Case 4:18-cv-07229-YGR Document 202-1 Filed 06/01/21 Page 1 of 3
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`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
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`
`
`
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`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
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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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`FINJAN LLC, a Delaware Limited Liability
`Company,
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`Plaintiff,
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`v.
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`QUALYS INC., a Delaware Corporation,
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`Defendant.
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`PLACE:
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`
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`Case No. 4:18-cv-07229-YGR (TSH)
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`DECLARATION OF JASON W. WOLFF
`IN SUPPORT OF PLAINTIFF FINJAN
`LLC’S REPLY IN SUPPORT OF
`MOTION FOR SUMMARY JUDGMENT
`AND OPPOSITION TO DEFENDANT
`QUALYS INC.’S CROSS-MOTION FOR
`SUMMARY JUDGMENT
`
`
`July 6, 2021
`DATE:
`2:00 P.M.
`TIME:
`JUDGE: Hon. Yvonne Gonzalez Rogers
`PLACE:
`Zoom
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`
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`
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`DECLARATION OF JASON W. WOLFF
`Case No. 4:18-cv-07229-YGR (TSH)
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`

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`Case 4:18-cv-07229-YGR Document 202-1 Filed 06/01/21 Page 2 of 3
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`I, Jason W. Wolff, hereby declare and state as follows:
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`1.
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`I am a principal in the law firm of Fish & Richardson P.C., counsel of record for
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`Plaintiff Finjan LLC in the above-captioned matter. I have personal knowledge of all the facts
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`contained herein and, if called as a witness, I could and would testify competently thereto.
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`2.
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`Attached as Exhibit 8 is a true and correct copy of excerpts from the Expert Report
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`of Nenad Medvidović, Ph.D. dated December 1, 2020.
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`3.
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`Attached as Exhibit 9 is a true and correct copy of excerpts from the Opening
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`Expert Report of Dr. Avi Rubin dated December 1, 2020.
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`4.
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`Attached as Exhibit 10 is a true and correct copy of the Redacted Version of
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`Finjan’s Opposition to SonicWall’s Motion for Partial Summary Judgment, Case No. 17-cv-
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`04467-BLF, D.I. 327-3 (N.D. Cal., Dec. 21, 2020).
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`5.
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`Attached as Exhibit 11 is a true and correct copy of the Redacted Version of
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`Defendant SonicWall, Inc.’s Motion for Partial Summary Judgment, Case No. 17-cv-04467-BLF,
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`D.I. 320 (N.D. Cal., Dec. 2, 2020).
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`6.
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`Attached as Exhibit 12 is a true and correct copy of QUALYS00355723-
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`QUALYS00355727, which was produced in this case.
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`7.
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`Attached as Exhibit 13 is a true and correct copy of QUALYS00606865-
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`QUALYS00606870, which was produced in this case.
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`8.
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`Attached as Exhibit 14 is a true and correct copy of excerpts from the deposition
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`transcript of Aviel Rubin, Ph.D. taken March 4, 2021.
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`9.
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`Attached as Exhibit 15 is a true and correct copy of excerpts from the Rebuttal
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`Expert Report of Dr. Avi Rubin Regarding U.S. Patent No. 8,225,408 dated January 12, 2020.
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`10.
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`Attached as Exhibit 16 is a true and correct copy of QUALYS00257792-
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`QUALYS00257795, which was produced in this case.
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`11.
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`Attached as Exhibit 17 is a true and correct copy of QUALYS01235879-
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`QUALYS01235940, which was produced in this case.
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`12.
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`Attached as Exhibit 18 is a true and correct copy of QUALYS01065909, which
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`was produced in this case.
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`DECLARATION OF JASON W. WOLFF
`Case No. 4:18-cv-07229-YGR (TSH)
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`Case 4:18-cv-07229-YGR Document 202-1 Filed 06/01/21 Page 3 of 3
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`13.
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`Attached as Exhibit 19 is a true and correct copy of excerpts from the deposition
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`transcript of Holger Kruse taken September 14, 2020.
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`14.
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`Attached as Exhibit 20 is a true and correct copy of QUALYS02019776-
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`QUALYS02019800, which was produced in this case.
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`15.
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`Attached as Exhibit 21 is a true and correct copy of excerpts from the Stuart
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`Stubblebine’s Rebuttal Expert Report Regarding Non-Infringement and Apportionment Issues
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`(U.S. Patent Nos. 8,677,494; 6,154,844 and 7,418,731).
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`16.
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`Attached as Exhibit 22 is a true and correct copy of excerpts from the deposition
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`transcript of Stuart Stubblebine, Ph.D. taken March 5, 2021.
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`17.
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`Attached as Exhibit 23 is a true and correct copy of the Joint Claim Construction
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`and Pre-Hearing Statement in Finjan, Inc. v. SonicWall, Inc., Case No. 5:17-cv-04467-BLF, D.I.
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`80 (N.D. Cal. July 25, 2018).
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`18.
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`Attached as Exhibit 24 is a true and correct copy of excerpts from the Opening
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`Expert Report of Eric Cole, Ph.D. Regarding Infringement by Qualys Inc. of Patent Nos.
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`6,154,844; 8,677,494 and 7,418,731, dated December 1, 2020.
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`19.
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`Attached as Exhibit 25 is a true and correct copy of excerpts from the deposition
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`transcript of Eric Cole, Ph.D. taken March 2, 2021.
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`I declare under the penalty of perjury of the laws of the United States of America that the
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`foregoing is true and correct. Executed on June 1, 2021, in San Diego, California.
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`/s/ Jason W. Wolff
`Jason W. Wolff
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`Attorneys for Plaintiff
`FINJAN LLC
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`DECLARATION OF JASON W. WOLFF
`Case No. 4:18-cv-07229-YGR (TSH)
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