Case 4:18-cv-07229-YGR Document 161 Filed 01/26/21 Page 1 of 3
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`Juanita R. Brooks (CA SBN 75934)
`brooks@fr.com
`Roger A. Denning (CA SBN 228998)
`denning@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
`Phone: (858) 678-5070 /Fax: (858) 678-5099
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`Robert P. Courtney (CA SBN 248392)
`courtney@fr.com
`FISH & RICHARDSON P.C.
`3200 RBC Plaza
`60 South 6th Street
`Minneapolis, MN 55402
`Phone: (612) 335-5070 /Fax: (612) 288-9696
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`Proshanto Mukherji (pro hac vice)
`mukherji@fr.com
`FISH & RICHARDSON P.C.
`One Marina Park Drive
`Boston, MA 02210
`Phone: (617) 542-5070/ Fax (617) 542-8906
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`Attorneys for Plaintiff
`FINJAN, LLC
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`(OAKLAND DIVISION)
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`FINJAN, LLC, a Delaware Limited Liability
`Company,
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`Case No. 4:18-cv-07229-YGR (TSH)
`Hon. Yvonne Gonzalez Rogers
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`Plaintiff,
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`v.
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`QUALYS INC., a Delaware Corporation,
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`Defendant.
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`DECLARATION OF JASON W. WOLFF
`IN SUPPORT OF QUALYS INC.’S
`MOTION TO FILE UNDER SEAL
`PORTIONS OF QUALYS’MOTION TO
`STRIKE PORTIONS OF PLAINTIFF
`FINJAN LLC’S INFRINGEMENT AND
`DAMAGES EXPERT REPORTS, AND
`EXHIBITS 1-3, 8-9, AND 12
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`DECL. OF WOLFF ISO QUALYS’ ADMIN MFUS
`Case No. 4:18-cv-07229-YGR (TSH)
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`Case 4:18-cv-07229-YGR Document 161 Filed 01/26/21 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.
`As required under Civil L.R. 79-5(d)(1)(A), Civil L.R. 79-5(e), and this Court’s
`Standing Order, the basis for asserting confidentiality and the grounds for filing under seal the
`documents listed below are as follows:
`3.
`Sealed Exhibit 3 to the Declaration of Christopher Mays in Support of [Qualys’]
`Administrative Motion to File Documents Under Seal (ECF No. 156-1, “Mays Declaration”)
`includes confidential and proprietary financial and licensing information relating to agreements
`between Finjan, LLC and multiple non-parties to the litigation. The agreements upon which the
`information disclosed in Exhibit 3 is based are designated as confidential information with
`disclosure obligations to non-parties to maintain their confidentiality. Accordingly, the summary
`royalty rate information found at:
` page 3, middle paragraph revealing % rates;
` page 4, penultimate paragraph identifying % rates;
` page 91, Table 6, “Impact” field for GP factors 1 and 4 revealing % rates as well as
`the rates in the first sentence of paragraph 126; and at
` page 92, second to last sentence of item “(2)” revealing % rates
`is all information reflecting confidential licensing and financial information of Finjan, LLC and its
`licensees that falls under the protective order. Moreover, it is not material for the resolution of the
`pending motion, so the public would not be harmed by not having this confidential financial
`information. Accordingly, good cause and compelling reasons exist to seal the rate information
`found at pages 3, 4, 91 and 92 of Exhibit 3 to the Mays Declaration.
`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 January 26, 2021, in San Diego, California.
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`/s/ Jason W. Wolff
`Jason W. Wolff (CA SBN 215819)
`wolff@fr.com
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`DECL. OF WOLFF ISO QUALYS’ ADMIN MFUS
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`Case 4:18-cv-07229-YGR Document 161 Filed 01/26/21 Page 3 of 3
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a true and correct copy of the above and foregoing
`document has been served on January 26, 2021, 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.
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`/s/ Jason W. Wolff
`Jason W. Wolff
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`DECL. OF WOLFF ISO QUALYS’ ADMIN MFUS
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