Case 4:18-cv-07229-YGR Document 79-1 Filed 07/22/20 Page 1 of 17
`Case 4:18-cv-07229—YGR Document 79-1 Filed 07/22/20 Page 1 of 17
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`EXHIBIT 1
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`EXHIBIT 1
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`Case 4:18-cv-07229-YGR Document 79-1 Filed 07/22/20 Page 2 of 17
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`PAUL ANDRE (SBN 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (SBN 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (SBN 237978)
`jhannah@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
`OAKLAND DIVISION
`
`Case No.: 4:18-cv-07229-YGR
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`FINJAN, INC.’S FIRST SET OF
`REQUESTS FOR PRODUCTION OF
`DOCUMENTS AND THINGS TO
`DEFENDANT QUALYS INC. (NOS. 1-64)
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`FINJAN, INC.,
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`Plaintiff,
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`v.
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`QUALYS INC.,
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`Defendant.
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`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO DEFENDANT (NOS. 1-64)
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`Case 4:18-cv-07229-YGR Document 79-1 Filed 07/22/20 Page 3 of 17
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`Plaintiff Finjan, Inc. (“Finjan”), by counsel, and pursuant to Federal Rule of Civil Procedure
`33, hereby requests that Defendant Qualys Inc. (“Qualys” or “Defendant”) produce the following
`documents for inspection and copying within thirty (30) days of the date of service of these requests at
`the offices of Kramer Levin Naftalis & Frankel LLP, 990 Marsh Road in Menlo Park, California
`94025, in accordance with the following Definitions and Instructions. These requests impose a
`continuing duty upon Qualys to supplement promptly in accordance with Federal Rule of Civil
`Procedure 26(e) and the Local Rules of the Northern District of California as Qualys becomes aware
`of, generates, or acquires additional knowledge or information responsive to these requests.
`DEFINITIONS
`1.
`The terms “You,” “Your,” and “Defendant” shall mean Qualys, Inc., Your present and
`former directors, officers, employees, parent organization(s), subsidiary organization(s), predecessors
`in interest, successors in interest, divisions, servants, agents, attorneys, consultants, partners,
`associates, investigators, representatives, accountants, financial advisors, distributors and any other
`person acting on Your behalf, pursuant to Your authority or subject to Your control, including any and
`all joint ventures or other legal entities of any type whatsoever in which You own or owned any
`interest, receive or received any payments, and/or participated or now participate in any manner.
`2.
`The term “Finjan” shall mean Finjan, its present and former directors, officers,
`employees, parent organization(s), subsidiary organization(s), predecessors in interest, successors in
`interest, divisions, servants, agents, attorneys, consultants, partners, associates, investigators,
`representatives, accountants, financial advisors, distributors and any other person acting on its behalf,
`pursuant to its authority or subject to its control.
`3.
`The term “third party” shall mean any person or entity other than Finjan or Defendant.
`4.
`The term “Complaint” shall refer to Finjan’s Complaint for Patent Infringement in this
`case, filed on November 29, 2018, and any subsequently filed amended complaints. See Dkt. No. 1.
`5.
`The term “Asserted Patents” shall mean U.S. Patent Nos.: 6,154,844 (“the ‘844
`Patent”), 8,677,494 (“the ‘494 Patent”), 7,975,305 (“the ‘305 Patent”), 8,225,408 (“the ‘408 Patent”),
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`Case 4:18-cv-07229-YGR Document 79-1 Filed 07/22/20 Page 4 of 17
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`6,965,968 (“the ‘968 Patent”), 7,418,731 (“the ‘731 Patent”), 8,141,154 (“the ‘154 Patent”),
`collectively.
`6.
`The term “Accused Instrumentalities” shall include the following Qualys products and
`services: Vulnerability Management, Threat Protection, Continuous Monitoring, Indicators of
`Compromise, Container Security, Web App Firewall, Web App Scanning, and Compliance
`Monitoring, including Qualys Cloud Platform products, as described in Finjan’s Complaint inter alia at
`paragraphs 34-54 and Exhibits 8-22. The term “Accused Instrumentalities” shall also include any and
`all previous or currently contemplated versions, revisions, releases, or continuations of said Qualys
`products and services, and all additional products accused of infringement by Finjan in this action in
`infringement contentions or similar pleadings.
