Case 5:17-cv-04467-BLF Document 401-1 Filed 03/11/21 Page 1 of 11
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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 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
`
`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 FINJAN
`LLC’S OMNIBUS ADMINISTRATIVE
`MOTION TO FILE UNDER SEAL ITS
`OPPOSITIONS TO SONICWALL’S
`MOTION IN LIMINE NOS. 1, 2 and 4
`AND EXHIBITS
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`Case No. 5:17-cv-04467 BLF (VKD)
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF FINJAN’S ADMIN.
`MOTION TO FILE UNDER SEAL
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`Case 5:17-cv-04467-BLF Document 401-1 Filed 03/11/21 Page 2 of 11
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`I, K. Nicole Williams, hereby declare and state as follows:
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`1.
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`I am licensed to practice in the State of California and am a principal in the law firm
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`of Fish & Richardson P.C., counsel of record for Plaintiff Finjan LLC in the above-captioned matter.
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`I have personal knowledge of all the facts contained herein and, if called as a witness, I could and
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`would testify competently thereto.
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`2.
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`I submit this declaration in support of Finjan LLC’s Omnibus Administration Motion
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`to File Under Seal its Opposition to SonicWall’s Motions in Limine Nos. 1, 2 and 4, and
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`accompanying Exhibits A-G, J-L, and O. All exhibits are attached to the Omnibus Declaration of
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`Robert Courtney in Support of Finjan’s Oppositions to SonicWall’s Motions in Limine . As required
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`under Civil L.R. 79-5(d)(1)(A), Civil L.R. 79-5(e), and this Court’s Standing Order, the basis for
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`asserting confidentiality and the grounds for filing under seal the documents listed below are as
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`follows:
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`Document
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`Portion(s) to Seal
`
`Reason(s) for Sealing
`
`ECF or
`Exh. No.
`ECF 398
`
`Highlighted portion at
`page 4, line 13
`
`Finjan LLC’s
`Opposition to
`SonicWall’s Motion in
`Limine To Exclude
`Background and
`Opinions (Motion in
`Limine No. 1)
`
`This document reflects
`information SonicWall has
`designated “Highly
`Confidential – Attorneys’
`Eyes Only” pursuant to the
`Stipulated Protective Order,
`and from which confidential
`information regarding
`SonicWall’s accused
`products could potentially
`be discerned. See Williams
`Decl. ¶ 3.
`This document reflects
`information regarding
`Finjan’s internal business
`practices and licensing
`negotiations, which Finjan
`has designated “HIGHLY
`CONFIDENTIAL –
`ATTORNEYS’ EYES
`ONLY” under the Protective
`
`ECF 399
`
`Finjan LLC’s
`Opposition to
`SonicWall’s Motion in
`Limine To Exclude Dr.
`McDuff’s Method No.
`1 (Motion in Limine
`No. 2)
`
`Highlighted portions
`at page 1, lines 16, 18,
`20; page 2, lines 1, 10,
`12-15; page 3, line 20;
`page 4, lines 11, 15-
`16; page 5, lines 7, 9-
`10, 15-17, 19.
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`Case No. 5:17-cv-04467 BLF (VKD)
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`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF FINJAN’S ADMIN.
`MOTION TO FILE UNDER SEAL
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`

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`Case 5:17-cv-04467-BLF Document 401-1 Filed 03/11/21 Page 3 of 11
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`Order (ECF No. 68).
`Additionally, the
`highlighted portions include
`third party confidential
`information regarding
`licensing with Finjan.
`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.”) ¶ 4.
`This document also reflects
`information SonicWall has
`designated “Highly
`Confidential – Attorneys’
`Eyes Only” pursuant to the
`Stipulated Protective Order,
`and from which confidential
`information regarding
`SonicWall’s accused
`products could potentially
`be discerned.
`This document reflects
`information regarding
`Finjan’s internal 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 also reflects
`information SonicWall has
`designated “Highly
`Confidential – Attorneys’
`Eyes Only” pursuant to the
`Stipulated Protective Order,
`and from which confidential
`information regarding
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`ECF 393
`
`Finjan LLC’s
`Opposition to
`SonicWall’s Motion in
`Limine To Exclude Dr.
`McDuff’s Method No.
`3 (Motion in Limine
`No. 4)
`
`Highlighted portions
`at page 1, lines 17-25;
`page 2, lines 1-4, 21-
`24; page 3, lines 1-8,
`lines, 10-15, 18; page
`4, lines 1-3, 7, 20-21,
`23-25; page 5, lines 1-
`2, 19.
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`Case No. 5:17-cv-04467 BLF (VKD)
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`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF FINJAN’S ADMIN.
