Case 4:18-cv-07229-YGR Document 201-2 Filed 06/01/21 Page 1 of 4
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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 UNDER SEAL
`
`FINJAN LLC, a Delaware Limited Liability
`Company,
`
`Plaintiff,
`
`v.
`
`QUALYS INC., a Delaware Corporation,
`
`Defendant.
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`
`
`On June 1, 2021, Plaintiff Finjan LLC (“Finjan”) filed a Motion for Administrative Relief
`
`with this Court, pursuant to Civil Local Rule 79-5, for permission to file under seal its Reply in
`
`Support of Motion for Summary Judgment and Opposition to Qualys’s Cross-Motion for Summary
`
`Judgment. Upon consideration of this motion and the exhibits and declaration of K. Nicole Williams
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`filed in support thereof (“Williams Sealing Decl.”), the Court finds good cause for granting the
`
`request to file the documents described below under seal.
`
`1.
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`There exists overriding confidentiality interests that overcome the right of public
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`access to the record for the following documents:
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`1
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`[PROPOSED] ORDER GRANTING FINJAN LLC’S
`ADMIN. MOT. TO SEAL
`Case No. 4:18-cv-07229-YGR (TSH)
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`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`(OAKLAND DIVISION)
`
`
`
`Case No. 4:18-cv-07229-YGR (TSH)
`
` [PROPOSED] ORDER GRANTING
`FINJAN LLC’S ADMINISTRATIVE
`MOTION TO FILE UNDER SEAL
`
`FINJAN LLC, a Delaware Limited Liability
`Company,
`
`Plaintiff,
`
`v.
`
`QUALYS INC., a Delaware Corporation,
`
`Defendant.
`
`
`
`On June 1, 2021, Plaintiff Finjan LLC (“Finjan”) filed a Motion for Administrative Relief
`
`with this Court, pursuant to Civil Local Rule 79-5, for permission to file under seal its Reply in
`
`Support of Motion for Summary Judgment and Opposition to Qualys’s Cross-Motion for Summary
`
`Judgment. Upon consideration of this motion and the exhibits and declaration of K. Nicole Williams
`
`filed in support thereof (“Williams Sealing Decl.”), the Court finds good cause for granting the
`
`request to file the documents described below under seal.
`
`1.
`
`There exists overriding confidentiality interests that overcome the right of public
`
`access to the record for the following documents:
`
`
`
`
`1
`
`
`
`[PROPOSED] ORDER GRANTING FINJAN LLC’S
`ADMIN. MOT. TO SEAL
`Case No. 4:18-cv-07229-YGR (TSH)
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`Case 4:18-cv-07229-YGR Document 201-2 Filed 06/01/21 Page 2 of 4
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`Document or Portion of Document
`Sought to be Sealed
`Finjan LLC’s Reply in Support of
`Motion for Summary Judgment and
`Opposition to Qualys’s Cross-Motion
`for Summary Judgment at highlighted
`portions at:
`Page 6, lines 6–8;
`Page 9, lines 8, 10–18, 20–23, 25–27;
`Page 10, line 21;
`Page 12, lines 27–28;
`Page 13, lines 1–2, 10, 12-13;
`Page 14, lines 3–5, 8–17, 21–24;
`Page 15, lines 5, 8–10;
`Page 18, line 28;
`Page 19, lines 1, 8, 11–13, 20, 23–26;
`Page 20, lines 1–2, 5–9, 12–14
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`Finjan LLC’s Responsive Separate
`Statement of Undisputed Material Facts
`at highlighted portions at:
`Page 2, line 15;
`Page 4, lines 4–5;
`Page 7, line 28;
`Page 8, lines 1, 3–4, 5–6, 8–9, 10;
`Page 9, lines 2–6, 1116, 18–25;
`Page 10, lines 1–7, 9–12;
`Page 11, line 16;
`Page 12, lines 8, 14–16, 18–20;
`Page 13, lines 4–7
`
`Ex. 8 to the Declaration of Jason W.