`7.
`The term “person” or “entity” shall refer to any individual, corporation, proprietorship,
`association, joint venture, company, partnership, or other business or legal entity, including
`governmental bodies and agencies. The masculine includes the feminine and vice versa; the singular
`includes the plural and vice versa.
`8.
`The term “document(s)” shall have the broadest meaning ascribed to it by Federal Rule
`of Civil Procedure 34 and Federal Rule of Evidence 1001, and shall include within its meaning any and
`all papers, videotapes or video recordings, photographs, films, recordings, memoranda, books, records,
`accounts, letters, telegrams, correspondence, notes of meetings, notes of conversations, notes of
`telephone calls, inter-office memoranda or written communications of any nature, recordings of
`conversations either in writing or by means of any mechanical or electrical recording device, notes,
`papers, reports, analyses, invoices, canceled checks or check stubs, receipts, minutes of meetings, time
`sheets, diaries, desk calendars, ledgers, schedules, licenses, financial statements, telephone bills, logs,
`and any differing versions of the foregoing whether denominated formal, informal, or otherwise, as
`well as copies of the foregoing which differ in any way, including handwritten notations or other
`written or printed matter of any nature, from the original. The foregoing specifically includes the
`information stored in any form, including electronic form, on a computer or in a computer database or
`otherwise, including electronic mail. Moreover, the term “document” shall also include all “technical
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`Case 4:18-cv-07229-YGR Document 79-1 Filed 07/22/20 Page 5 of 17
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`documents,” such as source code, specifications, schematics, flow charts, artwork, drawings, pictures,
`pictorial representations, formulas, troubleshooting guides, service bulletins, technical bulletins,
`production specification sheets, white papers, operator manuals, operation manuals, and instruction
`manuals.
`9.
`The term “communication” shall mean, including its usual and customary meaning, any
`transmission, conveyance or exchange of a word, statement, fact, thing, idea, document, instruction,
`information, demand, or question by any medium, whether by written, oral, or other means, including,
`but not limited to, electronic communications and electronic mail.
`10.
`The term “thing” shall mean any tangible object, other than a document.
`11.
`The terms “relate to,” “reflecting,” “relating to,” “concerning,” or any variations
`thereof, shall mean relating to, referring to, concerning, mentioning, reflecting, regarding, pertaining
`to, evidencing, involving, describing, discussing, commenting on, embodying, responding to,
`supporting, contradicting, or constituting (in whole or in part), or are between (as in the context of
`communications), as the context makes appropriate.
`12.
`The term “including” shall mean including but not by way of limitation.
`13.
`The words “and” and “or” shall be construed conjunctively or disjunctively in a manner
`making the request inclusive rather than exclusive.
`14.
`The term “any” shall mean “any and all” and the term “all” shall mean “any and all.”
`15.
`The singular of any word or phrase shall include the plural of such word or phrase, and
`the plural of any word or phrase shall include the singular of such word or phrase.
`INSTRUCTIONS
`1.
`In answering the following requests, please furnish all available information including
`information in the possession, custody, or control of any of Defendant’s attorneys, directors, officers,
`agents, employees, representatives, associates, investigators, divisions, affiliates, partnerships, parents,
`subsidiaries, and persons under Defendant’s control who have the best knowledge, not merely
`information known to Defendant based on Defendant’s own personal knowledge. If You cannot fully
`respond to the following requests after exercising due diligence to secure the information requested
`
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`Case 4:18-cv-07229-YGR Document 79-1 Filed 07/22/20 Page 6 of 17
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`b.
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`thereby, so state, and specify the portion of each request that cannot be responded to fully and
`completely. In the latter event, state what efforts were made to obtain the requested information and
`the facts relied upon that support the contention that the request cannot be answered fully and
`completely, and state what knowledge, information, or belief Defendant has concerning the
`unanswered portion of any such request.
`2.
`All documents must be produced in accordance with the requirements of Federal Rule
`of Civil Procedure 34(b) and per the following instructions:
`a.
