Case 5:17-cv-04467-BLF Document 404 Filed 03/11/21 Page 1 of 11
`
`DUANE MORRIS LLP
`D. Stuart Bartow (CA SBN 233107)
`dsbartow@duanemorris.com
`Nicole E. Grigg (CA SBN 307733)
`negrigg@duanemorris.com
`2475 Hanover Street
`Palo Alto, CA 94304-1194
`Telephone: 650.847.4150
`Facsimile: 650.847.4151
`DUANE MORRIS LLP
`Joseph A. Powers (PA SBN 84590)
`Admitted Pro Hac Vice
`japowers@duanemorris.com
`Jarrad M. Gunther (PA SBN 207038)
`Admitted Pro Hac Vice
`jmgunther@duanemorris.com
`30 South 17th Street
`Philadelphia, PA 19103
`Telephone: 215.979.1000
`Facsimile: 215.979.1020
`Attorneys for Defendant
`SONICWALL INC.
`
`DUANE MORRIS LLP
`Matthew C. Gaudet (GA SBN 287789)
`Admitted Pro Hac Vice
`mcgaudet@duanemorris.com
`John R. Gibson (GA SBN 454507)
`Admitted Pro Hac Vice
`jrgibson@duanemorris.com
`Robin L. McGrath (GA SBN 493115)
`Admitted Pro Hac Vice
`rlmcgrath@duanemorris.com
`David C. Dotson (GA SBN 138040)
`Admitted Pro Hac Vice
`dcdotson@duanemorris.com
`Jennifer H. Forte (GA SBN 940650)
`Admitted Pro Hac Vice
`jhforte@duanemorris.com
`1075 Peachtree NE, Suite 2000
`Atlanta, GA 30309
`Telephone: 404.253.6900
`Facsimile: 404.253.6901
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`FINJAN, LLC, A Delaware Limited Liability
`Company,
`
`
`Plaintiff,
`
`
`SONICWALL INC., a Delaware Corporation,
`
`
`
`
`v.
`
`
`
`
`
`
`
`
` Case No.: 5:17-cv-04467-BLF-VKD
`
`SONICWALL INC.’S ADMINISTRATIVE
`MOTION TO FILE DOCUMENTS UNDER
`SEAL
`
`
`Defendant.
`
`
`SONICWALL INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
`CASE NO. 5:17-CV-04467-BLF-VKD
`
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`Case 5:17-cv-04467-BLF Document 404 Filed 03/11/21 Page 2 of 11
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`I.
`
`Exh. No.
`
`
`
`Document
`SonicWall’s Response
`to Finjan’s Motion in
`Limine No. 2 to
`Preclude Certain
`Damages Testimony
`by Dr. Becker
`
`INTRODUCTION
`Pursuant to Civil L.R. 7-11 and 79-5, this Court’s Standing Civil Order Re: Civil Cases, the
`Parties Stipulated Protective Order (Dkt. 68) and Federal Rule of Civil Procedure 26(b)(5)(B),
`Defendant SonicWall Inc. (“SonicWall”) hereby moves the Court for leave to file under seal,
`pursuant to Civil L.R. 79-5(d)-(e), the items identified in the table below:
`Portion(s) to
`Seal
`Highlighted
`portions at:
`Pg. 1 at lines 19-
`24; pg. 3 at lines
`15-27; pg. 4 at
`lines 1-6, and 10-
`13; pg. 5 at lines
`6-11
`
`Reason(s) for Sealing
`The highlighted portions of this
`document reflect information that
`SonicWall has designated as
`“Highly Confidential – Attorneys’
`Eyes Only” pursuant to the
`Stipulated Protective Order. If
`filed publicly, this confidential
`information could be used to
`SonicWall’s disadvantage by
`competitors as it concerns
`SonicWall’s confidential business
`information. Additionally,
`highlighted portions of this
`document reflect information that
`Finjan has designated as “Highly-
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Protective
`Order. See Declaration of Nicole E.
