`
`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) 210-2900
`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
`
`DECLARATION OF CHRISTOPHER
`MAYS IN SUPPORT OF
`ADMINISTRATIVE MOTION TO
`FILE DOCUMENTS UNDER SEAL
`
`)))))))))))
`
`FINJAN, INC.,
`
`Plaintiff,
`
`v.
`
`QUALYS INC.,
`
`Defendant.
`
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`CASE NO. 4:18-cv-07229-YGR
`
`DECLARATION OF CHRISTOPHER MAYS
`
`
`
`Case 4:18-cv-07229-YGR Document 108-1 Filed 09/24/20 Page 2 of 3
`
`I, Christopher Mays, declare as follows:
`1.
`I am an attorney with the law firm of Wilson, Sonsini, Goodrich, & Rosati
`(“WSGR”), counsel of record for Defendant Qualys Inc. (“Qualys”). I have personal knowledge of
`the facts set forth in this declaration and can testify competently to those facts. I make this
`declaration in support of Qualys’s Renewed Administrative Motion to File Documents Under Seal
`pursuant to Civil Local Rules 79-5(d) and 79-5(e).
`2.
`I have reviewed the below documents and confirmed that they contain sealable
`information belonging to Qualys. Certain portions of the documents contain confidential business
`information that discuss business strategy and the technical details of Qualys’s technology, and are
`thus sealable because they contain Qualys’s trade secret information.
`3.
`Exhibit 5 to the Joint Discovery Letter is a Qualys internal document containing
`confidential business information such as business strategy and technical details of Qualys’s
`technology. It also includes confidential analyses of markets in which Qualys competes. As such,
`the document contains sensitive competitive information and was internally marked as
`CONFIDENTIAL by Qualys at creation. It is therefore sealable as containing Qualys’s trade secret
`information as follows: redacted portions on pages 1-6, 8-20, 24-27, 29-31, 33-36, 38-44, 47-95,
`97-111.
`Exhibit 8 to the Joint Discovery Letter is a Qualys internal document containing
`4.
`confidential business and technical information regarding Qualys products. The document was
`internally marked QUALYS CONFIDENTIAL – NOT FOR REDISTRIBUTION BEYOND
`INTENDED RECIPIENT. It contains Qualys trade secret information about its technical partners
`and customer information. Also, the document is a confidential response to a prospective
`customer’s request for proposal. As such, it contains Qualys confidential trade secret information,
`such as internal sales strategy for its products. Moreover, as this is a response to a third party’s
`request for proposal, the document may also implicate that third party’s confidential trade secret
`information as well. This document is kept under strict confidentiality and is sealable as containing
`Qualys’s trade secret information as follows: redacted portions on pages 1-22.
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`CASE NO. 3:18-cv-07229-YGR
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`1
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`DECLARATION OF CHRISTOPHER MAYS
`
`
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`Case 4:18-cv-07229-YGR Document 108-1 Filed 09/24/20 Page 3 of 3
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`The requested relief is necessarily and narrowly tailored to protect the confidentiality
`5.
`of the information contained in the Joint Discovery Letter and exhibits.
`
`I declare under the penalty of perjury under the laws of the United States of America that
`each of the above statements is true and correct. Executed on September 24, 2020, in Morgan Hill,
`CA.
`
`/s/ Christopher D. Mays
`Christopher D. Mays
`
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`DECLARATION OF CHRISTOPHER MAYS
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