`
`
`PAUL ANDRE (State Bar No. 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (State Bar No. 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (State Bar No. 237978)
`jhannah@kramerlevin.com
`KRISTOPHER KASTENS (State Bar No. 254797)
`kkastens@kramerlevin.com
`HANNAH LEE (State Bar No. 253197)
`hlee@kramerlevin.com
`KRAMER LEVIN NAFTALIS
` & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`SAN JOSE DIVISION
`
`FINJAN, INC.,
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`SONICWALL, INC.,
`
`
`
`
`
`
`Defendant.
`
`
`
`
`
`Case No.: 5:17-cv-04467-BLF-VKD
`
`[PROPOSED] ORDER GRANTING
`PLAINTIFF FINJAN, INC.’S
`ADMINISTRATIVE MOTION TO FILE
`DOCUMENTS UNDER SEAL
`
`[RE: PLAINTIFF FINJAN, INC.’S
`DECLARATION OF AARON FRANKEL IN
`SUPPORT OF SUBMISSION OF
`DOCUMENTS FOR IN CAMERA REVIEW
`RELATING TO APRIL 17, 2020 JOINT
`DISCOVERY LETTER BRIEF]
`
`
`
`
`__________________________________________________________________________________
`[PROPOSED] ORDER GRANTING FINJAN’S ADMIN. CASE NO.: 17-cv-04467-BLF-VKD
`MOTION TO FILE DOCUMENTS UNDER SEAL
`
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`
`10
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`
`
`Case 5:17-cv-04467-BLF Document 256-2 Filed 05/04/20 Page 2 of 3
`
`
`Portions of Document to
`be Sealed
`
`Designating
`Party
`
`Reasons for Sealing
`
`Plaintiff Finjan, Inc.’s (“Finjan”) Administrative Motion to File Documents Under Seal was
`
`brought before this Court. Upon consideration of this motion and the supporting declaration of Aaron
`Frankel filed in support of the motion, the Court finds there to be good cause for granting the request to
`file certain documents under seal.
`
`Good cause having been shown, the Court finds that:
`There exists overriding confidentiality interests that overcome the right of public access to the
`record of the following documents:
`
`Identification of
`Documents or Portions of
`Document to be Sealed
`Exhibit 1 to the
`Declaration of Aaron
`Frankel in Support of
`Submission of Documents
`for In Camera Review
`Relating to April 17, 2020
`Joint Discovery Letter
`Brief (“Declaration”)
`(Finjan’s Consolidated
`Privilege and Redaction
`Log for In Camera
`Review)
`Exhibit 2 to the
`Declaration (Finjan’s
`Investors’ Rights
`Agreement)
`
`
`Entirety
`
`Finjan
`
`Entirety
`
`Finjan
`
`This document
`contains Finjan’s
`highly confidential
`information relating
`to privileged and
`work product
`protected
`discussions with its
`counsel.
`
`
`This document
`contains Finjan’s
`highly confidential
`business information
`relating to its
`relationship with its
`investors, from
`before Finjan was a
`public company.
`
`This document
`contains Finjan’s
`highly confidential
`business information
`relating to its Board
`operations and
`licensing efforts.
`
`
`Exhibit 3 to the
`Declaration (Deposition of
`Daniel Chinn)
`
`
`Entirety
`
`Finjan
`
`1
`[PROPOSED] ORDER GRANTING FINJAN’S ADMIN. CASE NO.: 17-cv-04467-BLF-VKD
`MOTION TO FILE DOCUMENTS UNDER SEAL
`
`1 2 3 4 5 6 7 8 9
`
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`
`
`
`Case 5:17-cv-04467-BLF Document 256-2 Filed 05/04/20 Page 3 of 3
`
`
`Identification of
`Documents or Portions of
`Document to be Sealed
`Exhibit 4 to the
`Declaration (Deposition of
`Yoav Samet)
`
`
`Portions of Document to
`be Sealed
`
`Designating
`Party
`
`Reasons for Sealing
`
`Entirety
`
`Finjan; Cisco
`Systems, Inc.
`
`This document
`contains highly
`confidential
`information relating
`to the business
`relationship between
`Cisco Systems, Inc.
`and Finjan, and
`confidential internal
`Cisco
`correspondence.
`The deponent is a
`former employee of
`Cisco Systems, Inc.
`
`
` A
`
` substantial probability exists that the overriding confidentiality interests will be prejudiced if
`the record is not sealed;
`The proposed sealing is narrowly tailored; and
`No less restrictive means exist to achieve these overriding interests.
`IT IS THEREFORE ORDERED that Finjan’s Administrative Motion to File Documents Under
`Seal is GRANTED with respect to the document set forth above.
`
`IT IS SO ORDERED.
`
`
`
`
`DATED: ____________________
`
`
`
`
`
`
`
`Honarable Virginia K. DeMarchi
`United States Magistrate Judge
`
`
`
`
`
`
`
`2
`[PROPOSED] ORDER GRANTING FINJAN’S ADMIN. CASE NO.: 17-cv-04467-BLF-VKD
`MOTION TO FILE DOCUMENTS UNDER SEAL
`
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`11
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`
`
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