`Grigg in Support of Administrative
`Motion to File Documents Under
`Seal (“Grigg Declaration”), ¶¶ 2-5.
`The highlighted portions of this
`document reflect information that
`Finjan has designated as “Highly-
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Protective
`Order. See Declaration of Nicole E.
`Grigg in Support of Administrative
`Motion to File Documents Under
`Seal (“Grigg Declaration”), ¶¶ 2-5.
`
`The highlighted portions of this
`document reflect information that
`Finjan has designated as
`“Highly-Confidential –
`Attorneys’ Eyes Only” pursuant
`to the Protective Order. See
`Declaration of Nicole E. Grigg in
`Support of Administrative
`Motion to File Documents Under
`Seal (“Grigg Declaration”), ¶¶ 2-
`
`SonicWall’s Response
`to Finjan’s Motion in
`Limine No. 4 to
`Preclude Evidence or
`Testimony Regarding
`Mr. Touboul’s
`Replacement as CEO
`of Finjan
`
`SonicWall’s
`Response to Finjan’s
`Motion in Limine
`No. 5 to Preclude
`Evidence of Other
`Pending Proceedings
`Involving Finjan
`
`Highlighted
`portions at:
`Pg. 1 at lines 11-
`12, 14-15 and 19-
`24; pg. 2 at 16-
`17, 19-25 and 27;
`pg. 3 at lines 18-
`19 and 21
`Highlighted
`portions at:
`Pg. 1 at lines
`27-28; Pg. 2 at
`lines 1-3 and 9-
`11
`
`
`
`
`
`
`
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`SONICWALL INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
`CASE NO. 5:17-CV-04467-BLF-VKD
`
`

`

`Case 5:17-cv-04467-BLF Document 404 Filed 03/11/21 Page 3 of 11
`
`Exh. No.
`
`Document
`
`Portion(s) to
`Seal
`
`36 to
`Gunther
`Declaration
`
`37 to
`Gunther
`Declaration
`
`SonicWall’s
`Responsive Damages
`Contentions Pursuant
`to Patent L.R. 3-9
`
`Entire
`
`Entirety
`
`Excerpts from the
`September 4, 2020
`Expert Report of
`DeForest McDuff,
`Ph.D.
`
`Reason(s) for Sealing
`
`5.
`This document contains
`information that Finjan has
`designated as “Confidential”
`pursuant to the Stipulated
`Protective Order. See Grigg
`Declaration, ¶¶ 2-5.
`This document contains
`information that SonicWall has
`designated as “Highly Confidential
`– Attorneys’ Eyes Only” or
`“Highly Confidential – Attorneys’
`Eyes Only - Source Code”
`pursuant to the Stipulated
`Protective Order. If filed publicly,
`this confidential information could
`be used to SonicWall’s
`disadvantage by competitors as it
`concerns the identification,
`organization, and or operation of
`SonicWall’s proprietary products
`as well as SonicWall’s confidential
`business information. Additionally,
`this document contains information
`designated by Finjan as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order. See Grigg
`Declaration, ¶¶ 2-5.
`
`
`
`2
`SONICWALL INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
`CASE NO. 5:17-CV-04467-BLF-VKD
`
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`Case 5:17-cv-04467-BLF Document 404 Filed 03/11/21 Page 4 of 11
`
`Exh. No.
`
`38 to
`Gunther
`Declaration
`
`Document
`
`Excerpts from the
`October 9, 2020
`Expert Report of
`Stephen L. Becker
`
`Portion(s) to
`Seal
`Entirety
`
`39 to
`Gunther
`Declaration
`
`Entirety
`
`Evidence cited in the
`October 9, 2020
`Expert Report of
`Stephen L. Becker
`(SLB-1A and SLB-
`1B)
`
`Reason(s) for Sealing
`
`This document contains
`testimony that SonicWall has
`designated as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order. If filed
`publicly, this confidential
`information could be used to
`SonicWall’s disadvantage by
`competitors as it concerns the
`identification, organization, and
`or operation of SonicWall’s
`proprietary products, as well as
`confidential business and
`financial information of
`SonicWall. Additionally, this
`document contains information
`designated by Finjan as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order. See Grigg
`Declaration, ¶¶ 2-5.