`MOTION TO FILE UNDER SEAL
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`

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`Case 5:17-cv-04467-BLF Document 401-1 Filed 03/11/21 Page 4 of 11
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`Exh. A
`
`Excerpts from Expert
`Report of DeForest
`McDuff, Ph.D. dated
`September 4, 2020
`
`Entirety
`
`SonicWall’s accused
`products could potentially
`be discerned.
`This document reflects
`information regarding
`Finjan’s internal 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 also reflects
`information SonicWall has
`designated “Highly
`Confidential – Attorneys’
`Eyes Only” pursuant to the
`Stipulated Protective Order,
`and from which confidential
`information regarding
`SonicWall’s accused
`products could potentially
`be discerned.
`This document reflects
`information SonicWall has
`designated “Highly
`Confidential – Attorneys’
`Eyes Only” and “Highly
`Confidential – Attorneys’
`Eyes Only – Source Code”
`pursuant to the Stipulated
`Protective Order, and from
`which confidential
`information regarding
`SonicWall’s accused
`products could potentially
`be discerned. See Williams
`Decl. ¶ 7.
`This document reflects
`information SonicWall has
`designated “Highly
`Confidential – Attorneys’
`
`Entirety
`
`Excerpts from the
`Expert Report of Dr.
`Eric Cole Regarding
`Technology Tutorial
`and Infringement by
`SonicWall, Inc. of
`Patent Nos. 6,154,844;
`7,058,822; 7,647,633
`and 8,677,494 dated
`September 3, 2020
`
`Excerpts from the
`Expert Report of
`Michael
`Mitzenmacher, Ph.D.
`
`Entirety
`
`Exh. B
`
`Exh. C
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`3
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`Case No. 5:17-cv-04467 BLF (VKD)
`
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF FINJAN’S ADMIN.
`MOTION TO FILE UNDER SEAL
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`Case 5:17-cv-04467-BLF Document 401-1 Filed 03/11/21 Page 5 of 11
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`Exh. D
`
`Regarding
`Infringement by
`SonicWall, Inc. of
`Patent Nos. 6,804,780;
`6,965,968 and
`7,613,926 dated
`September 3, 2020
`
`Excerpts from the
`Expert Report of Dr.
`Nenad Medvidovic
`Regarding
`Infringement by
`SonicWall, Inc. of
`Patent Nos. 8,225,408;
`7,975,305 and
`8,141,154 dated
`September 3, 2020
`
`Entirety
`
`Exh. E
`
`Entirety
`
`Excerpts from the
`deposition transcript of
`DeForest McDuff,
`Ph.D. taken November
`2, 2020
`
`Eyes Only” and “Highly
`Confidential – Attorneys’
`Eyes Only – Source Code”
`pursuant to the Stipulated
`Protective Order, and from
`which confidential
`information regarding
`SonicWall’s accused
`products could potentially
`be discerned. See Williams
`Decl. ¶ 7.
`This document reflects
`information SonicWall has
`designated “Highly
`Confidential – Attorneys’
`Eyes Only” and “Highly
`Confidential – Attorneys’
`Eyes Only – Source Code”
`pursuant to the Stipulated
`Protective Order, and from
`which confidential
`information regarding
`SonicWall’s accused
`products could potentially
`be discerned. See Williams
`Decl. ¶ 7.
`This deposition transcript
`reflects information
`regarding Finjan’s internal
`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 also reflects
`information SonicWall has
`designated “Highly
`Confidential – Attorneys’
`Eyes Only” pursuant to the
`Stipulated Protective Order,
`
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`Case No. 5:17-cv-04467 BLF (VKD)
`
`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF FINJAN’S ADMIN.
`MOTION TO FILE UNDER SEAL
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`Case 5:17-cv-04467-BLF Document 401-1 Filed 03/11/21 Page 6 of 11
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`Exh. F
`
`Excerpts from Expert
`Report of Dr. Aaron
`Striegel dated
`September 3, 2020
`
`Entirety
`
`Exh. G
`
`Entirety
`
`Excerpts from the
`deposition transcript of
`Aaron Striegel, Ph.D.
`taken November 3,
`2020
`
`and from which confidential
`information regarding
`SonicWall’s accused
`products could potentially
`be discerned.
`This document reflects
`information SonicWall has
`designated “Highly
`Confidential – Attorneys’
`Eyes Only” pursuant to the
`Stipulated Protective Order,
`and from which confidential
`information regarding
`SonicWall’s accused
`products could potentially
`be discerned. See Williams
`Decl. ¶ 7.
