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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`(OAKLAND DIVISION)
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`
`
`Case No. 4:18-cv-07229-YGR (TSH)
`
`[PROPOSED] ORDER GRANTING
`FINJAN LLC’S ADMINISTRATIVE
`MOTION TO FILE DOCUMENTS
`UNDER SEAL
`
`FINJAN LLC, a Delaware Limited Liability
`Company,
`
`Plaintiff,
`
`v.
`
`QUALYS INC., a Delaware Corporation,
`
`Defendant.
`
`
`
`On February 8, 2021, Plaintiff Finjan LLC (“Finjan”) filed a Motion for Administrative
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`Relief with this Court, pursuant to Civil Local Rule 79-5, for permission to file documents under
`
`seal. Upon consideration of this motion and the exhibits and declaration of K. Nicole Williams filed
`
`in support thereof (“Williams Decl.”), the Court finds good cause and compelling reasons for
`
`granting the request to file the documents described below under seal.
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`1.
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`There exist overriding confidentiality interests that overcome the right of public
`
`access to the record for the following documents:
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`1
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`
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`[PROPOSED] ORDER GRANTING FINJAN’S
`ADMIN. MOT. TO SEAL
`Case No. 4:18-cv-07229-YGR (TSH)
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`Case 4:18-cv-07229-YGR Document 163-2 Filed 02/08/21 Page 2 of 3
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`
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`Document or Portion of Document Sought
`to be Sealed
`Plaintiff Finjan LLC’s Opposition to Qualys
`Inc.’s Motion to Strike Portions of Plaintiff’s
`Infringement and Damages Expert Reports
`at: page 2, lines 19-22;
`page 5, lines 15-20;
`page 7, lines 16-17, 21-22, 24, and 28;
`page 8, lines 3-7, 19, 22-28;
`page 9, lines 1-7, 9-12;
`page 11, lines 20-24, 25;
`page 12, lines 22-23;
`page 13, lines 12-13, 25-26;
`page 14, lines 9-10
`Exhibit B to the Declaration of Robert
`Courtney (“Courtney Declaration”)
`(Excerpts from the Expert Report of Nenad
`Medvidovic, Ph.D. dated December 1, 2020)
`Exhibit D to the Courtney Declaration
`(Excerpt from the Deposition Transcript of
`Dilip Bachwani taken September 18, 2020)
`Exhibit F to the Courtney Declaration
`(Excerpts from the Opening Expert Report of
`Dr. Avi Rubin dated December 1, 2020
`Exhibit G to the Courtney Declaration
`(Excerpts from the Opening Expert Report of
`Eric Cole, Ph.D. Regarding Infringement by
`Qualys Inc. of Patent Nos. 6,154,844;
`8,677,494; and 7,418,731 dated December 1,
`2020)
`
`Evidence Offered in
`Support of Sealing
`Williams Dec. ¶ 3
`
`
`
`Order
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`Williams Dec. ¶ 4
`
`Williams Dec. ¶ 5
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`Williams Dec. ¶ 6
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`Williams Dec. ¶ 7
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`2.
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`A substantial probability exists that the overriding confidentiality interests will be
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`prejudiced if the record is not sealed;
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`3.
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`4.
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`The proposed sealing is narrowly tailored; and
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`No less restrictive means exist to achieve these overriding interests.
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`IT IS THEREFORE ORDERED that Finjan’s Administrative Motion to File Documents
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`Under Seal is GRANTED with respect to the documents set forth above.
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`2
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`[PROPOSED] ORDER GRANTING FINJAN’S
`ADMIN. MOT. TO SEAL
`Case No. 4:18-cv-07229-YGR (TSH)
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`Case 4:18-cv-07229-YGR Document 163-2 Filed 02/08/21 Page 3 of 3
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`
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`IT IS SO ORDERED.
`
`
`Dated: ____________________
`
`
`Judge Yvonne Gonzalez Rogers
`United States District Court
`
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`3
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`[PROPOSED] ORDER GRANTING FINJAN’S
`ADMIN. MOT. TO SEAL
`Case No. 4:18-cv-07229-YGR (TSH)
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