`This document contains
`testimony that SonicWall has
`designated as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order. If filed
`publicly, this confidential
`information could be used to
`SonicWall’s disadvantage by
`competitors as it concerns
`SonicWall’s confidential
`business and financial
`information. See Grigg
`Declaration, ¶¶ 2-5.
`
`
`
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`SONICWALL INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
`CASE NO. 5:17-CV-04467-BLF-VKD
`
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`Case 5:17-cv-04467-BLF Document 404 Filed 03/11/21 Page 5 of 11
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`Portion(s) to
`Seal
`Entirety
`
`Entirety
`
`Entirety
`
`Entirety
`
`Exh. No.
`
`40 to
`Gunther
`Declaration
`
`41 to
`Gunther
`Declaration
`
`42 to
`Gunther
`Declaration
`
`43 to
`Gunther
`Declaration
`
`Document
`
`Excerpts from the
`August 6, 2019
`deposition transcript
`of Shlomo Touboul,
`taken in the matter
`of Finjan LLC v.
`Cisco Systems, Inc.,
`Case No. 5:17-cv-
`00072 (N.D. Ca.)
`(“the Cisco Case”)
`Excerpts from the
`November 2, 2020
`deposition transcript
`of DeForest McDuff
`
`Excerpts from the
`September 4, 2020
`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
`
`Excerpts from the
`September 4, 2020
`Expert Report of Dr.
`Kevin Almeroth on
`Invalidity of U.S.
`Patent Nos.
`6,154,844 and
`8,141,154
`
`Reason(s) for Sealing
`
`This document contains
`testimony that Finjan has
`designated as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order. See Grigg
`Declaration, ¶¶ 2-5.
`
`This document contains testimony
`that Finjan has designated as
`“Highly Confidential – Attorneys’
`Eyes Only” pursuant to the
`Stipulated Protective Order. See
`Grigg Declaration, ¶¶ 2-5.
`This document contains
`testimony that SonicWall has
`designated as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order. If filed
`publicly, this confidential
`information could be used to
`SonicWall’s disadvantage by
`competitors as it concerns the
`identification, organization, and
`or operation of SonicWall’s
`proprietary products. See Grigg
`Declaration, ¶¶ 2-5.
`This document contains
`testimony that SonicWall has
`designated as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order. If filed
`publicly, this confidential
`information could be used to
`SonicWall’s disadvantage by
`competitors as it concerns the
`identification, organization, and
`or operation of SonicWall’s
`proprietary products. See Grigg
`Declaration, ¶¶ 2-5.
`
`
`
`4
`SONICWALL INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
`CASE NO. 5:17-CV-04467-BLF-VKD
`
`

`

`Case 5:17-cv-04467-BLF Document 404 Filed 03/11/21 Page 6 of 11
`
`Portion(s) to
`Seal
`Entirety
`
`Exh. No.
`
`44 to
`Gunther
`Declaration
`
`Document
`
`Excerpts from the
`September 4, 2020
`Expert Report of Dr.
`Patrick McDaniel
`Regarding the
`Invalidity of the
`‘494 and ‘780
`Patents
`
`45 to
`Gunther
`Declaration
`
`46 to
`Gunther
`Declaration
`
`Entirety
`
`Entirety
`
`Excerpts from
`Finjan’s Objections
`and Responses to
`SonicWall’s Third
`Set of
`Interrogatories (Nos.
`11-25)
`Exhibit 13 to the
`August 5, 2019
`deposition of Asher
`Polani, taken in the.
`Cisco case
`
`47 to
`Gunther
`Declaration
`
`Exhibit 14 to the
`August 5, 2019
`deposition of Asher
`Polani, taken in the.
