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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
`
`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.
`
`
`
`Case No. 4:18-cv-07229-YGR (TSH)
`
`DECLARATION OF JASON W. WOLFF
`IN SUPPORT OF FINJAN LLC’S
`ADMINISTRATIVE MOTION FOR
`LEAVE TO FILE A COMBINED REPLY
`AND OPPOSITION TO QUALYS’S
`MOTION FOR SUMMARY JUDGMENT
`OF NO MORE THAN 25 PAGES
`
`
`
`
`
`
`
`
`PLACE:
`
`
`
`
`
`
`
`DECLARATION OF WOLFF IN SUPPORT OF
`ADMINISTRATIVE MOTION FOR LEAVE TO FILE
`COMBINED BRIEF
`Case No. 4:18-cv-07229-YGR (TSH)
`
`
`
`Case 4:18-cv-07229-YGR Document 203-1 Filed 06/01/21 Page 2 of 2
`
`
`
`
`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.
`
`On June 1, counsel appreciated that as a consequence of Qualys referring to its
`
`motions for summary judgment as a “cross-motion” the parties might dispute whether Civil Local
`
`Rules 7-3 and 7-4 apply to Finjan’s opposition to Qualys’s separate motion for summary judgment
`
`and its reply in support of Finjan’s motion for summary judgment, or the Court’s April 28, 2021
`
`Standing Order concerning cross-motions. Counsel for Finjan reached out to counsel for Qualys
`
`to attempt to resolve the briefing format and page limit conflict between the Civil Local Rules (7-2
`
`et seq.) and this Court’s Standing Order.
`
`3.
`
`Counsel for Qualys disagreed that its summary judgment motion was not a “cross-
`
`motion” because both sides filed motions, albeit on different legal issues. Counsel for Qualys
`
`indicated it was too late to resolve this issue by stipulation since the Standing Order and Court’s
`
`directions at the March 26, 2021 hearing left no room for ambiguity.
`
`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 June 1, 2021, in San Diego, California.
`
`
`Dated: June 1, 2021
`
`
`
`
`
`/s/ Jason W. Wolff
`Jason W. Wolff
`
`Attorneys for Plaintiff
`FINJAN LLC
`
`
`
`
`
`1
`
`
`
`DECLARATION OF WOLFF IN SUPPORT OF
`ADMINISTRATIVE MOTION FOR LEAVE TO
`FILE COMBINED BRIEF
`Case No. 4:18-cv-07229-YGR (TSH)
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