`
`
`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
`
`AARON FRANKEL (pro hac vice)
`afrankel@kramerlevin.com
`KRAMER LEVIN NAFTALIS
` & FRANKEL LLP
`1177 Avenue of the Americas
`New York, NY 10036
`Telephone: (212) 715-7793
`
`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
`
`DECLARATION OF AARON FRANKEL IN
`SUPPORT OF PLAINTIFF FINJAN, INC.’S
`RESPONSE TO THE COURT’S ORDER OF
`REDACTION [DKT. NO. 269]
`
`
`
`
`
`__________________________________________________________________________________
`FRANKEL DECL. ISO FINJAN’S RESPONSE TO
`CASE NO.: 17-cv-04467-BLF-VKD
`THE COURT’S ORDER RE REDACTION [Dkt. No. 269]
`
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`
`
`
`Case 5:17-cv-04467-BLF Document 271-1 Filed 07/17/20 Page 2 of 2
`
`
`
`I, Aaron Frankel, declare as follows:
`1.
`I am a partner with the law firm of Kramer Levin Naftalis & Frankel LLP (“Kramer
`Levin”), counsel of record for Plaintiff Finjan, Inc. (“Finjan”). I have personal knowledge of the facts
`set forth in this declaration and can testify competently to those facts. I make this declaration in
`support of Finjan’s Response to the Court’s Order of Redaction (Dkt. No. 269) regarding the Court’s
`Order on a Discovery Dispute Regarding Privilege Claims (Dkt. No. 268, the “Order”).
`2.
`I have reviewed the following document and confirmed that it contains information
`designated as confidential by Finjan.
`
`Identification of
`Document to be Sealed
`Order re Discovery
`Dispute re Privilege
`Claims (Dkt. No. 268)
`
`Portions of Document to
`be Sealed
`Highlighted portion at Page
`2, lines 19-23
`
`Designating
`Party
`Finjan
`
`Reasons for Sealing
`
`This excerpt of the
`Order contains an
`excerpt from the
`confidential
`agreement between
`Cisco Systems, Inc.
`and Finjan.
`
`
`Finjan requests that the Court file the highlighted portion at page 2, lines 19-23 of the
`3.
`Order described above under seal because it contains an excerpt from a confidential agreement
`between Finjan and third party Cisco Systems, Inc. (“Cisco”). Finjan designated the confidential
`agreement as “Highly Confidential – Attorneys’ Eyes Only” under the Protective Order in this case.
`The Court’s July 9th Order (Dkt. No. 270) granted Finjan’s request to seal this confidential agreement.
`I declare under the penalty of perjury under the laws of the United States of America that each
`of the above statements is true and correct. Executed on July 17, 2020, in Allendale, NJ.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Aaron Frankel
`Aaron Frankel
`
`1
` CASE NO.: 17-cv-04467-BLF-VKD
`FRANKEL DECL. ISO FINJAN’S RESPONSE TO
`THE COURT’S ORDER RE REDACTION [Dkt. No. 269]
`
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`
`
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