Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 1 of 13
`Case 4:18-cv-07229—YGR Document 79-7 Filed 07/22/20 Page 1 of 13
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`EXHIBIT 7
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`EXHIBIT 7
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`Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 2 of 13
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`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) 210-2901
`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
`
`DEFENDANT QUALYS INC.’S
`SECOND SUPPLEMENTAL
`OBJECTIONS AND RESPONSES
`TO FINJAN, INC.’S SECOND SET
`OF INTERROGATORIES (NOS. 7-
`11)
`
`)))))))))))
`
`FINJAN, INC., a Delaware Corporation,
`
`Plaintiff,
`
`v.
`
`QUALYS INC., a Delaware Corporation,
`
`Defendant.
`
`CASE NO. 4:18-cv-07229-YGR
`
`QUALYS’S SECOND SUPPLEMENTAL
`RESPONSES TO FINJAN’S SECOND SET OF
`INTERROGATORIES (NOS. 7-11)
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`Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 3 of 13
`
`Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure and the Local Rules of
`the United States District Court for the Northern District of California, Defendant Qualys Inc.
`(“Qualys”) hereby supplements its responses and objections to Plaintiff Finjan, Inc.’s Second Set of
`Interrogatories to Qualys (Nos. 7-11).
`
`PRELIMINARY STATEMENT
`
`The following responses are made solely for the purpose of, and in relation to, this action.
`Each response is provided subject to all appropriate objections (including, without limitation,
`objections concerning competency, relevancy, materiality, propriety, and admissibility) that would
`require the exclusion of any statement contained herein if the statement were made by a witness
`present and testifying in court. All such objections and grounds are therefore reserved and may be
`interposed at the time of trial.
`The following responses are based on the facts and information presently known and
`available to Qualys. Discovery, investigation, research, and analysis are ongoing in this case and
`may disclose the existence of additional facts, add meaning to known facts, establish entirely new
`factual conclusions or legal contentions, or possibly lead to additions, variations, and changes to
`these responses. Qualys reserves the right to change or supplement these responses as additional
`facts are discovered, revealed, recalled, or otherwise ascertained.
`
`GENERAL OBJECTIONS
`
`In addition to any specifically stated objections, each of Qualys’s responses herein is subject
`to and incorporates the following general objections:
`1.
`Qualys objects to each interrogatory and each definition to the extent it purports to
`impose obligations greater or more extensive than those required by the Federal Rules of Civil
`Procedure, the Local Rules of the United States District Court for the Northern District of California,
`or other applicable law.
`2.
`Qualys objects to each interrogatory and definition to the extent it purports to request
`information that cannot be found in the course of a reasonable search.
`
`CASE NO. 4:18-cv-07229-YGR
`
`-1-
`
`QUALYS’S SECOND SUPPLEMENTAL
`RESPONSES TO FINJAN’S SECOND SET OF
`INTERROGATORIES (NOS. 7-11)
`
`