`Wolff (Excerpts from the Expert Report
`of Nenad Medvidović, Ph.D. dated
`December 1, 2020) at pages 51–53, 67–
`69, 79–81, 84, 99–100, 102, 104, 107–
`108, 111–121, 123, 129–133, 137, 139–
`140, and 156
`Ex. 14 to the Wolff Declaration
`(Excerpts from the deposition transcript
`of Aviel Rubin, Ph.D. taken March 4,
`2021)
`Ex. 15 to the Wolff Declaration
`(Excerpts from the Rebuttal Expert
`Report of Dr. Avi Rubin Regarding U.S.
`Patent No. 8,225,408 dated January 21,
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`Evidence Offered in
`Support of Sealing
`Williams Sealing Decl. ¶ 3
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`Order
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`Williams Sealing Decl. ¶ 4
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`Williams Sealing Decl. ¶ 5
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`Williams Sealing Decl. ¶ 6
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`Williams Sealing Decl. ¶ 7
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`[PROPOSED] ORDER GRANTING FINJAN LLC’S
`ADMIN. MOT. TO SEAL
`Case No. 4:18-cv-07229-YGR (TSH)
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`
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`Case 4:18-cv-07229-YGR Document 201-2 Filed 06/01/21 Page 3 of 4
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`2020)
`Ex. 16 to the Wolff Declaration
`(QUALYS00257792-
`QUALYS00257795)
`Ex. 17 to the Wolff Declaration
`(QUALYS01235879-
`QUALYS01235940)
`Ex. 19 to the Wolff Declaration
`(Excerpts from the deposition transcript
`of Holger Kruse taken September 14,
`2020) at pages 7–8
`
`Williams Sealing Decl. ¶ 8
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`Williams Sealing Decl. ¶ 9
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`Williams Sealing Decl. ¶
`10
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`Ex. 20 to the Wolff Declaration
`(QUALYS02019776-
`QUALYS02019800)
`Ex. 21 to the Wolff Declaration
`(Excerpts from the Stuart Stubblebine’s
`Rebuttal Expert Report Regarding Non-
`Infringement and Apportionment Issues
`(U.S. Patent Nos. 8,677,494; 6,154,844
`and 7,418,731 dated January 12, 2021)
`Ex. 22 to the Wolff Declaration
`(Excerpts from the deposition transcript
`of Stuart Stubblebine, Ph.D. taken
`March 5, 2021)
`Ex. 24 to the Wolff 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) at
`pages 129–132, 150–152, 678–680, and
`690–703
`Ex. 25 to the Wolff Declaration
`(Excerpts from the deposition transcript
`of Eric Cole, Ph.D. taken March 2,
`2021) at pages 90–96, 133–135
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`Williams Sealing Decl. ¶
`11
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`Williams Sealing Decl. ¶
`12
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`Williams Sealing Decl. ¶
`13
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`Williams Sealing Decl. ¶
`14
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`Williams Sealing Decl. ¶
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`[PROPOSED] ORDER GRANTING FINJAN LLC’S
`ADMIN. MOT. TO SEAL
`Case No. 4:18-cv-07229-YGR (TSH)
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`Case 4:18-cv-07229-YGR Document 201-2 Filed 06/01/21 Page 4 of 4
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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 LLC’s Administrative Motion to File Under
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`Seal its Reply in Support of Motion for Summary Judgment and Opposition to Qualys’s Cross-
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`Motion for Summary Judgment is GRANTED with respect to the documents set forth above.
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`
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`IT IS SO ORDERED.
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`Dated: ____________________
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`
`Hon. Yvonne Gonzalez Rogers
`United States District Court
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`[PROPOSED] ORDER GRANTING FINJAN LLC’S
`ADMIN. MOT. TO SEAL
`Case No. 4:18-cv-07229-YGR (TSH)
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