Case 5:17-cv-04467-BLF Document 322 Filed 12/07/20 Page 1 of 10
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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
`John-Paul Fryckman (CA SBN 317591) fryckman@fr.com
`K. Nicole Williams (CA291900) nwilliams@fr.com
`FISH & RICHARDSON P.C.
`12860 El Camino Real, Suite 400
`San Diego, CA 92130
`Telephone: (858) 678-5070 / Fax: (858) 678-5099
`
`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) 542-5906
`
`Robert Courtney (CA SNB 248392) courtney@fr.com
`FISH & RICHARDSON P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Phone: (612) 335-5070 / Fax: (612) 288-9696
`
`Attorneys for Plaintiff
`FINJAN LLC
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`(SAN JOSE DIVISION)
`
`
`
`FINJAN LLC, a Delaware Limited Liability
`Company,
`
`Case No. 5:17-cv-04467-BLF (VKD)
`
`Plaintiff,
`
`v.
`
`SONICWALL INC., a Delaware Corporation,
`
`Defendant.
`
`DECLARATION OF K. NICOLE
`WILLIAMS IN SUPPORT OF
`DEFENDANT SONICWALL INC.’S
`ADMINISTRATIVE MOTION TO FILE
`DOCUMENTS UNDER SEAL
`(ECF NO. 319)
`
`Date: January 14, 2021
`Time: 9:00 AM
`Judge: Hon. Beth Labson Freeman
`Dept: Courtroom 3, Fifth Floor
`
`
`
`
`
`Case No. 5:17-cv-04467 BLF (VKD)
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF SONICWALL’S ADMIN.
`MOTION TO FILE UNDER SEAL (ECF NO. 319)
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`Case 5:17-cv-04467-BLF Document 322 Filed 12/07/20 Page 2 of 10
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`
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`I, K. Nicole Williams, hereby declare and state as follows:
`
`1.
`
`I am licensed to practice in the State of California and am an associate in the law
`
`firm of Fish & Richardson P.C., counsel of record for Plaintiff Finjan LLC (“Finjan”) 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.
`
`I submit this declaration in support of SonicWall’s Administration Motion to File
`
`Under Seal its Motion for Partial Summary Judgment (ECF No. 319), pursuant to Civil Local Rules
`
`79-5(d)-(e) and this Court’s Standing Order. The basis for asserting confidentiality and the grounds
`
`for filing the documents under seal are as follows:
`
`Document
`
`Portion(s) to Seal
`
`Reason(s) for Sealing
`
`This document reflects
`information and testimony
`regarding Finjan’s business
`practices and licensing
`negotiations, which Finjan
`has designated “HIGHLY
`CONFIDENTIAL –
`ATTORNEYS’ EYES
`ONLY” under the
`Protective Order (ECF No.
`68). Public disclosure of
`this information would
`cause harm to Finjan. See
`Declaration of K. Nicole
`Williams in Support of
`SonicWall’s
`Administrative Motion to
`File Under Seal (“Williams
`Decl.”) ¶ 3.
`This document reflects
`testimony regarding
`Finjan’s business practices
`and licensing negotiations,
`which Finjan has
`designated “HIGHLY
`CONFIDENTIAL –
`ATTORNEYS’ EYES
`
`or
`
`ECF
`Exh. No.
`Ex. 28 to
`Gunther
`Declaration;
`ECF No.
`319-24
`
`Entirety
`
`July 31, 2020 Plaintiff
`Finjan Inc.’s Third
`Supplemental
`Objections and
`Responses to
`Defendant SonicWall
`Inc.’s First Set of
`Interrogatories (No 6)
`
`Ex. 29 to
`Gunther
`Declaration;
`ECF No.
`319-25
`
`Excerpts from
`February 26, 2020
`Deposition Transcript
`of John Garland
`
`Entirety
`
`
`
`1
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`Case No. 5:17-cv-04467 BLF (VKD)
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF SONICWALL’S ADMIN.
`MOTION TO FILE UNDER SEAL (ECF NO. 319)
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`Case 5:17-cv-04467-BLF Document 322 Filed 12/07/20 Page 3 of 10
`
`Ex. 30 to
`Gunther
`Declaration;
`ECF No.
