`
`
`
`Juanita R. Brooks (CA SBN 75934)
`brooks@fr.com
`Jason W. Wolff (CA SBN 215819)
`wolff@fr.com
`Megan A. Chacon (CA SBN 304912)
`chacon@fr.com
`FISH & RICHARDSON P.C.
`12860 El Camino Real, Suite 400
`San Diego, CA 92130
`Telephone: (858) 678-5070 / Fax: (858) 678-5099
`Robert P. Courtney (CA SBN 248392)
`courtney@fr.com
`FISH & RICHARDSON P.C.
`3200 RBC Plaza
`60 South 6th Street
`Minneapolis, MN 55402
`Telephone: (612) 335-5070 / Fax: (612) 288-9696
`
`Proshanto Mukherji (Admitted pro hac vice)
`mukherji@fr.com
`FISH & RICHARDSON P.C.
`One Marina Park Drive
`Boston, MA 02210
`Telephone: (617) 542-5070 / Fax (617) 542-8906
`
`Attorneys for Plaintiff
`FINJAN LLC
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`(OAKLAND DIVISION)
`
`
`FINJAN LLC, a Delaware Limited Liability
`Company,
`
`Plaintiff,
`
`v.
`
`QUALYS INC., a Delaware Corporation,
`
`Defendant.
`
`Case No. 4:18-cv-07229-YGR (TSH)
`
`DECLARATION OF JASON W. WOLFF
`IN SUPPORT OF FINJAN LLC’S
`OPPOSITION TO QUALYS INC.’S
`MOTION TO STRIKE PLAINTIFF
`FINJAN LLC’S INFRINGEMENT
`CONTENTIONS
`
`
`DATE:
`TIME:
`JUDGE:
`PLACE:
`
`
`
`12/08/2020
`2:00 PM
`Hon. Yvonne Gonzalez Rogers
`Courtroom 1, 4th Floor
`
`
`
`1
`
`
`
`DECL OF JASON W. WOLFF ISO FINJAN LLC’S
`OPP TO QUALYS INC.’S MOT TO STRIKE
`Case No. 4:18-cv-07229-YGR (TSH)
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`Case 4:18-cv-07229-YGR Document 143-1 Filed 11/13/20 Page 2 of 3
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`I, Jason W. Wolff, hereby declare and state as follows:
`1.
`I am a principal in the law firm of Fish & Richardson P.C., counsel of record for
`Plaintiff Finjan LLC in the above-captioned matter. I have personal knowledge of all the facts
`contained herein and, if called as a witness, I could and would testify competently thereto.
`2.
`Attached as Exhibit A is a true and correct copy of excerpts from Plaintiff Finjan
`Inc’s Initial Disclosure of Asserted Claims and Infringement Contentions and Document
`Production Pursuant to Patent Local Rules 3-1 and 3-2 dated April 19, 2019.
`3.
`Attached as Exhibit B is a true and correct copy of Qualys Vulnerability
`Management datasheet (“vulnerability-management-datasheet.pdf”), which was produced as
`FINJAN-QUALYS 038136-038139.
`4.
`Attached as Exhibit C is a true and correct copy of Qualys Cloud Platform (“qsc18-
`day1-03-cloud-platform.pdf”), which was produced as FINJAN-QUALYS 041177-041193.
`I declare under the penalty of perjury of the laws of the United States of America that the
`foregoing is true and correct. Executed on November 13, 2020, in San Diego, California.
`
`
`
`By:
`
`
`/s/ Jason W. Wolff
`Jason W. Wolff (CA SBN 215819)
`wolff@fr.com
`
`
`
`2
`
`
`
`DECL OF JASON W. WOLFF ISO FINJAN LLC’S
`OPP TO QUALYS INC.’S MOT TO STRIKE
`Case No. 4:18-cv-07229-YGR (TSH)
`
`
`
`Case 4:18-cv-07229-YGR Document 143-1 Filed 11/13/20 Page 3 of 3
`
`
`
`
`
`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a true and correct copy of the above and foregoing
`document has been served on November 13, 2020, to all counsel of record who are deemed to
`have consented to electronic service via the Court’s CM/ECF system. Any other counsel of record
`will be served by electronic mail and regular mail.
`
`
`
`
`/s/ Jason W. Wolff
`Jason W. Wolff (CA SBN 215819)
`wolff@fr.com
`
`Attorneys for Plaintiff
`FINJAN LLC.
`
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`CERTIFICATE OF SERVICE
`Case No. 4:18-cv-07229-YGR (TSH)
`
`
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