`
`
`
`
`
`
`EDWARD G. POPLAWSKI (SBN 113590)
`epoplawski@wsgr.com
`OLIVIA M. KIM (SBN 228382)
`okim@wsgr.com
`TALIN GORDNIA (SBN 274213)
`tgordnia@wsgr.com
`STEPHANIE C. CHENG (SBN 319856)
`stephanie.cheng@wsgr.com
`WILSON SONSINI GOODRICH &
`ROSATI
`Professional Corporation
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071
`Telephone: (323) 210-2901
`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
`
`
`FINJAN LLC,
`
`
`Plaintiff,
`
`
`QUALYS INC.,
`
`
`Defendant.
`
`
`
`v.
`
`
`
`CASE NO.: 4:18-cv-07229-YGR
`
`QUALYS INC.’S RESPONSE TO
`FINJAN LLC’S ADMINISTRATIVE
`MOTION TO FILE UNDER SEAL
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`CASE NO. 4:18-cv-07229-YGR
`
`
`
`
`QUALYS’S RESPONSE TO FINJAN’S ADMINISTRATIVE
`MOTION TO SEAL
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`Case 4:18-cv-07229-YGR Document 182 Filed 03/26/21 Page 2 of 3
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`Plaintiff Finjan LLC’s (“Finjan”) Administrative Motion to File Under Seal its Letter to the
`Honorable Yvonne Gonzalez Rogers from Finjan LLC Regarding Qualys Inc.’s Letter Requesting
`a Pre-Filing Conference for its Summary Judgment Motion (D.I. 175) seeks to seal highlighted
`portions of its letter brief as identified in Declaration of Jason W. Wolff In Support of Administrative
`Motion to File Under Seal (D.I. 175-1).
`Qualys does not maintain a claim of confidentiality over the highlighted portions of Finjan
`LLC’s Letter to the Honorable Yvonne Gonzalez Rogers from Finjan LLC Regarding Qualys Inc.’s
`Letter Requesting a Pre-Filing Conference for its Summary Judgment Motions (“Finjan’s Letter
`Brief”) (D.I. 176). In other words, Qualys does not maintain confidentiality claims over the
`highlighted portions of Finjan’s Letter Brief at 1:15-19; 1:21-22; 1:27-28; 2:1-3; 2:8-12: 2:15-23;
`and 3:1-2. However, Qualys does maintain confidentiality claims over the underlying documents
`that the highlighted portions were quoted from.
`Because Qualys does not maintain a claim of confidentiality over the highlighted portions
`of Finjan’s Letter Brief, Finjan’s Administrative Motion to File Under Seal should be denied.
`
`
`
`
`
`Dated: March 26, 2021
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`WILSON SONSINI GOODRICH & ROSATI
`
`
`By:
`/s/ Christopher D. Mays
` Christopher D. Mays
`
`Counsel for
`QUALYS INC.
`
`
`
`
`
`CASE NO. 3:18-cv-07229-YGR
`
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`QUALYS’S RESPONSE TO FINJAN’S ADMINISTRATIVE
`MOTION TO SEAL
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`Case 4:18-cv-07229-YGR Document 182 Filed 03/26/21 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 March 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/ Christopher D. Mays
`Christopher D. Mays
`
`
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`CASE NO. 3:18-cv-07229-YGR
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`CERTIFICATE OF SERVICE
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