5 to the Brief are excerpts of the deposition transcript of Finjan employee
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`John Garland that have been designated confidential by Finjan.
`5.
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`The redacted portions of Exhibit 6 to the Brief are excerpts of the deposition
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`transcript of Juniper employee Raju Manthena that include discussion of Juniper’s confidential
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`technical information related to Juniper’s highly proprietary software.
`6.
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`The redacted portions of Exhibit 7 to the Brief are excerpts from Juniper’s Notice
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`of Specific Unmarked Products under Arctic Cat, Inc. v. Bombardier Recreational that have been
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`designated confidential by Finjan.
`7.
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`Exhibit 8 to the Brief are excerpts from Finjan’s Objections and Responses to
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`Juniper’s First Set of Interrogatories that have been designated confidential by Finjan.
`8.
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`Exhibit 19 to the Brief are excerpts from Finjan’s First Supplemental Objections
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`and Responses to Juniper’s First Set of Interrogatories that have been designated confidential by
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`Finjan.
`9.
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`The redacted portion of the Declaration of Ariel D. Rubin in support of the Brief
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`comprised of the last two lines of paragraph 96 has been designated confidential by Finjan. All
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`other redacted portions of the Declaration of Ariel D. Rubin include discussion of Juniper’s
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`confidential technical information related to Juniper’s highly proprietary software.
`10.
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`The redacted portions of the Declaration of Yuly Nerida Becerra Tenorio in support
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`of the Brief include discussion of Juniper’s confidential technical information related to Juniper’s
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`highly proprietary software.
`11.
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`The redacted portions of the Declaration of Rebecca Carson in support of the Brief
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`include discussion of Juniper’s confidential financial information related to Juniper’s highly
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`proprietary software.
`12.
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`The redacted portions of the Brief directly reference the confidential materials
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`discussed above. The redacted portions of the Brief at 24:26-25:3 and 25:7-15 have been
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`designated confidential by Finjan. All other redacted portions of the Brief include discussion of
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`Juniper’s confidential technical information related to Juniper’s highly proprietary software.
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10125765
`
`
`- 2 -
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`DECLARATION OF SHARON SONG ISO JUNIPER’S
`MOTION FOR ADMINISTRATIVE RELIEF
`TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`

`

`Case 3:17-cv-05659-WHA Document 95-1 Filed 06/07/18 Page 4 of 4
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`13.
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`The redacted portions of Exhibits 6; the redacted portions of the Declarations of
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`Rebecca Carson, Ariel D. Rubin (excluding the last two lines of paragraph 96), and Yuly Nerida
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`Becerra; and the redacted portions of the Brief (excluding the redactions at 24:26-25:3 and 25:7-
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`15) contain sealable confidential information that relate to the technical underpinnings and
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`development of Juniper’s highly proprietary software—which includes much information that
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`Juniper maintains as trade secrets. Juniper expends significant effort in maintaining the secrecy of
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`its software architecture and development, including, for example, implementing strict screening
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`procedures for visitors to its engineering campus. Public disclosure of essential nonpublic facts
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`about Juniper’s software development could materially impair Juniper’s intellectual property
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`rights and could cause serious competitive consequences to Juniper’s business positioning.
`14.
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`Exhibits 5, 8, and 19; the redacted portions of Exhibit 7; the redacted portions of
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`the Brief at 24:26-25:3 and 25:7-15; and the redacted portion of the Declaration of Ariel D. Rubin
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`comprised of the last two lines of paragraph 96 were designated confidential by Finjan.
`15.
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`For these reasons, the documents described above should be filed under seal.
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`15
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`Executed on June 7, 2018, at Los Angeles, California.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct to the best of my knowledge.
`
` /s/ Sharon Song
` Sharon Song
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`10125765
`
`
`- 3 -
`
`DECLARATION OF SHARON SONG ISO JUNIPER’S
`MOTION FOR ADMINISTRATIVE RELIEF
`TO FILE DOCUMENTS UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`