`319-26
`
`June 10-11, 2014
`Email bearing BATES
`numbers Finjan-SW
`047868 – Finjan-SW
`047869
`
`Entirety
`
`Entirety
`
`Ex. 31 to
`Gunther
`Declaration
`ECF No.
`319-27
`
`November 25, 2014
`Finjan Presentation
`bearing BATES
`numbers Finjan-SW
`047884 – Finjan-SW
`047924
`
`Entirety
`
`Ex. 32 to
`Gunther
`Declaration
`ECF No.
`319-28
`
`September 17, 2014
`Email and
`Attachments bearing
`BATES numbers
`FINJAN-SW 047936
`– FINJAN-SW
`047946
`
`ONLY” under the
`Protective Order (ECF No.
`68). Public disclosure of
`this information would
`cause harm to Finjan. See
`Williams Decl. ¶ 4.
`This document reflects
`information regarding
`Finjan’s business practices
`and licensing negotiations,
`which Finjan has
`designated “HIGHLY
`CONFIDENTIAL –
`ATTORNEYS’ EYES
`ONLY” under the
`Protective Order (ECF No.
`68). Public disclosure of
`this information would
`cause harm to Finjan. See
`Williams Decl. ¶ 5.
`This document reflects
`information regarding
`Finjan’s business practices
`and licensing negotiations,
`which Finjan has
`designated “HIGHLY
`CONFIDENTIAL –
`ATTORNEYS’ EYES
`ONLY” under the
`Protective Order (ECF No.
`68). Public disclosure of
`this information would
`cause harm to Finjan. See
`Williams Decl. ¶ 6.
`This document reflects
`information regarding
`Finjan’s business practices
`and licensing negotiations,
`which Finjan has
`designated “HIGHLY
`CONFIDENTIAL –
`ATTORNEYS’ EYES
`ONLY” under the
`Protective Order (ECF No.
`68). Public disclosure of
`this information would
`
`
`
`2
`
`Case No. 5:17-cv-04467 BLF (VKD)
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF SONICWALL’S ADMIN.
`MOTION TO FILE UNDER SEAL (ECF NO. 319)
`
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`Case 5:17-cv-04467-BLF Document 322 Filed 12/07/20 Page 4 of 10
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`28
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`Entirety
`
`Ex. 33 to
`Gunther
`Declaration
`ECF No.
`319-29
`
`October 12, 2016
`Finjan Presentation
`bearing BATES
`numbers FINJAN-SW
`047979 – FINJAN-
`SW 048008
`
`Entirety
`
`Ex. 34 to
`Gunther
`Declaration
`ECF No.
`319-30
`
`March 28, 2017 Email
`and Attachments
`bearing BATES
`numbers SonicWall-
`Finjan_01044804 –
`SonicWall-
`Finjan_01044812
`
`Entirety
`
`Ex. 36 to
`Gunther
`Declaration
`ECF No.
`319-31
`
`July 8, 2014 Email
`and Attachment
`bearing BATES
`numbers FINJAN-SW
`047947 – FINJAN-
`SW 047952
`
`Ex. 37 to
`Gunther
`Declaration
`
`November 21, 2016
`Email bearing BATES
`numbers FINJAN-SW
`
`Entirety
`
`cause harm to Finjan. See
`Williams Decl. ¶ 7.
`This document reflects
`information regarding
`Finjan’s business practices
`and licensing negotiations,
`which Finjan has
`designated “HIGHLY
`CONFIDENTIAL –
`ATTORNEYS’ EYES
`ONLY” under the
`Protective Order (ECF No.
`68). Public disclosure of
`this information would
`cause harm to Finjan. See
`Williams Decl. ¶ 8.
`This document reflects
`information regarding
`Finjan’s business practices
`and licensing negotiations,
`which Finjan has
`designated “HIGHLY
`CONFIDENTIAL –
`ATTORNEYS’ EYES
`ONLY” under the
`Protective Order (ECF No.