`Electronic records and computerized information shall be produced in an
`intelligible format, together with a description of the system from which they
`were derived sufficient to permit rendering the records and information
`intelligible;
`Selection of documents from the files and other sources and the numbering of
`such documents shall be performed in such a manner as to ensure that the source
`of each document can be determined;
`File folders with tabs or labels or directories of files identifying documents shall
`be produced intact with such documents;
`Documents attached to each other shall not be separated. All documents that
`respond, in whole or in part, to any portion of any request shall be produced in
`their entirety, including all addenda, appendices, attachments and enclosures.
`3.
`If any information requested is claimed to be privileged or otherwise, provide all
`information falling within the scope of the request that is not privileged, and for each item of
`information contained in a document to which a claim of privilege is made, identify such document
`with sufficient particularity for purposes of a motion to compel, such identification to include at least
`the following:
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`c.
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`d.
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`a.
`b.
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`the basis on which the privilege is claimed;
`the names and positions of the author of the document and all other persons
`participating in the preparation of the document;
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`Case 4:18-cv-07229-YGR Document 79-1 Filed 07/22/20 Page 7 of 17
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`c.
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`d.
`e.
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`f.
`g.
`h.
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`the name and position of each individual or other person to whom the document,
`or a copy thereof, was sent or otherwise disclosed;
`the date of the document;
`a description of any accompanying material transmitted with or attached to such
`document;
`the number of pages in such document;
`the particular request to which such document is responsive; and
`whether any business or non-legal matter is contained or discussed in such
`document.
`4.
`If Defendant’s response to a particular request is a statement that Defendant lacks the
`ability to comply with that request, Defendant shall specify whether the inability to comply is because
`the particular item or category of information never existed, has been destroyed, has been lost,
`misplaced, or stolen, or has never been, or is no longer in the possession, custody, or control of
`Defendant, in which case Defendant shall identify the name and address of any person or entity known
`or believed by Defendant to have possession, custody, or control of that information or category of
`information.
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`REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS
`REQUEST FOR PRODUCTION NO. 1:
`All documents, communications, or things relating to Finjan and its patents.
`REQUEST FOR PRODUCTION NO. 2:
`All documents, communications, or things relating to the Asserted Patents, including
`documents or communications with third parties.
`REQUEST FOR PRODUCTION NO. 3:
`All documents, communications, or things relating to the timing and circumstances of the
`moment You first became aware of each of the Asserted Patents.
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`REQUEST FOR PRODUCTION NO. 4:
`All documents, communications, or things relating to the timing and circumstances of the
`moment You were first provided notice of each of the Asserted Patents.
`REQUEST FOR PRODUCTION NO. 5:
`All documents, communications, or things relating to the timing and circumstances of the
`moment You were first provided notice of Your infringement of each of the Asserted Patents.
`REQUEST FOR PRODUCTION NO. 6:
`All documents, communications, or things relating to any investigation or analysis You
`performed of any of the Asserted Patents.
`REQUEST FOR PRODUCTION NO. 7:
`Documents, communications, or things sufficient to show the infringement or non-infringement
`of the Asserted Patents by You or any other person or entity, including but not limited to, all
`documents, communications, or things relating to Your efforts to assess the validity, infringement, or
`enforceability of the Asserted Patents or to design around or avoid infringing the Asserted Patents.
`REQUEST FOR PRODUCTION NO. 8:
`Documents, communications, or things sufficient to show any alleged non-infringing
`alternatives to the inventions of the Asserted Patents.
`REQUEST FOR PRODUCTION NO. 9:
`Documents, communications, or things sufficient to show any attempt by You to design around
`or mitigate or avoid infringement of the Asserted Patents.
`REQUEST FOR PRODUCTION NO. 10:
`Documents, communications, or things sufficient to show any alleged prior art to, or searches
`for prior art, regarding the Asserted Patents.
`REQUEST FOR PRODUCTION NO. 11:
`Documents, communications, or things sufficient to show the scope, patentability, novelty,
`validity, invalidity, enforceability, or unenforceability of any claim of the Asserted Patents.
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`REQUEST FOR PRODUCTION NO. 12:
`Documents, communications, or things sufficient to show any secondary consideration or other
`objective evidence of non-obviousness of the Asserted Patents, including but not limited to any long-
`felt need, failure of others, commercial success, copying of the claimed invention by others,
`unexpected or superior results from the claimed invention, licensing or praise by others, criticism by
`others, or any other objective indicia of non-obviousness.
