`
`EDWARD G. POPLAWSKI (SBN 113590)
`epoplawski@wsgr.com
`OLIVIA M. KIM (SBN 228382)
`okim@wsgr.com
`TALIN GORDNIA (SBN 274213)
`tgordnia@wsgr.com
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071
`Telephone: (323) 210-2900
`Facsimile: (866) 974-7329
`
`RYAN R. SMITH (SBN 229323)
`rsmith@wsgr.com
`CHRISTOPHER D. MAYS (SBN 266510)
`cmays@wsgr.com
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Telephone: (650) 493-9300
`Facsimile: (650) 493-6811
`
`Attorneys for Defendant
`QUALYS INC.
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`OAKLAND DIVISION
`
`CASE NO.: 4:18-cv-07229-YGR
`
`QUALYS’S RENEWED
`ADMINISTRATIVE MOTION TO
`FILE DOCUMENTS UNDER SEAL
`
`)))))))))))
`
`FINJAN, INC., a Delaware Corporation,
`
`Plaintiff,
`
`v.
`
`QUALYS INC., a Delaware Corporation,
`
`Defendant
`
`CASE NO. 4:18-cv-07229-YGR
`
`QUALYS’S RENEWED MOTION TO
`FILE DOCUMENTS UNDER SEAL
`
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`Case 4:18-cv-07229-YGR Document 108 Filed 09/24/20 Page 2 of 3
`
`I.
`
`INTRODUCTION
`Pursuant to the Court’s September 17, 2020 Order (ECF 106), Rule 26(c) of the Federal
`Rules of Civil Procedure, Civil Local Rule 79-5, and the Stipulated Protective Order, Defendant
`Qualys Inc. (“Qualys”) respectfully brings this Renewed Administrative Motion to File
`Documents Under Seal. Specifically, there are compelling reasons to file the following portions
`of the document under seal as identified below:
`
`Identification of Documents to be Sealed
`
`Finjan’s Exhibit 5 to Joint Discovery Statement (ECF 99-
`6 and 100-5), redacted portions at pp. 1-6, 8-20, 24-27,
`29-31, 33-36, 38-44, 47-95, 97-111.
`Finjan’s Exhibit 8 to Joint Discovery Statement (ECF 99-
`8 and 100-8), redacted portions at pp. 1-22.
`
`Entity That Designated
`the Information As
`Confidential
`Qualys
`
`Qualys
`
`II.
`
`ARGUMENT
`Qualys seeks to seal portions of documents that contain confidential information
`designated by Qualys as “Highly Confidential – Outside Counsels’ Eyes Only” as set forth in the
`above table. Qualys has narrowly tailored its request with this Renewed Administrative Motion
`seeking to file under seal only those portions of documents containing confidential information
`pursuant to the Stipulated Protective Order governing treatment of confidential information
`exchanged during discovery.
`Attached hereto are unredacted and redacted versions of the above-referenced documents.
`CONCLUSION
`Qualys has shown good cause and compelling reasons for this request to file the above-
`referenced portions of the documents under seal. This request is narrowly tailored to seal only
`information that is regarded as confidential. For these reasons, Qualys respectfully requests that
`the Court grant its Renewed Administrative Motion to File Documents Under Seal.
`
`III.
`
`CASE NO. 4:18-cv-07229-YGR
`
`-1-
`
`QUALYS’S RENEWED MOTION TO
`FILE DOCUMENTS UNDER SEAL
`
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`Case 4:18-cv-07229-YGR Document 108 Filed 09/24/20 Page 3 of 3
`
`DATED: September 24, 2020
`
`By:
`
`Respectfully submitted,
`
`/s/ Christopher D. Mays
`EDWARD G. POPLAWSKI (SBN 113590)
`epoplawski@wsgr.com
`OLIVIA M. KIM (SBN 228382)
`okim@wsgr.com
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071
`Telephone: (323) 210-2901
`Facsimile: (866) 974-7329
`
`RYAN R. SMITH (SBN 229323)
`rsmith@wsgr.com
`CHRISTOPHER D. MAYS (SBN 266510)
`cmays@wsgr.com
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Telephone: (650) 493-9300
`Facsimile: (650) 493-6811
`
`Counsel for Defendant
`QUALYS INC.
`
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`CASE NO. 4:18-cv-07229-YGR
`
`-2-
`
`QUALYS’S RENEWED MOTION TO
`FILE DOCUMENTS UNDER SEAL
`
`
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