`

`Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 4 of 13
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`Qualys’s partial response to any interrogatory is not a waiver of its objection or right
`3.
`to object to the interrogatory, or any part thereof, or to any additional, supplemental, or further
`interrogatory or part thereof, but is instead offered in an effort to resolve a potential discovery
`dispute.
`Qualys objects to each interrogatory to the extent it seeks information that is neither
`4.
`relevant to any party’s claim or defense nor proportional to the needs of the case.
`5.
`Qualys objects to each interrogatory to the extent it is unreasonably cumulative or
`duplicative of other discovery requests, or seeks information that is obtainable from some other
`source that is more convenient, less burdensome, or less expensive.
`6.
`Qualys objects to each interrogatory to the extent it is overly broad, fails to
`reasonably identify the information sought, is unduly burdensome, and is posed for improper
`purposes, including, without limitation, embarrassment, undue annoyance, harassment, oppression,
`delay, or to increase the expense of litigation or to the extent it calls for a legal conclusion or opinion.
`7.
`Qualys objects to each interrogatory to the extent it seeks information for which the
`burden or expense of obtaining and disclosing outweighs its likely benefit in resolving the issues of
`this action.
`Qualys objects to each interrogatory to the extent it fails to describe with reasonable
`8.
`particularity the information requested.
`9.
`To the extent that any interrogatory may be construed as calling for information
`which is subject to a claim of privilege, including, without limitation, the attorney-client privilege
`and attorney work-product doctrine, Qualys hereby claims such privilege and objects to the
`disclosure of the information. Such information as may hereafter be provided in response to the
`interrogatory should not include any information subject to such privileges and doctrines, but the
`inadvertent disclosure of privileged information shall not constitute a waiver of any applicable
`privilege.
`Qualys objects to each interrogatory to the extent it is vague or ambiguous.
`10.
`Qualys objects to each interrogatory to the extent it seeks confidential, commercially
`11.
`sensitive, trade secret, and/or proprietary information of a non-party or information covered by a
`
`CASE NO. 4:18-cv-07229-YGR
`
`-2-
`
`QUALYS’S SECOND SUPPLEMENTAL
`RESPONSES TO FINJAN’S SECOND SET OF
`INTERROGATORIES (NOS. 7-11)
`
`

`

`Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 5 of 13
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`confidentiality agreement, or information that is otherwise protected from disclosure pursuant to
`Rule 26(c)(1)(G) of the Federal Rules of Civil Procedure or Rule 501 of the Federal Rules of
`Evidence. Qualys will not produce such information unless the non-party agrees to the terms of the
`protective order entered in this case or consents in writing to the disclosure of that information to
`Finjan.
`Qualys objects each interrogatory to the extent it seeks information that is not in
`12.
`Qualys’s possession, custody, or control.
`13.
`Qualys objects to any interrogatory that seeks information, documents, or things
`subject to confidentiality agreements, protective orders, and/or any other obligation pursuant to
`which Qualys is required to protect and/or maintain the confidentiality of any third party’s
`documents. Should an interrogatory call for such information, documents, or things, Qualys will
`act reasonably to obtain the consent of the third party to produce the information.
`14.
`Qualys objects generally to the interrogatories to the extent that they prematurely call
`for discovery concerning, among other things, Qualys products, downstream products, and facts and
`contentions relating to claim construction, non-infringement, invalidity, and other claims and
`defenses pursuant to Patent Local Rule 2-5.
`
`OBJECTIONS TO DEFINITIONS
`
`Qualys objects to Finjan’s definition of “You,” “Your,” and “Defendant” as overly
`1.
`broad and unduly burdensome. For purposes of these interrogatories, reference to “You,” “Your,”
`and “Defendant” shall refer to Defendant Qualys Inc. only.
`2.
`Qualys objects to Finjan’s definition of “Finjan” as overly broad and unduly
`burdensome. For purposes of these interrogatories, reference to “Finjan” shall refer to Plaintiff
`Finjan, Inc. only.
`3.
`Qualys objects to Finjan’s definition of “Accused Instrumentalities” as overly broad
`and unduly burdensome. For purposes of these interrogatories, reference to the “Accused
`Instrumentalities” shall refer to the Qualys products and services that Finjan has specifically
`identified in its Complaint and Infringement Contentions.
`
`CASE NO. 4:18-cv-07229-YGR
`
`-3-
`
`QUALYS’S SECOND SUPPLEMENTAL
`RESPONSES TO FINJAN’S SECOND SET OF
`INTERROGATORIES (NOS. 7-11)
`
`

