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`Juanita R. Brooks (CA SBN 75934)
`brooks@fr.com
`FISH & RICHARDSON P.C.
`12860 El Camino Real, Suite 400
`San Diego, CA 92130
`Telephone: (858) 678-5070 / Fax: (858) 678-5099
`
`Robert P. Courtney (CA SBN 248392)
`courtney@fr.com
`FISH & RICHARDSON P.C.
`3200 RBC Plaza
`60 South 6th Street
`Minneapolis, MN 55402
`Telephone: (612) 335-5070 / Fax: (612) 288-9696
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
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`FINJAN, INC., a Delaware
`Corporation,
`
`Plaintiff,
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`v.
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`QUALYS INC., a Delaware
`Corporation,
`
`Case No. 4:18-cv-07229-YGR (TSH)
`
`DECLARATION OF ROBERT
`COURTNEY SUPPORTING
`FINJAN, INC.’S MOTION FOR
`RELIEF FROM THE
`MAGISTRATE JUDGE’S
`DISCOVERY ORDER OF
`SEPTEMBER 17, 2020
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`Defendant.
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`I, Robert Courtney, declare as follows:
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`1.
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`I am an attorney at Fish & Richardson P.C., counsel of record in this
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`action for Plaintiff Finjan, Inc. I am a member of the Bar of the State of California.
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`I have personal knowledge of the matters stated in this declaration and would testify
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`truthfully to them if called to do so.
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`2.
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`Attached as Exhibit 1 is a true and accurate copy of Appendix E to
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`Finjan’s P.R. 3-1 contentions, as served April 19, 2019.
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`COURTNEY DECL. SUPP. FINJAN
`MOTION FOR RELIEF
`Case No. 4:18-cv-07229-YGR (TSH)
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`Case 4:18-cv-07229-YGR Document 114-1 Filed 10/01/20 Page 2 of 2
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`3.
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`Attached as Exhibit 2 is a true and accurate copy of Defendant Qualys,
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`Inc.’s Third Supplemental Objections and Responses to Finjan’s First Set of
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`Interrogatories (Nos. 1–6), as served on September 28, 2020.
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`4.
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`Attached as Exhibit 3 is a true and accurate copy of excerpts from the
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`Rough Transcript of the Deposition of Dilip Bachwani, taken September 18, 2020.
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`5.
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`Attached as Exhibit 4 is a true and accurate copy of excerpts from the
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`Rough Transcript of the Deposition of Holger Kruse, taken September 14, 2020.
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`6.
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`Attached as Exhibit 5 is a true and accurate copy of excerpts from
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`Finjan’s First Set of Requests for Production, as served March 1, 2019.
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`Attached as Exhibit 6 is a true and accurate copy of excerpts from
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`Finjan’s First Set of Interrogatories, as served March 1, 2019.
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`8.
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`Attached as Exhibit 7 is a true and accurate copy of Qualys’s Second
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`Amended Objections and Responses to Finjan’s Notice of 30(b)(6) Deposition, as
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`served August 25, 2020.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Dated: October 1, 2020
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`/s/ Robert Courtney
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`Robert Courtney
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`COURTNEY DECL. SUPP. FINJAN
`MOTION FOR RELIEF
`Case No. 4:18-cv-07229-YGR (TSH)
`
`