Case 4:18-cv-07229-YGR Document 57 Filed 03/24/20 Page 1 of 3
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`PAUL J. ANDRE (State Bar No. 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (State Bar No. 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (State Bar No. 237978)
`jhannah@kramerlevin.com
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
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`Attorneys for Plaintiff
`FINJAN, INC.
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE NORTHERN DISTRICT OF CALIFORNIA
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`OAKLAND DIVISION
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`FINJAN, INC., a Delaware Corporation,
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`Plaintiff,
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`v.
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`QUALYS INC., a Delaware Corporation,
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`Defendant.
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`Case No.: 4:18-cv-07229-YGR
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`DECLARATION OF JAMES HANNAH IN
`SUPPORT OF QUALYS INC.’S
`ADMINISTRATIVE MOTION TO FILE
`DOCUMENTS UNDER SEAL (DKT. NO. 55)
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` CASE NO.: 4:18-cv-07229-YGR
`HANNAH DECL. IN SUPPORT OF QUALYS’ ADMIN.
`MOT. TO FILE DOCUMENTS UNDER SEAL (DKT. NO. 55)
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`Case 4:18-cv-07229-YGR Document 57 Filed 03/24/20 Page 2 of 3
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`I, James Hannah, declare:
`I have personal knowledge of the facts stated herein and can testify competently to those
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`facts. I am licensed to practice law in the State of California and am an attorney at Kramer Levin
`Naftalis & Frankel LLP, counsel of record for Finjan, Inc. (“Finjan”). I make this declaration in support
`of Qualys Inc.’s (“Qualys”) Administrative Motion to File Documents Under Seal in connection with its
`Reply in Support of its Motion for Leave to Amend Answer and Affirmative Defenses (Dkt. No. 55)
`(“Reply”).
`I have reviewed the portions of Qualys’ Reply sought to be sealed, and confirmed that
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`those portions are designated as “Highly Confidential – Attorneys’ Eyes Only” by Finjan and contains
`information that Finjan regards confidential within its business.
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`Identification of Document(s) to be Sealed
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`Portions of Document(s) Sought to be
`Sealed
`Reply at page 4, lines 16-17, 24-27;
`Reply at page 6, lines 4-28;
`Reply at page 7, lines 1-2, 4-8
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`Defendant Qualys Inc.’s Reply in Support of its
`Motion for Leave to Amend Answer and Affirmative
`Defenses (“Reply”)
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`Finjan seeks to seal the above portions of the Reply because these portions reflect
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`Finjan’s confidential licensing information. The confidential portions of this document are limited to
`disclosure within Finjan to only those with a need to know, and may be disclosed in litigation only when
`relevant and under the highest level of confidentiality. If competitors gain access to Finjan’s confidential
`licensing information, Finjan will be placed at an unfair disadvantage in future business negotiations. In
`the context of confidential settlement discussions, Finjan and its licensees exchange proposed license fee
`terms under Fed. R. Evid. 408 based on confidential business and product information of both parties. If
`such confidential information were to be disclosed publicly, prospective licensees would be unwilling to
`exchange relevant confident information to engage in productive licensing and settlement negotiations.
`4.
`Based on the foregoing, good cause exists to seal the portions of the document described
`above. Finjan seeks to seal only those portions of the document that contain its confidential information
`pursuant to the Protective Order and for which it has good cause to seal.
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` CASE NO.: 4:18-cv-07229-YGR
`HANNAH DECL. IN SUPPORT OF QUALYS’ ADMIN.
`MOT. TO FILE DOCUMENTS UNDER SEAL (DKT. NO. 55)
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`

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`Case 4:18-cv-07229-YGR Document 57 Filed 03/24/20 Page 3 of 3
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`I declare under penalty of perjury under the laws of the United States of America that each of the
`above statements is true and correct. Executed on March 24, 2020, in Menlo Park, California
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` /s/ James Hannah
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`James Hannah
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` CASE NO.: 4:18-cv-07229-YGR
`HANNAH DECL. IN SUPPORT OF QUALYS’ ADMIN.
`MOT. TO FILE DOCUMENTS UNDER SEAL (DKT. NO. 55)
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