`REQUEST FOR PRODUCTION NO. 13:
`All documents, communications, or things relating to the design, development, structure,
`architecture, testing, research, updating or operation for each of the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 14:
`All technical and marketing documents, communications, or things discussing or regarding the
`components of the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 15:
`All documents, communications, or things relating to any database or database schema relating
`to, created for, referenced by, or used by any of the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 16:
`All documents, communications, or things relating to any presentations, overviews, technical
`overviews, power point slides, or briefing related to any of the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 17:
`All documents, communications, or things relating to any API (Application Program Interface)
`specifications, functional specifications, flow charts, architecture diagrams, or design documents
`related to any of the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 18:
`Copies of the source code for each of the Accused Instrumentalities, including but not limited
`to, all past and present releases, versions, updates, or upgrades.
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`REQUEST FOR PRODUCTION NO. 19:
`All source code repositories, development environments, bug tracking systems, and all
`information stored in the source code repositories, development environments, and bug tracking
`systems, including but not limited to comments, notes, log information, check-in and check-out
`information, documentation, programming guides or manuals, chat or forum discussions, and metadata.
`REQUEST FOR PRODUCTION NO. 20:
`Working copies of the most recent version of each of the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 21:
`Documents, communications, or things sufficient to show the in-licensing or out-licensing of
`patents or technology related to the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 22:
`Documents, communications, or things sufficient to show the first offer for sale and sale of
`each of the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 23:
`Documents, communications, or things sufficient to show any sales or revenue generated from
`each of the Accused Instrumentalities from the year 2013 to the present.
`REQUEST FOR PRODUCTION NO. 24:
`Documents, communications, or things sufficient to show the sales or revenue forecasts for
`each of the Accused Instrumentalities generated in the past six (6) years, which forecast sales or
`revenue for the year 2013 or any year past 2013.
`REQUEST FOR PRODUCTION NO. 25:
`Documents, communications, or things sufficient to show the market share of each of the
`Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 26:
`Documents, communications, or things sufficient to show the pricing of each of the Accused
`Instrumentalities from the year 2013 to the present.
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`REQUEST FOR PRODUCTION NO. 27:
`Documents, communications, or things sufficient to show the costs associated with each of the
`Accused Instrumentalities from the year 2013 to the present, including but not limited to, production
`costs, marketing costs, distribution costs, research and development costs, advertising costs and costs
`to update.
`REQUEST FOR PRODUCTION NO. 28:
`Documents, communications, or things sufficient to show the gross profits of each of the
`Accused Instrumentalities from the year 2013 to the present.
`REQUEST FOR PRODUCTION NO. 29:
`Documents, communications, or things sufficient to show the net profits associated with each
`of the Accused Instrumentalities from the year 2013 to the present.
`REQUEST FOR PRODUCTION NO. 30:
`Summaries of the revenue, sales, pricing, costs, gross profits, net profits, and market share of
`each of the Accused Instrumentalities from the year 2013 to the present.
`REQUEST FOR PRODUCTION NO. 31:
`All documents, communications, or things related to any agreements between You and any
`third party related to the development, testing, manufacture, distribution, sale, updating, or importation
`of each of the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 32:
`Documents, communications, or things sufficient to show any marketing, advertising, or
`promotion of each of the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 33:
`Documents, communications, or things sufficient to show any market reports, industry reports,
`competitive analyses, surveys, or studies in the past six (6) years, related to the Accused
`Instrumentalities, any of Your competitors, or any competing products of the Accused
`Instrumentalities, including but not limited to any analyses relating to customer purchasing habits,
`desires, needs, or preferences.
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`REQUEST FOR PRODUCTION NO. 34:
`Documents, communications, or things sufficient to show any products or services sold, offered
`for sale, marketed, or bundled with each of the Accused Instrumentalities from the year 2013 to the
`present.
`REQUEST FOR PRODUCTION NO. 35:
`Documents, communications, or things sufficient to identify each of the Accused
`Instrumentalities by type and model number, including any internal names used within Qualys for each
`of the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 36:
`Documents, communications, or things sufficient to show the process by which You detect new
`malware or security threats or update the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 37:
`Documents, communications, or things sufficient to show the location where the Accused
`Instrumentalities are developed, tested, manufactured, distributed, sold, updated and imported.
