`
`EDWARD G. POPLAWSKI (SBN 113590)
`epoplawski@wsgr.com
`OLIVIA M. KIM (SBN 228382)
`okim@wsgr.com
`TALIN GORDNIA (SBN 274213)
`tgordnia@wsgr.com
`WILSON SONSINI GOODRICH &
`ROSATI
`Professional Corporation
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071
`Telephone: (323) 210-2900
`Facsimile: (866) 974-7329
`
`Attorneys for Defendant
`QUALYS INC.
`
`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
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`OAKLAND DIVISION
`
`CASE NO.: 4:18-cv-07229-YGR (TSH)
`
`DECLARATION OF
`CHRISTOPHER D. MAYS IN
`SUPPORT OF DEFENDANT
`QUALYS INC.’S MOTION TO
`STRIKE
`
`Judge: Hon. Yvonne Gonzalez
`Rogers
`Date: December 8, 2020
`Time: 2:00pm
`Location: Zoom Teleconference1
`
`))))))))))))))
`
`FINJAN LLC, a Delaware Limited Liability
`Company,
`
`Plaintiff,
`
`v.
`
`QUALYS INC., a Delaware Corporation,
`
`Defendant.
`
`1 Per the Court’s Notice regarding Civil Law and Motion Calendars and its Order at D.I. 48.
`
`CASE NO. 4:18-cv-07229-YGR
`
`MAYS DECL. ISO MOTION TO STRIKE
`
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`
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`Case 4:18-cv-07229-YGR Document 126-1 Filed 10/30/20 Page 2 of 3
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`I, Christopher D. Mays, the undersigned, declare as follows:
`
`1.
`
`I am an attorney at law, duly licensed to practice before all the courts of the State of
`
`California, and I am an associate with the law firm of Wilson Sonsini Goodrich & Rosati, counsel
`
`for Defendant Qualys Inc. (“Qualys”). I submit this declaration in support of Defendant Qualys
`
`Inc.’s Motion to Strike Plaintiff Finjan LLC’s Infringement Contentions.
`
`2.
`
`Attached as Exhibit 1 is a true and correct copy of Finjan, Inc. v. Juniper Networks,
`
`Inc., No. 2019-2405 (Fed. Cir. October 9, 2020).
`
`3.
`
`Attached as Exhibit 2 is a true and correct copy of Qualys’s Proposed Constructions,
`
`sent via email October 23, 2019.
`
`4.
`
`Attached as Exhibit 3 is a true and correct copy of Qualys Inc.’s Preliminary
`
`Disclosure of Intrinsic and Extrinsic Evidence, dated November 6, 2019.
`
`5.
`
`Attached as Exhibit 4 is a true and correct copy of a letter I wrote to Lisa Kobialka,
`
`Finjan’s counsel of record at the time, dated July 23, 2020.
`
`6.
`
`Attached as Exhibit 5 is a true and correct copy of a letter I received from Kris
`
`Kastens, Finjan’s counsel of record at the time, dated August 13, 2020.
`
`7.
`
`Attached as Exhibit 6 is a true and correct copy of a Qualys Source Code Review
`
`Log dated September 10-12, 2019.
`
`8.
`
`Attached as Exhibit 7 is a true and correct copy of a Qualys Source Code Review
`
`Log dated October 1-4, 2019.
`
`9.
`
`Attached as Exhibit 8 is a true and correct copy of a Qualys Source Code Review
`
`Log dated January 31, 2020, February 5-6, 2020.
`
`10.
`
`Attached as Exhibit 9 is a true and correct copy of a Qualys Source Code Review
`
`Log dated February 11-14, 2020.
`
`CASE NO. 4:18-cv-07229-YGR
`
`-1-
`
`MAYS DECL. ISO MOTION TO STRIKE
`
`
`
`Case 4:18-cv-07229-YGR Document 126-1 Filed 10/30/20 Page 3 of 3
`
`11.
`
`Attached as Exhibit 10 is a true and correct copy of a Qualys Source Code Review
`
`Log dated July 1-2, 2020.
`
`12.
`
`Attached as Exhibit 11 is a true and correct copy of relevant, annotated excerpts of
`
`D.I. 100-11, Finjan’s Infringement Contentions, dated April 19, 2019.
`
`I declare under penalty of perjury of the laws of the United States of America that the
`
`foregoing is true and correct and that this Declaration is executed this 30th day of October, 2020,
`
`in Morgan Hill, California.
`
`By:
`
`/s/ Christopher D. Mays
`Christopher D. Mays
`
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`CASE NO. 4:18-cv-07229-YGR
`
`-2-
`
`MAYS DECL. ISO MOTION TO STRIKE
`
`
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