`
`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
`
`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 D. MAYS IN
`SUPPORT OF DEFENDANT
`QUALYS INC.’S RESPONSIVE
`CLAIM CONSTRUCTION BRIEF
`
`Date: May 1, 20201
`Time: 10:00 AM
`Place: Courtroom 1, 4th Floor
`Before: Hon. Yvonne Gonzalez Rogers
`
`)))))))))))))))
`
`FINJAN, INC., a Delaware Corporation,
`
`Plaintiff,
`
`v.
`
`QUALYS INC., a Delaware Corporation,
`
`Defendant.
`
`1 Subject to the Court’s March 12, 2020 Order (D.I. 48) suspending in-person appearances.
`
`CASE NO. 4:18-cv-07229-YGR
`
`MAYS DECL. ISO QUALYS’S
`RESPONSIVE CLAIM CONSTRUCTION BRIEF
`
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`Case 4:18-cv-07229-YGR Document 52-1 Filed 03/16/20 Page 2 of 2
`
`I. Christopher D. Mays, the undersigned, declare as follows:
`
`1.
`
`I am an attorney at law, duly licensed to practice before all the courts of the State of
`
`California, and I am an associate with the law firm of Wilson Sonsini Goodrich Rosati, counsel for
`
`Defendant Qualys Inc. (“Qualys”). I submit this declaration in support of Defendant Qualys Inc.’s
`
`Responsive Claim Construction Brief
`
`2.
`
`Attached as Exhibit A is a true and correct copy of Finjan’s supplemental claim
`
`construction brief that I caused to be downloaded from the public docket in Finjan, Inc. v.
`
`Proofpoint, Inc., No. 3:13-cv-5808-HSG, Dkt. No. 462.
`
`3.
`
`Attached as Exhibit B is a true and correct copy of Finjan’s opposition to a motion
`
`for summary judgment that I caused to be downloaded from the public docket in Finjan, Inc. v.
`
`Proofpoint, Inc., No. 3:13-cv-5808-HSG, Dkt. No. 321.
`
`4.
`
`Attached as Exhibit C is a true and correct of an excerpt of the file history for
`
`the ’844 patent (bates-labeled FINJAN-QUALYS 000318- FINJAN-QUALYS 000323), that Finjan
`
`produced in this litigation.
`
`5.
`
`Attached as Exhibit D is a true and correct copy of Juniper’s Ex. P to its opposition
`
`to Finjan’s motion for summary judgment that I caused to be downloaded from the public docket in
`
`Finjan Inc. v. Juniper Networks, Inc., 3:17-cv-05659-WHA, Dkt. No. 390-19, the Final Written
`
`Decision (Paper 62) from IPR2015-01979.
`
`I declare under penalty of perjury of the laws of the United States of America that the
`
`foregoing is true and correct and that this Declaration is executed this 16th day of March, 2020, at
`
`Palo Alto, California.
`
`By:
`
`/s/ Christopher D. Mays
`Christopher D. Mays
`
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`CASE NO. 4:18-cv-07229-YGR
`
`-1-
`
`MAYS DECL. ISO QUALYS’S
`RESPONSIVE CLAIM CONSTRUCTION BRIEF
`
`
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