`
`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
`
`[PROPOSED] ORDER GRANTING
`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
`
`[PROPOSED ] ORDER GRANTING
`QUALYS’S MOTION TO
`FILE DOCUMENTS UNDER SEAL
`
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`Case 4:18-cv-07229-YGR Document 54-2 Filed 03/20/20 Page 2 of 3
`
`Defendant Qualys Inc. (“Qualys”) Administrative Motion to File Documents Under Seal
`
`was brought before this Court. Upon consideration of this motion and the supporting declaration
`
`of Christopher D. Mays filed in support thereof, the Court finds there to be good cause and
`
`compelling reasons for granting the request to file under seal.
`
`GOOD CAUSE and compelling reasons having been shown, the Court finds that:
`
`1.
`
`There exists overriding confidentiality interests that overcome the right of public
`
`access to the record of the following document:
`
`Identification of Documents
`to be Sealed
`
`Portion of Document Sought to be
`Sealed
`
`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
`
`Entity That
`Designated the
`Information As
`Confidential
`Finjan
`
`2.
`
`A substantial probability exists that the overriding confidentiality interests will be
`
`prejudiced if the record is not sealed;
`
`3.
`
`4.
`
`The proposed sealing is narrowly tailored; and
`
`No less restrictive means exist to achieve these overriding interests.
`
`CASE NO. 4:18-cv-07229-YGR
`
`-1-
`
`[PROPOSED ] ORDER GRANTING
`QUALYS’S MOTION TO
`FILE DOCUMENTS UNDER SEAL
`
`
`
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`Case 4:18-cv-07229-YGR Document 54-2 Filed 03/20/20 Page 3 of 3
`
`IT IS THEREFORE ORDERED that Qualys’s Administrative Motion to File Documents
`
`Under Seal is GRANTED with respect to the document set forth as follows:
`
`Document or Portion of Document
`Sought to be Sealed
`
`Evidence Offered in Support
`of Sealing
`
`Order
`
`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
`
`Mays Declaration ¶ 2-3.
`
`Dated: _____________________
`
`
`
`By: ______________________________
` Honorable Yvonne Gonzalez Rogers
`
`CASE NO. 4:18-cv-07229-YGR
`
`-2-
`
`[PROPOSED ] ORDER GRANTING
`QUALYS’S MOTION TO
`FILE DOCUMENTS UNDER SEAL
`
`
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