Case 4:18-cv-07229-YGR Document 54-1 Filed 03/20/20 Page 1 of 2
`
`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 D. MAYS IN
`SUPPORT OF 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
`
`MAYS DECL. ISO
`MOT. TO FILE UNDER SEAL
`
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`

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`Case 4:18-cv-07229-YGR Document 54-1 Filed 03/20/20 Page 2 of 2
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`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. I am an associate in the law firm of Wilson Sonsini Goodrich Rosati and counsel
`of record for Defendant Qualys Inc. (“Qualys”). I make this declaration in support of Qualys’s
`Administrative Motion to File Documents Under Seal on my own personal knowledge.
`2.
`I have reviewed the following document and confirmed that it contains
`information that Plaintiff Finjan, Inc.’s (“Finjan”) has designated as “Highly Confidential –
`Attorneys’ Eyes Only”:
`Identification of Documents
`to be Sealed
`
`Portion of Document Sought to be
`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 Brief”)
`
`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
`
`As required by Local Rules 79-5, I submit this Declaration in support of Qualys’s
`3.
`Motion to File Documents Under Seal to confirm that the above-identified document, based on
`current information and belief, contains information that is highly confidential and sealable as
`follows:
`
`The Reply Brief (redacted portions at redacted portions at 4:16-17, 4:24-
`a.
`27, 5:1-2, 5:7; 6:4-28, 7:12, and 7:4-8) refers to information that has been designated by Finjan
`as “Highly Confidential – Attorneys’ Eyes Only” under the Protective Order in this case.
`4.
`The requested relief is necessarily and narrowly tailored to protect only the
`confidentiality of the designated document. Qualys seeks only to seal this one document.
`I declare under penalty of perjury of the laws of the State of California and the United
`States that each of the above statements is true and correct. Executed on the 20th Day of March,
`2020, in Morgan Hill, California.
`
`CASE NO. 4:18-cv-07229-YGR
`
`-1-
`
`MAYS DECL. ISO
`MOT. TO FILE UNDER SEAL
`
`By:
`
`/s/ Christopher D. Mays
`Christopher D. Mays
`
`