Case 4:18-cv-07229-YGR Document 114-7 Filed 10/01/20 Page 1 of 5
`Case 4:18-cv-07229—YGR Document 114-7 Filed 10/01/20 Page 1 of 5
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`EXHIBIT 6
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`EXHIBIT 6
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`Case 4:18-cv-07229-YGR Document 114-7 Filed 10/01/20 Page 2 of 5
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`PAUL ANDRE (SBN 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (SBN 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (SBN 237978)
`jhannah@kramerlevin.com
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`OAKLAND DIVISION
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`Case No.: 4:18-cv-07229-YGR
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`FINJAN, INC.’S FIRST SET OF
`INTERROGATORIES TO DEFENDANT
`QUALYS INC. (NOS. 1-6)
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`FINJAN, INC.,
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`Plaintiff,
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`v.
`
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`QUALYS INC.,
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`Defendant.
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`FINJAN’S FIRST SET OF INTERROGATORIES
`TO DEFENDANT QUALYS (NOS. 1-6)
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`CASE NO.: 4:18-cv-07229-YGR
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`Case 4:18-cv-07229-YGR Document 114-7 Filed 10/01/20 Page 3 of 5
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`Asserted Patents, the identity of all persons with knowledge of such facts and circumstances, and the
`identity of all documents reflecting such facts and circumstances.
`INTERROGATORY NO. 2:
`For each of the Accused Instrumentalities, identify all releases or versions that are or have been
`made, used, offered for sale, sold in the United States, or imported into the United States by You or on
`Your behalf from the year 2013 to the present.
`INTERROGATORY NO. 3:
`Describe in detail the revenue, sales, billings, pricing, costs, gross profits, net profits, and
`market share of each of the Accused Instrumentalities from the year 2013 to the present generated (a)
`in the United States and separately, (b) worldwide, including but not limited to identifying on a
`monthly, quarterly, and annual basis the gross and net revenues and gross and net profits generated by
`each of the Accused Instrumentalities, as well as the costs and expenses incurred by You in generating
`such revenue and profits.
`INTERROGATORY NO. 4:
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`For the source code that You produced or made available for inspection or will produce and
`make available for inspection, identify the Accused Instrumentalities that correspond to the source
`code including the name and version number of each Accused Instrumentalities, the directories and
`subdirectories of the source code corresponding to the active source code incorporated into each of the
`Accused Instrumentalities, the last date the source code was modified for each of the products, which
`portion, if any, of the source code You contend is not active in the Accused Instrumentalities, and
`which portion, if any, of the source code You contend is prior art to the Asserted Patents.
`INTERROGATORY NO. 5:
`Describe in detail the geographic location(s) where the Accused Instrumentalities and their
`components were and are developed, tested, manufactured, used and updated since the date
`development began through the present, including the name(s) and address(es) of the location(s), the
`name(s) of the entity or entities involved in such activities, and if different components are developed,
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`FINJAN’S FIRST SET OF INTERROGATORIES
`TO DEFENDANT QUALYS (NOS. 1-6)
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`Case 4:18-cv-07229-YGR Document 114-7 Filed 10/01/20 Page 4 of 5
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`tested, manufactured or updated in different locations, identify which components are developed,
`tested, manufactured or updated at each location and by whom.
`INTERROGATORY NO. 6:
`Since the date of first sale, identify the amount of both actual and forecasted sales of each
`model, version, or release of each of the Accused Instrumentalities, including by the following: (1)
`gross and net revenues, (2) gross and net profits, (3) research and development costs, (4) other
`costs/expenses, (5) sales prices, (6) number of units, (7) number of users, and (8) amount of foregoing
`that You contend are subject to 28 U.S.C. § 1498, and describe in detail how the foregoing (1-8) was
`calculated, including identification of persons, electronic databases, and documents who are
`knowledgeable or contain information regarding the foregoing.
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`Dated: March 1, 2019
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`By: /s/ Lisa Kobialka
`
`Paul J. Andre (State Bar. No. 196585)
`Lisa Kobialka (State Bar No. 191404)
`James Hannah (State Bar No. 237978)
`KRAMER LEVIN NAFTALIS
`& FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`pandre@kramerlevin.com
`lkobialka@kramerlevin.com
`jhannah@kramerlevin.com
`
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`FINJAN’S FIRST SET OF INTERROGATORIES
`TO DEFENDANT QUALYS (NOS. 1-6)
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`CASE NO.: 4:18-cv-07229-YGR
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`Case 4:18-cv-07229-YGR Document 114-7 Filed 10/01/20 Page 5 of 5
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`PROOF OF SERVICE
`I, Sean Robertson, am employed in the Menlo Park, California office of Kramer Levin Naftalis
`& Frankel LLP. I am over the age of 18 and not a party to the within action. My business address is
`990 Marsh Road, Menlo Park, California 94025. I am readily familiar with the firm’s practice of
`collecting and processing of mail for mailing with the U.S. Postal Service and overnight delivery
`services.
`On March 1, 2019, I caused the following document(s) to be served:
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`FINJAN, INC.’S FIRST SET OF INTERROGATORIES TO DEFENDANT
`QUALYS, INC. (NOS. 1-6)
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`by electronic mail, addressed as follows:
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`
`Edward G. Poplawski
`Olivia M Kim
`Wilson Sonsini Goodrich & Rosati, P.C.
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071
`epoplawski@wsgr.com
`okim@wsgr.com
`
`
`Ryan R. Smith
`Christopher Don Mays
`Wilson Sonsini Goodrich & Rosati
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`rsmith@wsgr.com
`cmays@wsgr.com
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`I declare under penalty of perjury that the foregoing is true and correct. Executed on March 1,
`2019, in Menlo Park, California.
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`__________________________
` Sean Robertson
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