`
`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
`
`))))))))))))))
`
`FINJAN LLC, a Delaware Limited Liability
`Company,
`
`Plaintiff,
`
`v.
`
`QUALYS INC., a Delaware Corporation,
`
`Defendant.
`
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`CASE NO. 4:18-cv-07229-YGR
`
`MAYS DECL. ISO MOTION TO STRIKE
`
`
`
`Case 4:18-cv-07229-YGR Document 158-1 Filed 01/23/21 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 Portions of Plaintiff Finjan LLC’s Infringement and Damages Expert
`
`Reports.
`
`2.
`
`Attached as Exhibit 1 is a true and correct copy of selected portions of the Expert
`
`Report of Nenad Medvidovic, Ph.D., served December 2, 2020.
`
`3.
`
`Attached as Exhibit 2 is a true and correct copy of selected portions of the Opening
`
`Expert Report of Eric Cole, Ph.D., served December 1, 2020.
`
`4.
`
`Attached as Exhibit 3 is a true and correct copy of selected portions of the Expert
`
`Report of DeForest McDuff, Ph.D., served December 1, 2020.
`
`5.
`
`6.
`
`Attached as Exhibit 4 is a true and correct copy of U.S. Patent No. 8,225,408.
`
`Attached as Exhibit 5 is a true and correct copy of Finjan’s Infringement Contentions
`
`Claim Chart for U.S. Patent No. 8,225,408.
`
`7.
`
`Attached as Exhibit 6 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.
`
`8.
`
`Attached as Exhibit 7 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.
`
`9.
`
`Attached as Exhibit 8 is a true and correct copy of selected portions of Finjan’s
`
`Damages Contentions, served October 30, 2019.
`
`10.
`
`Attached as Exhibit 9 is a true and correct copy of selected portions of the Deposition
`
`Transcript of Holger Kruse, taken on September 14, 2020.
`
`CASE NO. 4:18-cv-07229-YGR
`
`-1-
`
`MAYS DECL. ISO MOTION TO STRIKE
`
`
`
`Case 4:18-cv-07229-YGR Document 158-1 Filed 01/23/21 Page 3 of 3
`
`11.
`
`Attached as Exhibit 10 is a true and correct copy of an index prepared for the Court’s
`
`convenience detailing the identifying: (1) the paragraph(s) of Medvidovic’s expert report to be
`
`struck; (2) the claim element the paragraph(s) pertains to; (3) pincites to the relevant portion of the
`
`Infringement Contentions; and (4) a brief statement regarding the basis for striking the paragraph(s).
`
`12.
`
`13.
`
`Attached as Exhibit 11 is a true and correct copy of FINJAN-QUALYS 042650.
`
`Attached as Exhibit 12 is a true and correct copy of selected portions of the Rebuttal
`
`Expert Report of Dr. Avi. Rubin Regarding U.S. Patent No. 8,225,408, served January 12, 2021
`
`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 22 day of January, 2021, 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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