`Case 4:18-cv-07229—YGR Document 80-1 Filed 07/22/20 Page 1 of 3
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`QUALYS EXHIBIT B
`QUALYS EXHIBIT
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`Case 4:18-cv-07229-YGR Document 80-1 Filed 07/22/20 Page 2 of 3
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`Gordnia, Talin
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`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Karineh Khachatourian <karinehk@rimonlaw.com>
`Sunday, April 5, 2020 7:57 PM
`Williams, Daniel; dhonda@barracuda.com
`Frankel, Aaron; Gordnia, Talin; Mays, Christopher; Smith, Ryan; Poplawski, Edward
`RE: Finjan v. Qualys, Case No. 18-cv-07229-YGR - Request for Protected Materials
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`[External]
`So long as the documents are marked as AEO BNI has no objection. Thank you.
`
`From: Williams, Daniel
`Sent: Tuesday, March 31, 2020 5:10 PM
`To: Karineh Khachatourian ; dhonda@barracuda.com
`Cc: Frankel, Aaron ; Gordnia, Talin ; Mays, Christopher ; Smith, Ryan ; Poplawski, Edward
`Subject: Finjan v. Qualys, Case No. 18-cv-07229-YGR - Request for Protected Materials
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`Counsel,
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`Defendant Qualys served Finjan with discovery requests in the matter Finjan, Inc. v. Qualys Inc., Case No. 18-cv-07229-
`YGR (N.D. Cal.), in which Qualys seeks the production of documents that may contain the confidential information of
`your client, Barracuda. See, e.g., Qualys’ Request for Production No. 24 (attached). By way of preview, the documents
`sought by Qualys generally include licensing/settlement negotiations. We request that you reach out separately to
`Qualys’ counsel (copied here) to reach agreement as to the scope of documents that your client consents to be
`produced and to resolve any objections.
`
`Let us know within 14 days from today if your client objects to the production of the requested confidential information.
`See Protective Order, section 11(c) (attached). Unless we receive a response within that time period, Finjan will move
`forward with the production.
`
`Kind regards,
`Dan
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`
`
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`Daniel Williams
`Associate
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`Kramer Levin Naftalis & Frankel LLP
`990 Marsh Road, Menlo Park, California 94025
`T 650.752.1735 F 650.752.1800
`ddwilliams@kramerlevin.com
`
`Bio
`Follow our blog, Bio Law Blog
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`This communication (including any attachments) is intended solely for the recipient(s) named above and may contain
`information that is confidential, privileged or legally protected. Any unauthorized use or dissemination of this
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`Case 4:18-cv-07229-YGR Document 80-1 Filed 07/22/20 Page 3 of 3
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`communication is strictly prohibited. If you have received this communication in error, please immediately notify the
`sender by return e-mail message and delete all copies of the original communication. Thank you for your cooperation.
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