`

`Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 6 of 13
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`Qualys objects to the definition of “relate to,” “reflecting,” “relating to,”
`4.
`“concerning,” and “any variations thereof” and all requests incorporating these terms, as overly
`broad, vague, ambiguous, unintelligible, requiring subjective judgment on the part of Qualys and/or
`its attorneys, and calling for conclusions or opinions of counsel in violation of the attorney work
`product doctrine.
`the definitions of “person,” “entity,” “document(s),”
`to
`5.
`Qualys objects
`“communication,” and “thing” to the extent they call for information that exceeds the scope
`contemplated by the Federal Rules of Civil Procedure and the Local Rules of the United States
`District Court for the Northern District of California, or other applicable law.
`
`OBJECTIONS TO INSTRUCTIONS
`
`Qualys objects to the instructions accompanying Finjan’s interrogatories to the extent
`1.
`that such instructions are not consistent with the provisions of the Federal Rules of Civil Procedure,
`Local Rules of the United States District Court for the Northern District of California, or other
`applicable law, or to the extent that the instructions purport to require Qualys to take actions or
`provide information not required or which exceed the scope of the Federal Rules of Civil Procedure,
`Local Rules of the United States District Court for the Northern District of California, or other
`applicable law.
`
`SPECIFIC OBJECTIONS AND RESPONSES TO INTERROGATORIES
`
`INTERROGATORY NO. 7:
`For each of the Accused Instrumentalities, provide a complete list of which products and
`services the Accused Instrumentalities is incorporated into or used by, and when such incorporation
`or use first occurred.
`RESPONSE TO INTERROGATORY NO. 7:
`In addition to the foregoing general objections, which are expressly incorporated herein,
`Qualys objects to this interrogatory on the grounds and to the extent that it: (1) is compound in that
`it contains at least two discrete subparts (provide a complete list of which products and services the
`Accused Instrumentalities is incorporated into or used by; and identify when such incorporation or
`
`CASE NO. 4:18-cv-07229-YGR
`
`-4-
`
`QUALYS’S SECOND SUPPLEMENTAL
`RESPONSES TO FINJAN’S SECOND SET OF
`INTERROGATORIES (NOS. 7-11)
`
`

`

`Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 7 of 13
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`use first occurred); (2) is overbroad and unduly burdensome; (3) seeks information that is irrelevant
`to the claims and defenses at issue in this case and is not proportional to the needs of the case; (4)
`seeks information that may be covered under one or more applicable privileges and/or may be
`covered by third-party confidentiality agreements; and (5) is vague and ambiguous as to at least the
`phrases “incorporated into” and “used by.” Qualys cannot discern from the Interrogatory what
`Finjan considers the difference to be between an “Accused Instrumentality,” a “product,” and a
`“service,” and so therefore cannot understand what Finjan means when it seeks a list of “products”
`and “services” into which the “Accused Instrumentalities” are offered. To the best of Qualys’
`understanding, this Interrogatory seeks a list of commercial products that include one or more of the
`Accused Instrumentalities, and Qualys will respond to this Interrogatory on that basis.
`Subject to and without waiver of the foregoing general and specific objections, Qualys
`responds as follows: Pursuant to Fed. R. Civ. P. 33(d), and to the extent any exist in Qualys’s
`possession, custody, or control, Qualys will produce documents that provide the information
`responsive to this interrogatory. For example, responsive information can be determined at least
`from
`the
`following
`documents:
` QUALYS00000984, QUALYS00030017-114,
`QUALYS00030115-219, QUALYS00030220-319, QUALYS00030320-424, QUALYS00030425-
`525, QUALYS00030526-623, QUALYS00030624-631, QUALYS00030632-740,
`and
`QUALYS00030741-851.
`Discovery is ongoing, and Qualys reserves the right to supplement this response based on
`the results of that investigation.
`FIRST SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 7:
`In addition to the foregoing responses and objections, none of which are waived, Qualys
`further states that malware detection capability are Bundled with web application security (WAS).
`The antivirus engine used in Qualys Malware Detection is provided by Trend Micro Inc. Further,
`Qualys physical appliances are currently provided by SYNNEX Corporation pursuant to a
`manufacturing services agreement dated March 1, 2011. For its cloud services, Qualys relies on
`large third-party data center vendors and are located in the United States, Canada, Switzerland, the
`Netherlands and India.
`
`CASE NO. 4:18-cv-07229-YGR
`
`-5-
`
`QUALYS’S SECOND SUPPLEMENTAL
`RESPONSES TO FINJAN’S SECOND SET OF
`INTERROGATORIES (NOS. 7-11)
`
`