`REQUEST FOR PRODUCTION NO. 38:
`Documents, communications, or things sufficient to show the operation, functionality, design,
`development, testing, manufacturing, distribution, sale, updating and import of Qualys’s Vulnerability
`Management products (as described in paragraphs 34-54 of the Complaint).
`REQUEST FOR PRODUCTION NO. 39:
`Documents, communications, or things sufficient to show the operation, functionality, design,
`development, testing, manufacturing, distribution, sale, updating and import of Qualys’s Threat
`Protection products (as described in paragraphs 34-54 of the Complaint).
`REQUEST FOR PRODUCTION NO. 40:
`Documents, communications, or things sufficient to show the operation, functionality, design,
`development, testing, manufacturing, distribution, sale, updating and import of Qualys’s Continuous
`Monitoring products (as described in paragraphs 34-54 of the Complaint).
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`REQUEST FOR PRODUCTION NO. 41:
`Documents, communications, or things sufficient to show to the operation, functionality,
`design, development, testing, manufacturing, distribution, sale, updating and import of Qualys’s
`Indicators of Compromise products (as described in paragraphs 34-54 of the Complaint).
`REQUEST FOR PRODUCTION NO. 42:
`Documents, communications, or things sufficient to show to the operation, functionality,
`design, development, testing, manufacturing, distribution, sale, updating and import of Qualys’s
`Container Security products (as described in paragraphs 34-54 of the Complaint).
`REQUEST FOR PRODUCTION NO. 43:
`Documents, communications, or things sufficient to show to the operation, functionality,
`design, development, testing, manufacturing, distribution, sale, updating and import of Qualys’s Web
`App Firewall products (as described in paragraphs 34-54 of the Complaint).
`REQUEST FOR PRODUCTION NO. 44:
`Documents, communications, or things sufficient to show to the operation, functionality,
`design, development, testing, manufacturing, distribution, sale, updating and import of Qualys’s Web
`App Scanning products (as described in paragraphs 34-54 of the Complaint).
`REQUEST FOR PRODUCTION NO. 45:
`Documents, communications, or things sufficient to show to the operation, functionality,
`design, development, testing, manufacturing, distribution, sale, updating and import of Qualys’s
`Compliance Monitoring products (as described in paragraphs 34-54 of the Complaint).
`REQUEST FOR PRODUCTION NO. 46:
`Documents, communications, or things sufficient to show to the operation, functionality,
`design, development, testing, manufacturing, distribution, sale, updating and import of Qualys’s Cloud
`Platform products (as described in paragraphs 34-54 of the Complaint).
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`Case 4:18-cv-07229-YGR Document 79-1 Filed 07/22/20 Page 14 of 17
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`REQUEST FOR PRODUCTION NO. 47:
`Documents, communications, or things sufficient to show Your organizational structure with
`respect to research, development, engineering, manufacture, assembly, testing, marketing, distribution,
`sale, licensing, updating and importation of each of the Accused Instrumentalities, including
`organizational charts.
`REQUEST FOR PRODUCTION NO. 48:
`All documents, communications, or things relating to the instant litigation.
`REQUEST FOR PRODUCTION NO. 49:
`All documents, communications, or things on which You intend to rely in support of or
`opposition to any claim or defense in this litigation.
`REQUEST FOR PRODUCTION NO. 50:
`Documents, communications, or things sufficient to show Your policies or practices regarding
`the retention or destruction of hard copy or electronic documents and hard copy or electronic versions
`of source code.
`REQUEST FOR PRODUCTION NO. 51:
`All documents, communications, or things exchanged between You and any other person or
`entity, relating to any litigation involving Finjan.
`REQUEST FOR PRODUCTION NO. 52:
`All documents, communications, or things exchanged between You and any other person or
`entity, regarding any post-grant proceedings before the U.S. Patent and Trademark Office, including
`but not limited to any reexamination or inter partes review proceedings, within the past six (6) years.
`REQUEST FOR PRODUCTION NO. 53:
`Documents, communications, or things sufficient to show any valuation, appraisal, offer, or any
`other indication of Your economic value, within the past six (6) years.
`REQUEST FOR PRODUCTION NO. 54:
`Documents, communications, or things sufficient to show the billings and the revenues for the
`Accused Instrumentalities.
