Case 4:18-cv-07229-YGR Document 156-1 Filed 01/22/21 Page 1 of 3
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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) 210-2900
`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
`
`DECLARATION OF CHRISTOPHER
`MAYS IN SUPPORT OF
`ADMINISTRATIVE MOTION TO
`FILE DOCUMENTS UNDER SEAL
`
`)))))))))))
`
`FINJAN, INC.,
`
`Plaintiff,
`
`v.
`
`QUALYS INC.,
`
`Defendant.
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`CASE NO. 4:18-cv-07229-YGR
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`DECLARATION OF CHRISTOPHER MAYS
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`Case 4:18-cv-07229-YGR Document 156-1 Filed 01/22/21 Page 2 of 3
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`I, Christopher Mays, declare as follows:
`1.
`I am an attorney with the law firm of Wilson, Sonsini, Goodrich, & Rosati
`(“WSGR”), counsel of record for Defendant Qualys Inc. (“Qualys”). I have personal knowledge of
`the facts set forth in this declaration and can testify competently to those facts. I make this
`declaration in support of the parties’ Administrative Motion to File Documents Under Seal pursuant
`to Civil Local Rules 79-5(d) and 79-5(e).
`2.
`I have reviewed the below documents and confirmed that they contain sealable
`information belonging to Qualys. The reasons justifying sealing these documents are provided
`below.
`Exhibit 1 to Defendant Qualys Inc.’s Motion to Strike Portions of Plaintiff Finjan
`3.
`LLC’s Infringement and Damages Expert Reports is an excerpt of selected portions of Finjan’s
`Infringement Expert Report (Expert Report of Nenad Medvidovic, Ph.D.) and contains technical
`analysis of Qualys’s products. As such, the document contains sensitive information and was
`marked by Finjan as “HIGHLY CONFIDENTIAL – ATTORNEYS EYES’ ONLY.” It is therefore
`sealable as containing Qualys’s technical information.
`4.
`Exhibit 2 to Defendant Qualys Inc.’s Motion to Strike Portions of Plaintiff Finjan
`LLC’s Infringement and Damages Expert Reports is an excerpt of selected portions of Finjan’s
`Infringement Expert Report (Opening Expert Report of Eric Cole, Ph.D.) and contains technical
`analysis of Qualys’s products and reference to Qualys Source Code. As such, the document contains
`sensitive information and was marked by Finjan as “HIGHLY CONFIDENTIAL – ATTORNEYS
`EYES’ ONLY – SOURCE CODE.” It is therefore sealable as containing Qualys’s technical
`information and source code.
`5.
`Exhibit 3 to Defendant Qualys Inc.’s Motion to Strike Portions of Plaintiff Finjan
`LLC’s Infringement and Damages Expert Reports is an excerpt of selected portions of Finjan’s
`Infringement Expert Report (Expert Report of DeForest McDuff, Ph.D ) and contains analysis of
`Qualys’s non-public financials. As such, the document contains sensitive information and was
`marked by Finjan as “HIGHLY CONFIDENTIAL.” It is therefore sealable as containing Qualys’s
`financial information.
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`CASE NO. 3:18-cv-07229-YGR
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`DECLARATION OF CHRISTOPHER MAYS
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`Case 4:18-cv-07229-YGR Document 156-1 Filed 01/22/21 Page 3 of 3
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`Exhibit 9 to Defendant Qualys Inc.’s Motion to Strike Portions of Plaintiff Finjan
`6.
`LLC’s Infringement and Damages Expert Reports is an excerpt of selected portions of the deposition
`transcript of Holger Kruse, taken on September 14, 2020, which contains technical discussion of
`Qualys’s products. As such, the document contains sensitive information. It is therefore sealable
`as containing Qualys’s technical information.
`7.
`Exhibit 12 to Defendant Qualys Inc.’s Motion to Strike Portions of Plaintiff Finjan
`LLC’s Infringement and Damages Expert Reports is an excerpt of selected portions of Qualys’s
`Rebuttal Report (Rebuttal Expert Report of Dr. Avi. Rubin Regarding U.S. Patent No. 8,225,408)
`and contains technical analysis of Qualys’s products. As such, the document contains sensitive
`information and was marked by Qualys as “HIGHLY CONFIDENTIAL – OUTSIDE
`ATTORNEYS EYES’ ONLY.” It is therefore sealable as containing Qualys’s technical
`information.
`Defendant Qualys Inc.’s Motion to Strike Portions of Plaintiff Finjan LLC’s
`8.
`Infringement and Damages Expert Reports letter quotes and/or describes portions of the above
`exhibits. It is therefore sealable for the foregoing reasons.
`
`I declare under the penalty of perjury under the laws of the United States of America that each of
`the above statements is true and correct. Executed on January 22, 2021, in Morgan Hill, CA.
`
`/s/ Christopher D. Mays
`Christopher D. Mays
`
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`CASE NO. 3:18-cv-07229-YGR
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`DECLARATION OF CHRISTOPHER MAYS
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