`

`Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 8 of 13
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`INTERROGATORY NO. 8:
`Identify the basis for customer demand for the Accused Instrumentalities, including the
`nature of and/or technological features that makes such products valuable in the marketplace and to
`your customers, and any surveys or analysis of customer demand that either You or a Third Party
`has performed regarding the use, marketability, or competitive nature of the Accused
`Instrumentalities, including the identification of any persons with information of the foregoing and
`documents supporting Your response.
`RESPONSE TO INTERROGATORY NO. 8:
`In addition to the foregoing general objections, which are expressly incorporated herein,
`Qualys objects to this Interrogatory on the ground and to the extent that it:
`(1) is compound in that it contains at least four discrete subparts (identify nature of and/or
`technological features that makes such products valuable; identify any surveys or analysis of
`customer demand; identify persons; and identify documents); (2) is overbroad and unduly
`burdensome in that it seeks the identification of any and all persons and documents that may identify
`the basis for customer demand, however trivial or redundant; and (3) seeks information that is
`irrelevant to the claims and defenses at issue in this case and is not proportional to the needs of the
`case in that, again, it seeks to impose an excessive burden on Qualys of identifying any and all
`persons and documents with any knowledge or information regarding customer demand; (4) seeks
`information that may be covered under one or more applicable privileges and/or may be covered by
`third-party confidentiality agreements; (5) seeks information that is not in Qualys’s possession,
`custody, or control (information that “a Third Party has” and the basis of customer demand which,
`by its nature, pertains to third party’s state of mind); and (6) seeks expert opinion evidence regarding
`the mental state of third parties – i.e., why third parties buy Qualys’s products. This is properly the
`subject of expert discovery and is therefore premature.
`Subject to and without waiver of the foregoing general and specific objections, Qualys
`responds as follows: Pursuant to Fed. R. Civ. P. 33(d), and to the extent any exist in Qualys’s
`possession, custody, or control, Qualys will produce documents that provide the information
`responsive to this interrogatory. For example, responsive information can be determined at least
`
`CASE NO. 4:18-cv-07229-YGR
`
`-6-
`
`QUALYS’S SECOND SUPPLEMENTAL
`RESPONSES TO FINJAN’S SECOND SET OF
`INTERROGATORIES (NOS. 7-11)
`
`

`

`Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 9 of 13
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` QUALYS00000984, QUALYS00030017-114,
`documents:
`following
`the
`from
`QUALYS00030115-219, QUALYS00030220-319, QUALYS00030320-424, QUALYS00030425-
`525, QUALYS00030526-623, QUALYS00030624-631, QUALYS00030632-740,
`and
`QUALYS00030741-851.
`Discovery is ongoing, and Qualys reserves the right to supplement this response based on
`the results of that investigation.
`INTERROGATORY NO. 9:
`Describe in detail any non-infringing alternative product, technology or process or design
`around of the Asserted Patents that you contend has been or could be used as an alternative to the
`Accused Instrumentalities. Your identification should include a description of the technology that
`allows the non-infringing alternative product or design around to achieve the same functionality as
`the Accused Instrumentality; the costs to develop, use, or manufacture such product; actual or
`forecasted revenues and profits of such product; any valuations of such product; when and how any
`of the foregoing information was compiled or calculated.
`RESPONSE TO INTERROGATORY NO. 9:
`In addition to the foregoing general objections, which are expressly incorporated herein,
`Qualys objects to this interrogatory.
`Qualys objects that this interrogatory is premature. The Court has not yet construed any
`terms of the asserted patents, which is a necessary precursor to identifying any non-infringing
`alternatives. Moreover, this Interrogatory is properly the subject of expert opinion testimony, and
`is therefore for that additional reason.
`Qualys objects that this interrogatory is overbroad and unduly burdensome. It requires
`Qualys to identify any and all non-infringing alternatives that (a) actually exist, (b) may exist, and/or
`(c) may not exist, and the Interrogatory is not limited to alternatives that Qualys may advance at
`trial. Further, this Interrogatory improperly seeks speculation from Qualys regarding what it might
`cost to develop, use, or manufacture such a non-infringing alternative; and forecasted revenues from
`such speculative non-infringing alternatives. Such speculative is the realm of opinion and outside
`the proper scope of a Rule 33 Interrogatory. For these same reasons, Qualys objects to this
`
`CASE NO. 4:18-cv-07229-YGR
`
`-7-
`
`QUALYS’S SECOND SUPPLEMENTAL
`RESPONSES TO FINJAN’S SECOND SET OF
`INTERROGATORIES (NOS. 7-11)
`
`