`68). Public disclosure of
`this information would
`cause harm to Finjan. See
`Williams Decl. ¶ 9.
`This document reflects
`information regarding
`Finjan’s business practices
`and licensing negotiations,
`which Finjan has
`designated “HIGHLY
`CONFIDENTIAL –
`ATTORNEYS’ EYES
`ONLY” under the
`Protective Order (ECF No.
`68). Public disclosure of
`this information would
`cause harm to Finjan. See
`Williams Decl. ¶ 10.
`This document reflects
`information regarding
`Finjan’s business practices
`
`
`
`3
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`Case No. 5:17-cv-04467 BLF (VKD)
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF SONICWALL’S ADMIN.
`MOTION TO FILE UNDER SEAL (ECF NO. 319)
`
`

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`Case 5:17-cv-04467-BLF Document 322 Filed 12/07/20 Page 5 of 10
`
`ECF No.
`319-32
`
`047959 – FINJAN-
`SW 047962
`
`Entirety
`
`Ex. 38 to
`Gunther
`Declaration
`ECF No.
`319-33
`
`June 8, 2017 Finjan
`Presentation bearing
`BATES numbers
`FINJAN-SW 146162
`– FINJAN-SW
`146192
`
`
`
`
`
`
`
`and licensing negotiations,
`which Finjan has
`designated “HIGHLY
`CONFIDENTIAL –
`ATTORNEYS’ EYES
`ONLY” under the
`Protective Order (ECF No.
`68). Public disclosure of
`this information would
`cause harm to Finjan. See
`Williams Decl. ¶ 11.
`This document reflects
`information regarding
`Finjan’s business practices
`and licensing negotiations,
`which Finjan has
`designated “HIGHLY
`CONFIDENTIAL –
`ATTORNEYS’ EYES
`ONLY” under the
`Protective Order (ECF No.
`68). Public disclosure of
`this information would
`cause harm to Finjan. See
`Williams Decl. ¶ 12.
`
`3.
`
`I have reviewed Exhibit 28 to the Declaration of Jarrad M. Gunther in Support of
`
`Defendant SonicWall Inc.’s Motion for Partial Summary Judgment (“Gunther Declaration”). (ECF
`
`No. 319-24.) Exhibit 28 to the Gunther Declaration reflects information and testimony regarding
`
`Finjan’s business practices and licensing negotiations, which Finjan designated as “HIGHLY
`
`CONFIDENTIAL – ATTORNEYS’ EYES ONLY” subject to the Protective Order. Finjan treats
`
`this confidential business and licensing information as highly confidential within its business and
`
`makes substantial efforts not to disclose such information to the public. Such information could be
`
`used by Finjan’s competitors, as it reveals information related to Finjan’s business practices and
`
`dealings. Accordingly, good cause and compelling reasons exist to seal Ex. 28 to the Gunther
`
`Declaration.
`
`
`
`4
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`Case No. 5:17-cv-04467 BLF (VKD)
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF SONICWALL’S ADMIN.
`MOTION TO FILE UNDER SEAL (ECF NO. 319)
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`Case 5:17-cv-04467-BLF Document 322 Filed 12/07/20 Page 6 of 10
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`4.
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`I have reviewed Exhibit 29 to the Gunther Declaration. (ECF No. 319-25.) Exhibit
`
`29 to the Gunther Declaration reflects testimony regarding Finjan’s business practices and licensing
`
`negotiations. Finjan treats this confidential business and licensing information as highly
`
`confidential within its business and makes substantial efforts not to disclose such information to the
`
`public. Such information could be used by Finjan’s competitors, as it reveals information related to
`
`Finjan’s business practices and dealings,
`
`including confidential
`
`licensing negotiations.
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`Accordingly, good cause and compelling reasons exist to seal Ex. 29 to the Gunther Declaration.
`
`5.
