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`Exhibit A
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`Case 3:18-cv-02621-WHO Document 264-2 Filed 03/27/20 Page 2 of 3
`
`July 25, 2018
`
`via email
`
`Paul Andre
`Kramer Levin Naftalis & Frankel LLP
`990 Marsh Road
`Menlo Park, CA 94025
`
`Orrick, Herrington & Sutcliffe LLP
`405 Howard Street
`San Francisco, CA 94105
`+1 415 773 5700
`orrick.com
`
`Clement Roberts
`
`E croberts@orrick.com
`D +1 415 773 5700
`F +1 415 773 5759
`
`Re:
`
`Finjan, Inc. v. Check Point Software Technologies, Inc.
`
`Dear Mr. Andre:
`
`I am writing to make the source code for the accused products in the above-entitled litigation available for
`inspection.
`
`Check Point is making the source code available pursuant to the Northern District of California’s Patent
`Local Rule 2-2 Interim Model Protective Order. To that end, the source code will be available on a secure
`computer with restricted read-write access in a room in which no other electronics will be permitted. If
`Finjan or its appointed expert would like to have a particular software review tool available for use for the
`inspection, please provide me with a licensed copy and we will have it installed (provided the tool does
`not compile any portion of the code).
`
`To arrange an inspection, please provide us with the following information: (1) the specific identity of the
`products Finjan would like to inspect on which days; (2) the dates on which Finjan would like to conduct
`the inspection for each identified product; and (3) the identity or identities of the expert or experts that
`Finjan intends to retain for inspection. Check Point reserves the right to object to Finjan’s identified expert
`or experts, and will require the inspection to be conducted on dates when Check Point’s engineers are
`available to oversee the production.
`
`In light of the fact that Check Point is making its source code available for inspection now, we expect your
`infringement contentions to include source code-specific citations for each element of each accused
`product, and will immediately move to compel if they do not.
`
`Sincerely,
`
`Clement Roberts
`
`
`
`Case 3:18-cv-02621-WHO Document 264-2 Filed 03/27/20 Page 3 of 3
`
`Paul Andre
`July 25, 2018
`Page 2
`
`
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