`
`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 317591) fryckman@fr.com
`K. Nicole Williams (CA291900) nwilliams@fr.com
`FISH & RICHARDSON P.C.
`12860 El Camino Real, Ste. 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,
`
` Plaintiff,
`
`
`v.
`
`
`SONICWALL, INC.,
`
` Defendant.
`
`Case No. 5:17-cv-04467-BLF (VKD)
`
`DECLARATION OF ROBERT
`COURTNEY IN SUPPORT OF
`PLAINTIFF FINJAN LLC’S MOTION TO
`PRECLUDE TRIAL TESTIMONY
`RELATING TO WRITTEN
`DESCRIPTION
`
`Date: June 24, 2021
`Time: 9:00 a.m.
`Judge: Hon. Beth Labson Freeman
`Dept: Courtroom 3, Fifth Floor
`
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`Case No. 17-cv-04467-BLF (VKD)
`DECLARATION OF ROBERT COURTNEY IN
`SUPPORT OF FINJAN’S DAUBERT MOTION
`RE WRITTEN DESCRIPTION
`
`
`
`Case 5:17-cv-04467-BLF Document 348-1 Filed 01/21/21 Page 2 of 3
`
`
`
`
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`I, Robert Courtney, 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.
`
`Attached as Exhibit A are true and correct copies of excerpts from the Expert Report
`
`of Dr. Avi Rubin Regarding Invalidity of U.S. Patent No. 8,225,408, U.S. Patent No. 7,975,305,
`
`U.S. Patent No. 7,613,926 and U.S. Patent No. 6,965,968 dated September 4, 2020.
`
`3.
`
`Attached as Exhibit B are true and correct copies of excerpts from the Expert Report
`
`of Dr. Kevin Almeroth on Invalidity of U.S. Patent Nos. 6,154,844 and 8,141,154 dated
`
`September 4, 2020.
`
`4.
`
`Attached as Exhibit C are true and correct copies of excerpts from the Expert Report
`
`of Dr. Patrick McDaniel Regarding the Invalidity of the ‘494 and ‘780 Patents dated September 4,
`
`2020.
`
`5.
`
`Attached as Exhibit D are true and correct copies of excerpts from the deposition of
`
`Avi Rubin, Ph.D. taken October 29, 2020.
`
`6.
`
`Attached as Exhibit E are true and correct copies of excerpts from the deposition of
`
`Kevin Almeroth, Ph.D. taken October 20, 2020.
`
`7.
`
`Attached as Exhibit F are true and correct copies of excerpts from the deposition of
`
`Patrick McDaniel, Ph.D. taken October 23, 2020.
`
`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 January 21, 2021, in Minneapolis, Minnesota.
`
`
`
`
`
`
`
`By:
`
`
`/s/ Robert Courtney
`Robert Courtney
`
`1
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`Case No. 17-cv-04467-BLF (VKD)
`DECLARATION OF ROBERT COURTNEY IN
`SUPPORT OF FINJAN’S DAUBERT MOTION
`RE WRITTEN DESCRIPTION
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`Case 5:17-cv-04467-BLF Document 348-1 Filed 01/21/21 Page 3 of 3
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the above and foregoing
`
`document has been served on January 21, 2021 to all counsel of record who are deemed to have
`
`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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`/s/ Robert Courtney
`Robert Courtney
`courtney@fr.com
`
`Attorney for Plaintiff
`FINJAN LLC
`
`
`
`2
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`Case No. 17-cv-04467-BLF (VKD)
`DECLARATION OF ROBERT COURTNEY IN
`SUPPORT OF FINJAN’S DAUBERT MOTION
`RE WRITTEN DESCRIPTION
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