`
`I have reviewed Exhibit 30 to the Gunther Declaration. (ECF No. 319-26.) Exhibit
`
`30 to the Gunther Declaration reflects information regarding Finjan’s business practices and
`
`licensing negotiations, which Finjan designated as “HIGHLY CONFIDENTIAL – ATTORNEYS’
`
`EYES ONLY” subject to the Protective Order. Finjan treats this confidential business and licensing
`
`information as highly confidential within its business and makes substantial efforts not to disclose
`
`such information to the public. Such information could be used by Finjan’s competitors, as it reveals
`
`information related to Finjan’s business practices and dealings, including confidential licensing
`
`negotiations. Accordingly, good cause and compelling reasons exist to seal Ex. 30 to the Gunther
`
`Declaration.
`
`6.
`
`I have reviewed Exhibit 31 to the Gunther Declaration. (ECF No. 319-27.) Exhibit
`
`31 to the Gunther Declaration reflects information regarding Finjan’s business practices and
`
`licensing negotiations, which Finjan designated as “HIGHLY CONFIDENTIAL – ATTORNEYS’
`
`EYES ONLY” subject to the Protective Order. Finjan treats this confidential business and licensing
`
`information as highly confidential within its business and makes substantial efforts not to disclose
`
`such information to the public. Such information could be used by Finjan’s competitors, as it reveals
`
`information related to Finjan’s business practices and dealings, including confidential licensing
`
`
`
`5
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`Case No. 5:17-cv-04467 BLF (VKD)
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF SONICWALL’S ADMIN.
`MOTION TO FILE UNDER SEAL (ECF NO. 319)
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`Case 5:17-cv-04467-BLF Document 322 Filed 12/07/20 Page 7 of 10
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`
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`negotiations. Accordingly, good cause and compelling reasons exist to seal Ex. 31 to the Gunther
`
`Declaration.
`
`7.
`
`I have reviewed Exhibit 32 to the Gunther Declaration. (ECF No. 319-28.) Exhibit
`
`32 to the Gunther Declaration reflects information regarding Finjan’s business practices and
`
`licensing negotiations, including information regarding compromise offers subject to Federal Rules
`
`of Evidence 408, which Finjan designated as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
`
`ONLY” subject to the Protective Order. Finjan treats this confidential business and licensing
`
`information as highly confidential within its business and makes substantial efforts not to disclose
`
`such information to the public. Such information could be used by Finjan’s competitors, as it reveals
`
`information related to Finjan’s business practices and dealings, including confidential licensing
`
`negotiations. Accordingly, good cause and compelling reasons exist to seal Ex. 32 to the Gunther
`
`Declaration.
`
`8.
`
`I have reviewed Exhibit 33 to the Gunther Declaration. (ECF No. 319-29.) Exhibit
`
`33 to the Gunther Declaration reflects information regarding Finjan’s business practices and
`
`licensing negotiations, including information regarding compromise offers subject to Federal Rules
`
`of Evidence 408, which Finjan designated as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
`
`ONLY” subject to the Protective Order. Finjan treats this confidential business and licensing
`
`information as highly confidential within its business and makes substantial efforts not to disclose
`
`such information to the public. Such information could be used by Finjan’s competitors, as it reveals
`
`information related to Finjan’s business practices and dealings, including confidential licensing
`
`negotiations. Accordingly, good cause and compelling reasons exist to seal Ex. 33 to the Gunther
`
`Declaration.
`
`9.
`
`I have reviewed Exhibit 34 to the Gunther Declaration. (ECF No. 319-30.) Exhibit
`
`34 to the Gunther Declaration reflects information regarding Finjan’s business practices and
`
`
`
`6
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`Case No. 5:17-cv-04467 BLF (VKD)
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF SONICWALL’S ADMIN.
`MOTION TO FILE UNDER SEAL (ECF NO. 319)
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`Case 5:17-cv-04467-BLF Document 322 Filed 12/07/20 Page 8 of 10
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`
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`licensing negotiations, which Finjan designated as “HIGHLY CONFIDENTIAL – ATTORNEYS’
`
`EYES ONLY” subject to the Protective Order. Finjan treats this confidential business and licensing
`
`information as highly confidential within its business and makes substantial efforts not to disclose
`
`such information to the public. Such information could be used by Finjan’s competitors, as it reveals
`
`information related to Finjan’s business practices and dealings, including confidential licensing
`
`negotiations. Accordingly, good cause and compelling reasons exist to seal Ex. 34 to the Gunther
`
`Declaration.
