`
`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
`
`DEFENDANT QUALYS INC.’S
`ADMINISTRATIVE MOTION TO
`FILE DOCUMENTS UNDER SEAL
`
`Judge:
`
`Date:
`
`Hon. Yvonne Gonzalez
`Rogers
`N/A1
`
`)))))))))
`
`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
`
`MOT. TO FILE UNDER SEAL
`
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`Case 4:18-cv-07229-YGR Document 54 Filed 03/20/20 Page 2 of 3
`
`I.
`
`INTRODUCTION
`
`Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, Civil Local Rules 7-11
`and 79-5, and the Stipulated Protective Order (Dkt. 34), Defendant Qualys Inc. (“Qualys”)
`respectfully brings this Administrative Motion to File Documents Under Seal. Specifically, there
`are compelling reasons to file the following document under seal:
`Identification of Documents
`Portion of Document Sought to be
`to be Sealed
`Sealed
`
`Entity That
`Designated the
`Information As
`Confidential
`Finjan
`
`Defendant Qualys Inc.’s
`Reply in Support of its Motion
`for Leave to Amend Answer
`and Affirmative Defenses
`
`Reply at page 4, lines 16-17, 24-27;
`Reply at page 5, lines 1-2, 7;
`Reply at page 6, lines 4-28;
`Reply at page 7, lines 1-2, 4-8
`
`The above-identified document contains highly confidential information designated by
`Plaintiff Finjan, Inc. (“Finjan”) as “Highly Confidential – Attorneys’ Eyes Only.” or contains
`information so designated by Finjan.
`II.
`ARGUMENT
`Qualys seeks to seal portions of its Reply in Support of its Motion for Leave to Amend
`Answer and Affirmative Defenses as it contains information that Finjan has designated as
`“Highly Confidential –Attorneys’ Eyes Only.” (Mays Decl.2 at ¶ 3(a).) This request is narrowly
`tailored in that it seeks to seal only this one document, regarded as highly confidential pursuant
`to the Stipulated Protective Order governing the treatment of confidential information exchanged
`during discovery.
`III.
`CONCLUSION
`
`2 Declaration of Christopher D. Mays in support of this motion to file concurrently hereto.
`
`CASE NO. 4:18-cv-07229-YGR
`
`-1-
`
`MOT. TO FILE UNDER SEAL
`
`
`
`Case 4:18-cv-07229-YGR Document 54 Filed 03/20/20 Page 3 of 3
`
`Qualys has shown good cause and compelling reasons for this request to file the above
`document 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
`Administrative Motion to File Documents Under Seal.
`
`DATED: March 20, 2020
`
`By:
`
`Respectfully submitted,
`
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`
`/s/ Christopher D. Mays
`EDWARD D. POPLAWSKI
`OLIVIA M. KIM
`RYAN R. SMITH
`CHRISTOPHER D. MAYS
`
`Counsel for Defendant
`QUALYS INC.
`
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`CASE NO. 4:18-cv-07229-YGR
`
`-2-
`
`MOT. TO FILE UNDER SEAL
`
`
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