`
`
`
`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
`AUSTIN MANES (State Bar No. 284065)
`amanes@kramerlevin.com
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`FINJAN, INC.,
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`QUALYS INC.,
`
`
`
`
`
`
`Defendant.
`
`OAKLAND DIVISION
`
`
`Case No.: 4:18-cv-07229-YGR
`
`PLAINTIFF FINJAN, INC.’S
`ADMINISTRATIVE MOTION FOR LEAVE
`TO FILE A RESPONSE TO DEFENDANT
`QUALYS, INC.’S OBJECTION TO
`EVIDENCE [DKT. 60]
`
`Date: May 1, 20201
`Time:
`10:00 AM
`Place: Courtroom 1, 4th Floor
`Judge: Hon. Yvonne Gonzalez Rogers
`
`
`1 Subject to the Court’s March 12, 2020 Order (Dkt. No. 48) suspending in-person appearances.
`FINJAN’S ADMIN. MOTION FOR LEAVE TO FILE
`CASE NO.: 4:18-cv-07229-YGR
`A RESPONSE TO QUALYS’ OBJECTION TO EVIDENCE
`
`1
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`Case 4:18-cv-07229-YGR Document 65 Filed 04/20/20 Page 2 of 2
`
`
`
`Plaintiff Finjan, Inc. hereby moves for leave to file a short response to the Objections to
`Evidence that Qualys filed on April 13, 2020, at Dkt. 60 (“Objections”). Finjan’s proposed 5-page
`response is attached hereto as Exhibit A, and will demonstrate that Qualys’ Objections misstate the
`record and misapply the controlling law and Patent Local Rules.
`On April 17, 2020 Qualys indicated that it reserves the right to oppose Finjan’s motion for leave
`to file the response. Declaration of Aaron Frankel filed herewith at ¶ 3.
`
`
`
`
`Dated: April 20, 2020
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`By: /s/ James Hannah
`Paul J. Andre (State Bar No. 196585)
`Lisa Kobialka (State Bar No. 191404)
`James Hannah (State Bar No. 237978)
`Austin Manes (State Bar No. 284065)
`KRAMER LEVIN NAFTALIS
`& FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`pandre@kramerlevin.com
`lkobialka@kramerlevin.com
`jhannah@kramerlevin.com
`amanes@kramerlevin.com
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`1
`FINJAN’S ADMIN. MOTION FOR LEAVE TO FILE
`A RESPONSE TO QUALYS’ OBJECTION TO EVIDENCE
`
`CASE NO.: 4:18-cv-07229-YGR
`
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`
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