`
`10.
`
`I have reviewed Exhibit 36 to the Gunther Declaration. (ECF No. 319-31.) Exhibit
`
`36 to the Gunther Declaration reflects information regarding Finjan’s business practices and
`
`licensing negotiations, which Finjan designated as “HIGHLY CONFIDENTIAL – ATTORNEYS’
`
`EYES ONLY” subject to the Protective Order. Finjan treats this confidential business and licensing
`
`information as highly confidential within its business and makes substantial efforts not to disclose
`
`such information to the public. Such information could be used by Finjan’s competitors, as it reveals
`
`information related to Finjan’s business practices and dealings, including confidential licensing
`
`negotiations. Accordingly, good cause and compelling reasons exist to seal Ex. 36 to the Gunther
`
`Declaration.
`
`11.
`
`I have reviewed Exhibit 37 to the Gunther Declaration. (ECF No. 319-32.) Exhibit
`
`37 to the Gunther Declaration reflects information regarding Finjan’s business practices and
`
`licensing negotiations, including information regarding compromise offers subject to Federal Rules
`
`of Evidence 408, which Finjan designated as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
`
`ONLY” subject to the Protective Order. Finjan treats this confidential business and licensing
`
`information as highly confidential within its business and makes substantial efforts not to disclose
`
`such information to the public. Such information could be used by Finjan’s competitors, as it reveals
`
`information related to Finjan’s business practices and dealings, including confidential licensing
`
`
`
`7
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`Case No. 5:17-cv-04467 BLF (VKD)
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF SONICWALL’S ADMIN.
`MOTION TO FILE UNDER SEAL (ECF NO. 319)
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`Case 5:17-cv-04467-BLF Document 322 Filed 12/07/20 Page 9 of 10
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`
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`negotiations. Accordingly, good cause and compelling reasons exist to seal Ex. 37 to the Gunther
`
`Declaration.
`
`12.
`
`I have reviewed Exhibit 38 to the Gunther Declaration. (ECF No. 319-33.) Exhibit
`
`38 to the Gunther Declaration reflects information regarding Finjan’s business practices and
`
`licensing negotiations, including information regarding compromise offers subject to Federal Rules
`
`of Evidence 408, which Finjan designated as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
`
`ONLY” subject to the Protective Order. Finjan treats this confidential business and licensing
`
`information as highly confidential within its business and makes substantial efforts not to disclose
`
`such information to the public. Such information could be used by Finjan’s competitors, as it reveals
`
`information related to Finjan’s business practices and dealings, including confidential licensing
`
`negotiations. Accordingly, good cause and compelling reasons exist to seal Ex. 38 to the Gunther
`
`Declaration.
`
`13.
`
`Based upon the foregoing, Finjan requests that Exhibits 28, 29, 30, 31, 32, 33, 34,
`
`36, 37, and 38 to the Gunther Declaration remain under seal.
`
`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 December 7, 2020, in Encinitas, California.
`
`
`
`
`
`
`
`
`By:
`
`
`/s/ K. Nicole Williams
`K. Nicole Williams
`nwilliams@fr.com
`
`8
`
`Case No. 5:17-cv-04467 BLF (VKD)
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF SONICWALL’S ADMIN.
`MOTION TO FILE UNDER SEAL (ECF NO. 319)
`
`1
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`2
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`3
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`Case 5:17-cv-04467-BLF Document 322 Filed 12/07/20 Page 10 of 10
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the above and foregoing
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`document has been served on December 7, 2020 to all counsel of record who are deemed to have
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`consented to electronic service via the Court’s CM/ECF system. Any other counsel of record will
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`be served by electronic mail and regular mail.
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`By:
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`/s/ K. Nicole Williams
`K. Nicole Williams
`nwilliams@fr.com
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`9
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`Case No. 5:17-cv-04467 BLF (VKD)
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF SONICWALL’S ADMIN.
`MOTION TO FILE UNDER SEAL (ECF NO. 319)
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