`
`
`
`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
`K. Nicole Williams (CA SBN 291900)
`nwilliams@fr.com
`FISH & RICHARDSON P.C.
`12860 El Camino Real, Suite 400
`San Diego, CA 92130
`Phone: (858) 678-5070 /Fax: (858) 678-5099
`
`Aamir A. Kazi (pro hac vice)
`kazi@fr.com
`Lawrence R. Jarvis (pro hac vice)
`jarvis@fr.com
`Fish and Richardson P.C.
`1180 Peachtree Street Ne 21st Floor
`Atlanta, GA 30309
`Phone: (404) 879-7238/ Fax: 404-892-5002
`
`Attorneys for Plaintiff
`FINJAN LLC
`
`Philip W. Goter (pro hac vice)
`goter@fr.com
`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
`
`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
`
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`(OAKLAND DIVISION)
`
`FINJAN LLC, a Delaware Limited Liability
`Company,
`
`Plaintiff,
`
`v.
`
`QUALYS INC., a Delaware Corporation,
`
`Defendant.
`
`PLACE:
`
`
`
`Case No. 4:18-cv-07229-YGR (TSH)
`
`DECLARATION OF JASON W. WOLFF
`IN SUPPORT OF FINJAN LLC’S
`MOTION FOR SUMMARY JUDGMENT
`
`DATE:
`TIME:
`JUDGE:
`PLACE:
`
`
`July 6, 2021
`2:00 P.M.
`Hon. Yvonne Gonzalez Rogers
`Courtroom 1, 4th Floor
`
`
`
`
`
`DECLARATION OF WOLFF ISO MSJ
`Case No. 4:18-cv-07229-YGR (TSH)
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`Case 4:18-cv-07229-YGR Document 192-1 Filed 04/19/21 Page 2 of 3
`
`
`
`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.
`
`Attached as Exhibit 1 is a true and correct copy of excerpts from the deposition
`
`transcript of Sylvia Hall-Ellis, Ph.D. taken March 1, 2021.
`
`3.
`
`Attached as Exhibit 2 is a true and correct copy of excerpts from a document titled
`
`“Dr. Solomon’s Anti-Virus Toolkit for Windows & DOS” (“DSAVT”) [QUALYS00002805-
`
`QUALYS00003805].
`
`4.
`
`Attached as Exhibit 3 is a true and correct copy of excerpts from the Expert Report
`
`of Dr. Sylvia D. Hall-Ellis Regarding Public Availability of Certain Publications dated
`
`December 1, 2020.
`
`5.
`
`Attached as Exhibit 4 is a true and correct copy of a document titled “Preliminary
`
`report on Distributed ASAX” (“Mounji”) [QUALYS00024281-QUALYS00024318].
`
`6.
`
`Attached as Exhibit 5 is a true and correct copy of Exhibit 8 to the deposition of
`
`Dr. Sylvia Hall-Ellis, which is the Wikipedia page for CiteSeerX.
`
`7.
`
`Attached as Exhibit 6 is a true and correct copy of Exhibit 9 to the deposition of Dr.
`
`Sylvia Hall-Ellis, which is the About page from the ResearchGate website.
`
`8.
`
`Attached as Exhibit 7 is a true and correct copy of the paper titled “Proxy Servers
`
`and Databases for Managing Web-based Information” (“Thomson”) [QUALYSS00112670-
`
`QUALYS00112683].
`
`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 April 19, 2021, in San Diego, California.
`
`
`
`
`
`
`
`
`
`/s/ Jason W. Wolff
`Jason W. Wolff
`
`Attorneys for Plaintiff
`FINJAN LLC.
`
`
`
`
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`1
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`DECLARATION OF WOLFF ISO MSJ
`Case No. 4:18-cv-07229-YGR (TSH)
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`Case 4:18-cv-07229-YGR Document 192-1 Filed 04/19/21 Page 3 of 3
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the above and foregoing
`
`document has been served on April 19, 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
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`be served by electronic mail and regular mail.
`
`
`
`/s/ Jason W. Wolff
`Jason W. Wolff
`
`
`
`
`
`
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`
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`CERTIFICATE OF SERVICE
`Case No. 4:18-cv-07229-YGR (TSH)
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