Case 4:18-cv-07229-YGR Document 165 Filed 02/12/21 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 FINJAN
`LLC’S ADMINISTRATIVE MOTION
`TO FILE UNDER SEAL
`
`)))))))))))
`
`FINJAN, LLC.,
`
`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 165 Filed 02/12/21 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.
`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 the documents
`below under seal are as follows:
`3.
`With respect to Finjan’s Opposition to Qualys’s Motion to Strike (D.I. 163-3), the
`redacted portions of this document describe the technical operations of Qualys’s products which
`Qualys maintains as highly confidential information. Qualys has marked this information
`“HIGHLY CONFIDENTIAL – ATTORNEYS EYES’ ONLY.” Specifically, the redactions on the
`following pages disclose Qualys’s technical information: Pages 2, 5, 7, 8, 9, 11, 12, 13, and 14.
`These redactions are also discussed in more detail below to the extent they quote or cite material
`listed below.
`Exhibit B to the Declaration of Robert Courtney is an excerpt of the Expert Report
`4.
`of Nenad Medvidovic, Ph.D., dated December 1, 2020, and contains technical analysis of Qualys’s
`products, which discusses materials that Qualys has marked “HIGHLY CONFIDENTIAL –
`ATTORNEYS EYES’ ONLY.” Specifically, the following paragraphs from Exhibit B include
`highly confidential technical discussions regarding the specifics of how Qualys’s technology works:
`¶¶ 21, 22, 99, 100, 102-105, 113-115, 134 (top of page 42, no paragraph number), 135-137, 163,
`165, 170 (top of page 56, no paragraph number), 188-194, 226 (top of page 88, no paragraph
`number), 227, 230, 235, 236, 238, 248 (top of page 98, no paragraph number), 259 (top of page 102,
`no paragraph number), 260, 262, 263, 280-283, 287, 295, and 303. It is therefore sealable as
`containing Qualys’s technical information.
`5.
`Exhibit D to the Declaration of Robert Courtney is an excerpt of the Deposition
`Transcript of Dilip Bachwani, a Qualys engineer, taken September 18, 2020 and contains technical
`discussion of Qualys’s products. The redacted portion of Exhibit D contains a discussion of the
`technical functionality of how Qualys’s Cloud Agent operates. As such, the document contains
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`Case 4:18-cv-07229-YGR Document 165 Filed 02/12/21 Page 3 of 3
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`sensitive information and was marked by Qualys as “HIGHLY CONFIDENTIAL – ATTORNEYS
`EYES’ ONLY.” It is therefore sealable as containing Qualys’s technical information.
`6.
`Exhibit F does not contain any Qualys confidential information and need not be
`sealed.
`7.
`sealed.
`
`Exhibit G does not contain any Qualys confidential information and need not be
`
`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 February 12, 2021, in Morgan Hill, CA.
`
`/s/ Christopher D. Mays
`Christopher D. Mays
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