Case 5:17-cv-04467-BLF Document 375 Filed 03/04/21 Page 1 of 4
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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 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 SBN 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
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`Attorneys for Plaintiff
`FINJAN LLC
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`(SAN JOSE DIVISION)
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`FINJAN LLC., a Delaware Limited Liability
`Company,
`
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`Plaintiff,
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`
`
`v.
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`SONICWALL, INC., a Delaware Corporation,
`
`
`Defendant.
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`Case No. 5:17-cv-04467-BLF (VKD)
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`OMNIBUS DECLARATION OF
`PROSHANTO MUKHERJI IN SUPPORT
`OF PLAINTIFF FINJAN LLC’S
`MOTIONS IN LIMINE NOS. 1-5
`
`Date: March 18, 2021
`Time:
`1:30 PM
` Hon. Beth Labson Freeman
` Ctrm: 3, 5th Floor
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`Case No. 17-cv-04467-BLF (VKD)
`OMNIBUS DECLARATION OF PROSHANTO MUKHERJI
`IN SUPPORT OF FINJAN’S MOTIONS IN LIMINE NOS. 1-5
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`

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`Case 5:17-cv-04467-BLF Document 375 Filed 03/04/21 Page 2 of 4
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`I, Proshanto Mukherji, hereby declare and state as follows:
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`1.
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`I am a principal in the law firm of Fish & Richardson P.C., counsel of record for
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`Plaintiff Finjan LLC in the above-captioned matter. I have personal knowledge of all the facts
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`contained herein and, if called as a witness, I could and would testify competently thereto.
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`2.
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`Attached as Exhibit 1 are true and correct copies of excerpts from the Expert Report
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`of Dr. Avi Rubin Regarding Invalidity of U.S. Patent No. 8,225,408, U.S. Patent No. 7,975,305,
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`U.S. Patent No. 7,613,926 and U.S. Patent No. 6,965,968 dated September 4, 2020.
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`3.
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`Attached as Exhibit 2 are true and correct copies of excerpts from the Expert
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`Report of Dr. Kevin Almeroth on Invalidity of U.S. Patent Nos. 6,154,844 and 8,141,154 dated
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`September 4, 2020.
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`4.
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`Attached as Exhibit 3 are true and correct copies of excerpts from the Expert
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`Report of Dr. Patrick McDaniel Regarding the Invalidity of the '494 and '780 Patents dated
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`September 4, 2020.
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`5.
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`Attached as Exhibit 4 are true and correct copies of excerpts from the deposition of
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`Avi Rubin, Ph.D. taken October 29, 2020.
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`6.
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`Attached as Exhibit 5 are true and correct copies of excerpts from the deposition of
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`Kevin Almeroth, Ph.D. taken October 20, 2020.
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`7.
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`Attached as Exhibit 6 are true and correct copies of excerpts from the deposition of
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`Patrick McDaniel, Ph.D. taken October 23, 2020.
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`8.
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`Attached as Exhibit 7 are true and correct copies of excerpts from the Expert
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`Report of Stephen L. Becker, Ph.D. on Behalf of Defendant dated October 9, 2020.
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`9.
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`Attached as Exhibit 8 are true and correct copies of excerpts from the Errata to
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`Expert Report of Stephen L. Becker, Ph.D. on Behalf of Defendant dated October 28, 2020.
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`Case No. 17-cv-04467-BLF (VKD)
`1
`OMNIBUS DECLARATION OF PROSHANTO MUKHERJI
`IN SUPPORT OF FINJAN’S MOTIONS IN LIMINE NOS. 1-5
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`

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`Case 5:17-cv-04467-BLF Document 375 Filed 03/04/21 Page 3 of 4
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`10.
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`Attached as Exhibit 9 are true and correct copies of excerpts from the deposition of
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`Stephen Becker, Ph.D. taken October 29, 2020.
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`11.
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`Attached as Exhibit 10 are true and correct copies of excerpts from the Expert
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`Report of DeForest McDuff, Ph.D. dated September 4, 2020.
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`12.
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`Attached as Exhibit 11 is a true and correct copy of Plaintiff Finjan, Inc.'s Third
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`Supplemental Objections and Responses to Defendant SonicWall, Inc.'s First Set of Interrogatories
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`(No. 6) dated July 31, 2020.
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`13.
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`Attached as Exhibit 12 is a true and correct of an excerpt from the Supplement to
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`Expert Report of Stephen L. Becker on Behalf of Defendant dated December 22, 2020.
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`14.
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`Attached as Exhibit 13 is a true and correct copy of Defendant SonicWall Inc.’s
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`Second Supplemental Response to Finjan, Inc.’s First Set of Interrogatories (No. 1) dated
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`August 21, 2020.
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`15.
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`Attached as Exhibit 14 is a true and correct copy of an excerpt from Plaintiff
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`Finjan, Inc.’s Disclosure of Damages Contentions Pursuant to Patent Local Rule 3-8 dated July 16,
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`2018.
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`16.
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`Attached as Exhibit 15 is a true and correct copy of an excerpt from Defendant
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`SonicWall Inc.’s Responsive Damages Contentions Pursuant to Patent L.R. 3-9 dated August 15,
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`2018.
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`17.
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`Attached as Exhibit 16 is a true and correct copy of an excerpt from the Sellers
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`Disclosure Schedule between Dell Inc., Dell International L.L.C. and Seahawk Holding (Cayman)
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`Limited dated June 19, 2016 [Daar Depo Exh. 6].
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`18.
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`Attached as Exhibit 17 is a true and correct copy of an excerpt from the deposition
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`transcript of John Gmuender taken July 9, 2020.
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`Case No. 17-cv-04467-BLF (VKD)
`2
`OMNIBUS DECLARATION OF PROSHANTO MUKHERJI
`IN SUPPORT OF FINJAN’S MOTIONS IN LIMINE NOS. 1-5
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`

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`Case 5:17-cv-04467-BLF Document 375 Filed 03/04/21 Page 4 of 4
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`I declare under the penalty of perjury of the laws of the United States of America that the
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`foregoing is true and correct. Executed on March 4, 2021, in Boston, Massachusetts.
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`By:
`
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`/s/ Proshanto Mukherji
`Proshanto Mukherji
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`Case No. 17-cv-04467-BLF (VKD)
`3
`OMNIBUS DECLARATION OF PROSHANTO MUKHERJI
`IN SUPPORT OF FINJAN’S MOTIONS IN LIMINE NOS. 1-5
`
`