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Case 4:18-cv-07229-YGR Document 99-3 Filed 09/04/20 Page 1 of 4
`
`
`PAUL ANDRE (SBN 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (SBN 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (SBN 237978)
`jhannah@kramerlevin.com
`KRISTOPHER KASTENS (SBN 254797)
`kkastens@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.
`
`
`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
`
`FINJAN, INC., a Delaware Corporation,
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`QUALYS INC., a Delaware Corporation,
`
`
`
`
`
`
`Defendant.
`
`Case No.: 18-cv-07229-YGR (TSH)
`
`[PROPOSED] ORDER GRANTING
`PLAINTIFF FINJAN, INC.’S AND
`DEFENDANT QUALYS INC.’S
`ADMINISTRATIVE MOTION TO FILE
`DOCUMENTS UNDER SEAL
`
`
`
`
`
`
`
`
`
`
`
`
`__________________________________________________________________________________
`[PROPOSED] ORDER GRANTING JOINT ADMIN.
`CASE NO.: 18-cv-07229-YGR
`MOTION TO FILE DOCUMENTS UNDER SEAL
`
`1 2 3 4 5 6 7 8 9
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`
`

`

`Case 4:18-cv-07229-YGR Document 99-3 Filed 09/04/20 Page 2 of 4
`
`
`Portions of Document to
`be Sealed
`
`Designating
`Party
`
`Reasons for Sealing
`
`Plaintiff Finjan, Inc.’s (“Finjan”) and Defendant Qualys Inc.’s (together, “the Parties”)
`Administrative Motion to File Documents Under Seal was brought before this Court. Upon
`consideration of this motion and the supporting declaration of Kristopher Kastens and the supporting
`declaration of Christopher Mays filed in support of the motion, the Court finds there to be good cause
`for granting the request to file certain documents under seal.
`Good cause having been shown, the Court finds that:
`There exists overriding confidentiality interests that overcome the right of public access to the
`record of the following documents:
`
`Identification of
`Documents or Portions of
`Document to be Sealed
`Joint Discovery Letter
`
`Highlighted portions of the
`Joint Discovery Letter at
`pp. 1, 2
`
`Qualys
`
`Entirety
`
`Qualys
`
`Exhibit 5 to Joint
`Discovery Letter
`
`(Qualys technical
`document)
`
`
`This information
`contains Qualys’s
`confidential
`technical and/or
`business
`information. This
`information has
`been designated by
`Qualys as “Highly
`Confidential –
`Attorneys’ Eyes
`Only.”
`
`This information
`contains Qualys’s
`confidential
`technical and/or
`business
`information. This
`information has
`been designated by
`Qualys as “Highly
`Confidential –
`Attorneys’ Eyes
`Only.”
`
`
`1
`[PROPOSED] ORDER GRANTING ADMIN.
`MOTION TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 18-cv-07229-YGR
`
`1 2 3 4 5 6 7 8 9
`
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`11
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`28
`
`

`

`Case 4:18-cv-07229-YGR Document 99-3 Filed 09/04/20 Page 3 of 4
`
`
`Portions of Document to
`be Sealed
`
`Designating
`Party
`
`Reasons for Sealing
`
`Entirety
`
`Qualys
`
`Identification of
`Documents or Portions of
`Document to be Sealed
`Exhibit 7 to Joint
`Discovery Letter
`
`(Qualys technical
`document)
`
`This information
`contains Qualys’s
`confidential
`technical and/or
`business
`information. This
`information has
`been designated by
`Qualys as “Highly
`Confidential –
`Attorneys’ Eyes
`Only.”
`
`This information
`contains Finjan’s
`confidential
`financial
`information and
`confidential
`licensing terms
`between Finjan and
`third party licensees
`or third parties
`whom Finjan has
`communicated with
`regarding its
`confidential
`licensing
`negotiations. This
`information has
`been designated by
`Finjan as “Highly
`Confidential –
`Attorneys’ Eyes
`Only.”
`
`
`Entirety
`
`Finjan
`
`Exhibit A to Joint
`Discovery Letter
`
`(Finjan’s Damages
`Contentions)
`
`
`
`
`A substantial probability exists that the overriding confidentiality interests will be prejudiced if
`the record is not sealed;
`The proposed sealing is narrowly tailored; and
`No less restrictive means exist to achieve these overriding interests.
`2
`[PROPOSED] ORDER GRANTING ADMIN.
`MOTION TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 18-cv-07229-YGR
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
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`
`

`

`Case 4:18-cv-07229-YGR Document 99-3 Filed 09/04/20 Page 4 of 4
`
`
`IT IS THEREFORE ORDERED that the Parties’ Administrative Motion to File Documents
`Under Seal is GRANTED with respect to the document set forth above. IT IS SO ORDERED.
`
`
`
`DATED:
`
`
`
`
`
`
`
`
`
`
` Honarable Thomas S. Hixson
`United States Magistrate Judge
`
`
`
`
`
`3
`[PROPOSED] ORDER GRANTING ADMIN.
`MOTION TO FILE DOCUMENTS UNDER SEAL
`
`CASE NO.: 18-cv-07229-YGR
`
`1 2 3 4 5 6 7 8 9
`
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`11
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`
`

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