`

`Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 10 of 13
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`Interrogatory as seeking information that is irrelevant to the claims and defenses at issue in this case
`and/or that is not proportional to the needs of the case.
`Qualys objects that this interrogatory is compound and contains at least five multiple,
`discrete subparts (identify any non-infringing alternative product; identify the costs to develop, use,
`or manufacture such product; identify actual or forecasted revenues and profits; any valuations of
`such product; and identify when and how the foregoing information was compiled or calculated).
`By Qualys’s count, this interrogatory exceeds the maximum permitted number of discrete
`interrogatories and subparts.
`Qualys objects that this interrogatory seeks information protected by attorney-client
`privilege, attorney work product, or other similar privileges.
`FIRST SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 9:
`Subject to and without waiving the foregoing responses and objections, Qualys further
`objects that Finjan has failed to provide infringement contentions that sufficiently identify specific
`infringing components of the Accused Instrumentalities and, thus, Qualys lacks sufficient
`knowledge and information to identify non-infringing alternatives.
`INTERROGATORY NO. 10:
`For each of the Accused Instrumentalities, identify and describe all Databases that are
`incorporated or used, either directly or indirectly, by the Accused Instrumentalities; such
`identification and description should at least include the type of database, what type and category
`of information the Database stores, where geographically the Database is located, any code or
`internal names for the Database, and a description of how the Database is organized.
`RESPONSE TO INTERROGATORY NO. 10:
`In addition to the foregoing general objections, which are expressly incorporated herein,
`Qualys objects to this interrogatory on the ground and to the extent that it: (1) is compound in that
`it contains multiple, discrete subparts (describe the Databases; identify geographic location of
`databases); (2) is overbroad and unduly burdensome in that it asks Qualys to identify and describe
`all Databases that are incorporated or used, either directly or indirectly, by the Accused
`Instrumentalities; and (3) seeks information that is irrelevant to the claims and defenses at issue in
`
`CASE NO. 4:18-cv-07229-YGR
`
`-8-
`
`QUALYS’S SECOND SUPPLEMENTAL
`RESPONSES TO FINJAN’S SECOND SET OF
`INTERROGATORIES (NOS. 7-11)
`
`