`This deposition transcript
`reflects information
`SonicWall has designated
`“Highly Confidential –
`Attorneys’ Eyes Only”
`pursuant to the Stipulated
`Protective Order, and from
`which confidential
`information regarding
`SonicWall’s accused
`products could potentially
`be discerned. See Williams
`Decl. ¶ 7.
`This document was
`designated by SonicWall as
`“Highly Confidential –
`Attorneys’ Eyes Only”
`pursuant to the Stipulated
`Protective Order. See
`Williams Decl. ¶ 8.
`This document was
`designated by SonicWall as
`“Highly Confidential –
`Attorneys’ Eyes Only”
`pursuant to the Stipulated
`Protective Order. See
`Williams Decl. ¶ 8.
`This document was
`designated by SonicWall as
`“Highly Confidential –
`
`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
`Excerpts from the
`Expert Report of Dr.
`Patrick McDaniel
`Regarding the
`Invalidity of the ‘494
`and ‘780 Patents dated
`September 4, 2020
`Excerpts from the
`Rebuttal Expert Report
`of Dr. Patrick
`
`Entirety
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`Entirety
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`Entirety
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`Exh. J
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`Exh. K
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`Exh. L
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`Case No. 5:17-cv-04467 BLF (VKD)
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`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF FINJAN’S ADMIN.
`MOTION TO FILE UNDER SEAL
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`Case 5:17-cv-04467-BLF Document 401-1 Filed 03/11/21 Page 7 of 11
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`Exh. O
`
`McDaniel Regarding
`Non-Infringement of
`U.S. Patent Nos.
`6,804,780 and
`8,677,494 dated
`October 9, 2020
`Excerpts from the
`Expert Report of
`Stephen L. Becker,
`Ph.D. on Behalf of
`Defendant dated
`October 9, 2020
`
`Entirety
`
`Attorneys’ Eyes Only –
`Source Code” pursuant to
`the Stipulated Protective
`Order. See Williams Decl. ¶
`8.
`
`This document reflects
`information regarding
`Finjan’s internal 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 also reflects
`information SonicWall has
`designated “Confidential –
`Outside Counsel Eyes Only”
`pursuant to the Stipulated
`Protective Order, and from
`which confidential
`information regarding
`SonicWall’s accused
`products could potentially
`be discerned.
`
`3.
`
`The highlighted portion of Finjan LLC’s Opposition to SonicWall’s Motion in
`
`Limine No. 1 reflects information SonicWall has designated “Highly Confidential – Attorneys’ Eyes
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`Only” pursuant to the Stipulated Protective Order, and from which confidential information
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`regarding SonicWall’s accused products could potentially be discerned
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`4.
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`The highlighted portions of Finjan LLC’s Opposition to SonicWall’s Motion in
`
`Limine No. 2 reflect information and testimony regarding Finjan’s business practices and licensing
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`negotiations, which Finjan designated as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
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`ONLY” subject to the Protective Order. Additionally, the highlighted portions contain confidential
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`Case No. 5:17-cv-04467 BLF (VKD)
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`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF FINJAN’S ADMIN.
`MOTION TO FILE UNDER SEAL
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`Case 5:17-cv-04467-BLF Document 401-1 Filed 03/11/21 Page 8 of 11
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`information of third parties regarding their licensing negotiations with Finjan. Finjan treats this
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`confidential business and licensing information as highly confidential within its business and makes
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`substantial efforts not to disclose such information to the public. Such information could be used
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`4
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`by Finjan’s competitors, as it reveals information related to Finjan’s business practices and dealings.
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`5
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`The highlighted portions also reflect information SonicWall has designated “Highly Confidential –
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`Attorneys’ Eyes Only” pursuant to the Stipulated Protective Order (ECF No. 68), and from which
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`confidential information regarding SonicWall’s accused products could potentially be discerned.
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`Accordingly, good cause and compelling reasons exist to seal the highlighted portions of Finjan’s
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`Opposition to SonicWall’s Motion in Limine No. 2.
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`5.
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`The highlighted portions of Finjan LLC’s Opposition to SonicWall’s Motion in
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`Limine No. 4 reflect information and testimony regarding Finjan’s business practices and licensing
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`negotiations, which Finjan designated as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
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`ONLY” subject to the Protective Order. Additionally, the highlighted portions contain confidential
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`information of third parties regarding their licensing negotiations with Finjan. Finjan treats this
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`confidential business and licensing information as highly confidential within its business and makes
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`substantial efforts not to disclose such information to the public. Such information could be used
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`by Finjan’s competitors, as it reveals information related to Finjan’s business practices and dealings.