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`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO DEFENDANT (NOS. 1-64)
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`CASE NO.: 4:18-cv-07229-YGR
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`Case 4:18-cv-07229-YGR Document 79-1 Filed 07/22/20 Page 15 of 17
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`REQUEST FOR PRODUCTION NO. 55:
`Documents, communications, or things sufficient to show the number of users or unique users
`and their geographic locations (e.g., United States vs. rest of world) for each release or version of the
`Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 56:
`Documents, communications, or things sufficient to show the pricing of licenses for users
`and/or seats for the Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 57:
`Documents, communications, or things sufficient to show any valuations performed by You or
`on Your behalf of the Accused Instrumentalities, including any components, parts, and/or features of
`such Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 58:
`Documents, communications, or things sufficient to identify payments, revenues, or royalties
`obtained by You from licensing the Accused Instrumentalities, including any components, parts,
`and/or features of such Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 59:
`Documents, communications, or things sufficient to show the number of scans or average
`number of scans performed by the Accused Instrumentalities, including identification of the
`technology or component thereof that is involved in the scan, and the geographic locations where the
`accused instrumentalities perform these scans (e.g., United States vs. rest of the world) since the date
`of first sale.
`REQUEST FOR PRODUCTION NO. 60:
`Documents, communications, or things sufficient to show the number of scans or average
`number of scans per hour, day, month or year or by license, seat or user or by geographic location
`since the date of first sale through the present.
`
`
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`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO DEFENDANT (NOS. 1-64)
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`CASE NO.: 4:18-cv-07229-YGR
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`Case 4:18-cv-07229-YGR Document 79-1 Filed 07/22/20 Page 16 of 17
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`REQUEST FOR PRODUCTION NO. 61:
`Documents, communications, or things sufficient to show the number and types of malware
`detected by the Accused Instrumentalities (and each technology or component thereof) per hour, day,
`month, or year since the date of first sale.
`REQUEST FOR PRODUCTION NO. 62:
`Documents, communications, or things sufficient to show Your tracking of the use of the
`Accused Instrumentalities.
`REQUEST FOR PRODUCTION NO. 63:
`All documents, communications, or things relating to any surveys of Your customers regarding
`You, Your products, and Your competitors’ products.
`REQUEST FOR PRODUCTION NO. 64:
`Documents, communications, or things sufficient to show any of Your business plans within
`the past six (6) years.
`
`
`Dated: March 1, 2019
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`
`By: /s/ Lisa Kobialka
`
`Paul J. Andre (State Bar. No. 196585)
`Lisa Kobialka (State Bar No. 191404)
`James Hannah (State Bar No. 237978)
`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
`
`
`
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`FINJAN’S FIRST SET OF REQUESTS FOR PRODUCTION
`OF DOCUMENTS TO DEFENDANT (NOS. 1-64)
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`CASE NO.: 4:18-cv-07229-YGR
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`Case 4:18-cv-07229-YGR Document 79-1 Filed 07/22/20 Page 17 of 17
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`PROOF OF SERVICE
`I, Sean Robertson, am employed in the Menlo Park, California office of Kramer Levin Naftalis
`& Frankel LLP. I am over the age of 18 and not a party to the within action. My business address is
`990 Marsh Road, Menlo Park, California 94025. I am readily familiar with the firm’s practice of
`collecting and processing of mail for mailing with the U.S. Postal Service and overnight delivery
`services.
`On March 1, 2019, I caused the following document(s) to be served:
`
`FINJAN, INC.’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS
`AND THINGS TO DEFENDANT QUALYS, INC. (NOS. 1-64)
`by electronic mail, addressed as follows:
`
`Edward G. Poplawski
`Olivia M Kim
`Wilson Sonsini Goodrich & Rosati, P.C.
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071
`epoplawski@wsgr.com
`okim@wsgr.com
`
`
`Ryan R. Smith
`Christopher Don Mays
`Wilson Sonsini Goodrich & Rosati
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`rsmith@wsgr.com
`cmays@wsgr.com
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed on March 1,
`2019, in Menlo Park, California.
`
`
`
`__________________________
` Sean Robertson
`
`
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`CASE NO.: 4:18-cv-07229-YGR
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