`

`Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 11 of 13
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`this case and is not proportional to the needs of the case. Qualys further objects that Finjan has
`exceeded the maximum permitted number of discrete interrogatories and subparts.
`FIRST SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 10:
`Subject to and without waiving the foregoing responses and objections, Qualys objects to
`this interrogatory on the ground and to the extent that it is vague and ambiguous as to at least the
`phrase “Database”. Qualys, thus, is unable to determine whether Finjan has accused any “Database”
`of infringement.
`INTERROGATORY NO. 11:
`State in detail the monetary amount of damages that Finjan is entitled for Qualys’
`infringement of each of the Asserted Patents, should it prevail in this action, and the complete legal
`and factual basis for your damages calculation, including, but not limited to, the royalty base(s) and
`royalty rate(s), comparable/non-comparable licenses, any apportionment or offset, the underlying
`methodology, nexus between the patented features and the corresponding damages amount. Your
`response should include an explanation of the underlying methodology and an identification of all
`factors (including but not limited to the factors set forth in Georgia Pacific Corp. v. United States
`Plywood Corp., 318 F. Supp. 1116 (S.D.N.Y. 1970)) that Qualys contends is relevant, or would be
`relevant, to the determination of damages between Finjan and Qualys for the Asserted Patents, any
`alleged apportionment between the patented and non-patented features, and a specific identification
`of all documents and witnesses that support all of Qualys’ contentions.
`RESPONSE TO INTERROGATORY NO. 11:
`In addition to the foregoing general objections, which are expressly incorporated herein,
`Qualys objects to this interrogatory on the ground that it: (1) it is premature – Finjan has not yet
`produced any damages contentions, and this is properly the subject of expert testimony; (2) is overly
`broad and unduly burdensome in that it seeks information without specifying a relevant and
`temporal scope and requests the identification of all witnesses and documents; (3) seeks information
`that is irrelevant to the claims and defenses at issue in this case and is not proportional to the needs
`of the case; (4) is compound in that it contains at least seven discrete subparts (identify the royalty
`base(s) and rate(s); identify comparable/non-comparable licenses; identify any apportionment or
`
`CASE NO. 4:18-cv-07229-YGR
`
`-9-
`
`QUALYS’S SECOND SUPPLEMENTAL
`RESPONSES TO FINJAN’S SECOND SET OF
`INTERROGATORIES (NOS. 7-11)
`
`

`

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`Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 12 of 13
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`offset; describe underlying methodology; describe nexus between patented features and damages
`amount; identify all documents; and identify all witnesses); and (5) seeks information protected by
`attorney-client privilege, attorney work product, or other similar privileges. Qualys further objects
`that Finjan has exceeded the maximum permitted number of discrete interrogatories and subparts.
`FIRST SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 11:
`Subject to and without waiving the foregoing responses and objections, Qualys further
`responds by incorporating by reference Qualys’s Responsive Damages Contentions, served
`December 18, 2019.
`
`DATED: July 20, 2020
`
`By:
`
`/s/ Ryan R. Smith
`RYAN R. SMITH
`
`Counsel for Defendant
`QUALYS INC.
`
`CASE NO. 4:18-cv-07229-YGR
`
`-10-
`
`QUALYS’S SECOND SUPPLEMENTAL
`RESPONSES TO FINJAN’S SECOND SET OF
`INTERROGATORIES (NOS. 7-11)
`
`

`

`Case 4:18-cv-07229-YGR Document 79-7 Filed 07/22/20 Page 13 of 13
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`
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`CERTIFICATE OF SERVICE
`I, Christina Tong, am employed in the Los Angeles, California office of Wilson Sonsini
`Goodrich & Rosati, P.C. I am over the age of 18 and not a party to the within action. My
`business address is 633 West Fifth Street, Suite 1550, Los Angeles, California 90071.
`On July 20, 2020, I caused the following document to be served:
` DEFENDANT QUALYS INC.’S SECOND SUPPLEMENTAL OBJECTIONS AND
`RESPONSES TO FINJAN, INC.’S SECOND SET OF INTERROGATORIES (NOS.
`7-11)
`
`via e-mail on the following individuals:
` Paul Andre (pandre@kramerlevin.com );
` Aaron M. Frankel (AFrankel@KRAMERLEVIN.com);
` Kristopher Benjamin Kastens (kkastens@kramerlevin.com);
` Lisa Kobialka (lkobialka@kramerlevin.com ); and
` James Hannah (jhannah@kramerlevin.com).
`
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` declare under penalty of perjury under the laws of the State of California and the United
`States that each of the above statement is true and correct.
`Executed on July 20, 2020, at Los Angeles, California.
`
`
`
`
`By:
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`/s/ Christina Tong
`Christina Tong
`
`
`
`-1-
`
`CERTIFICATE OF SERVICE
`CASE NO.:4:18-CV-07229-YGR
`
`