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`The highlighted portions also reflect information SonicWall has designated “Highly Confidential –
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`Attorneys’ Eyes Only” pursuant to the Stipulated Protective Order (ECF No. 68), and from which
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`confidential information regarding SonicWall’s accused products could potentially be discerned.
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`Accordingly, good cause and compelling reasons exist to seal the highlighted portions of Finjan’s
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`Opposition to SonicWall’s Motion in Limine No. 4.
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`6.
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`Exhibits A and E to the Courtney Declaration reflect information regarding Finjan’s
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`business practices and
`
`licensing negotiations, which Finjan designated as “HIGHLY
`
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`Case No. 5:17-cv-04467 BLF (VKD)
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`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF FINJAN’S ADMIN.
`MOTION TO FILE UNDER SEAL
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`Case 5:17-cv-04467-BLF Document 401-1 Filed 03/11/21 Page 9 of 11
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`CONFIDENTIAL – ATTORNEYS’ EYES ONLY” subject to the Protective Order. Additionally,
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`the highlighted portions contain confidential information of third parties regarding their licensing
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`negotiations with Finjan. Finjan treats this confidential business and licensing information as highly
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`confidential within its business and makes substantial efforts not to disclose such information to the
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`public. Such information could be used by Finjan’s competitors, as it reveals information related to
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`Finjan’s business practices and dealings. The document also reflect information SonicWall has
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`designated “Highly Confidential – Attorneys’ Eyes Only” pursuant to the Stipulated Protective
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`8
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`Order (ECF No. 68), and from which confidential information regarding SonicWall’s accused
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`products could potentially be discerned. Accordingly, good cause and compelling reasons exist to
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`seal Exhibits A and E to the Courtney Declaration.
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`7.
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`Exhibits B, C, D, F, and G reflect information SonicWall has designated “Highly
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`Confidential – Attorneys’ Eyes Only” or “Highly Confidential – Attorneys’ Eyes Only – Source
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`13
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`Code” pursuant to the Stipulated Protective Order, and from which confidential information
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`regarding SonicWall’s accused products could potentially be discerned.
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`8.
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`SonicWall designated Exhibits J, K, and L to the Courtney Declaration have been
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`designated “Highly Confidential – Attorneys’ Eyes Only” or “Highly Confidential – Attorneys’
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`Eyes Only – Source Code” by SonicWall pursuant to the Stipulated Protective Order (ECF No. 68).
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`9.
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`Exhibit O to the Courtney Declaration reflects information regarding Finjan’s
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`business practices and
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`licensing negotiations, which Finjan designated as “HIGHLY
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`CONFIDENTIAL – ATTORNEYS’ EYES ONLY” subject to the Protective Order. Additionally,
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`the highlighted portions contain confidential information of third parties regarding their licensing
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`negotiations with Finjan. Finjan treats this confidential business and licensing information as highly
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`confidential within its business and makes substantial efforts not to disclose such information to the
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`public. Such information could be used by Finjan’s competitors, as it reveals information related to
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`Case No. 5:17-cv-04467 BLF (VKD)
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`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF FINJAN’S ADMIN.
`MOTION TO FILE UNDER SEAL
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`Case 5:17-cv-04467-BLF Document 401-1 Filed 03/11/21 Page 10 of 11
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`Finjan’s business practices and dealings. The was also designated “Confidential – Outside Counsel
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`Eyes Only” by SonicWall pursuant to the Stipulated Protective Order (ECF No. 68), and from which
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`confidential information regarding SonicWall’s accused products could potentially be discerned.
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`Accordingly, good cause and compelling reasons exist to seal Exhibit O to the Courtney Declaration.
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`10.
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`Plaintiff Finjan has carefully balanced the need to protect highly confidential and
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`proprietary information along with information that is reasonable for the public to know. Finjan has
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`demonstrated “good cause” and “compelling reasons” for filing this information under seal.
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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.
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`Executed on March 11, 2021, in San Diego, California.
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`/s/ K. Nicole Williams
`K. Nicole Williams
`nwilliams@fr.com
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`Case No. 5:17-cv-04467 BLF (VKD)
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`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF FINJAN’S ADMIN.
`MOTION TO FILE UNDER SEAL
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`Case 5:17-cv-04467-BLF Document 401-1 Filed 03/11/21 Page 11 of 11
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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 March 11, 2021 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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`/s/ K. Nicole Williams
`K. Nicole Williams
`nwilliams@fr.com
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`Case No. 5:17-cv-04467 BLF (VKD)
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`DECLARATION OF K. NICOLE WILLIAMS
`IN SUPPORT OF FINJAN’S ADMIN.
`MOTION TO FILE UNDER SEAL
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