`Cisco case
`
`Entirety
`
`Reason(s) for Sealing
`
`This document contains
`testimony that SonicWall has
`designated as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order. If filed
`publicly, this confidential
`information could be used to
`SonicWall’s disadvantage by
`competitors as it concerns the
`identification, organization, and
`or operation of SonicWall’s
`proprietary products. See Grigg
`Declaration, ¶¶ 2-5.
`This document contains
`information that Finjan has
`designated as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order. See Grigg
`Declaration, ¶¶ 2-5.
`This document was produced in
`the Cisco case and contains
`information that Finjan
`designated as “Confidential”
`pursuant to the Stipulated
`Protective Order entered in the
`Cisco case. See Grigg
`Declaration, ¶¶ 2-5.
`This document was produced in
`the Cisco case and contains
`information that Finjan
`designated as “Confidential”
`pursuant to the Stipulated
`Protective Order entered in the
`Cisco case. See Grigg
`Declaration, ¶¶ 2-5.
`
`
`
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`SONICWALL INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
`CASE NO. 5:17-CV-04467-BLF-VKD
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`Case 5:17-cv-04467-BLF Document 404 Filed 03/11/21 Page 7 of 11
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`Portion(s) to
`Seal
`Entirety
`
`Exh. No.
`
`48 to
`Gunther
`Declaration
`
`Document
`
`Exhibit 31 to the
`August 6, 2019
`deposition of
`Shlomo Touboul,
`taken in the Cisco
`case
`
`49 to
`Gunther
`Declaration
`
`Exhibit 4 to the
`August 5, 2019
`deposition of Asher
`Polani, taken in the
`Cisco case
`
`Entirety
`
`50 to
`Gunther
`Declaration
`
`Excerpts of the
`August 5, 2019
`deposition of Asher
`Polani, taken in the
`Cisco case
`
`Entirety
`
`51 to
`Gunther
`Declaration
`
`Exhibit 7 to the
`August 5, 2019
`deposition of Asher
`Polani, taken in the
`Cisco case
`
`Entirety
`
`54 to
`Gunther
`Declaration
`
`Excerpts from the
`February 25, 2019
`deposition of Philip
`Hartstein, taken in
`the Cisco case
`
`Entirety
`
`Reason(s) for Sealing
`
`This document was produced in
`the Cisco case and contains
`information that Finjan
`designated as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order entered in the
`Cisco case. See Grigg
`Declaration, ¶¶ 2-5.
`This document was produced in
`the Cisco case and contains
`information that Finjan
`designated as “Confidential”
`pursuant to the Stipulated
`Protective Order entered in the
`Cisco case. See Grigg
`Declaration, ¶¶ 2-5.
`This document was produced in
`the Cisco case and contains
`information that Finjan
`designated as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order entered in the
`Cisco case. See Grigg
`Declaration, ¶¶ 2-5.
`This document was produced in
`the Cisco case and contains
`information that Finjan
`designated as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order entered in the
`Cisco case. See Grigg
`Declaration, ¶¶ 2-5.
`This document contains
`testimony that Finjan has
`designated as “Highly
`Confidential – Attorneys’ Eyes
`Only” pursuant to the Stipulated
`Protective Order in the Cisco
`case. See Grigg Declaration, ¶¶
`2-5.
`
`
`
`6
`SONICWALL INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
`CASE NO. 5:17-CV-04467-BLF-VKD
`
`

`

`Case 5:17-cv-04467-BLF Document 404 Filed 03/11/21 Page 8 of 11
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`
`II.
`
`ARGUMENT
`A.
`Legal Standard
`There is a presumption of public access to judicial records and documents. Nixon v. Warner
`Commc'ns, Inc., 435 U.S. 589, 597 (1978). However, records attached to non-dispositive motions,
`such is the case here, are not subject to the strong presumption of access. Finjan, Inc. v. Proofpoint,
`Inc., No. 13-CV-05808-HSG, 2015 WL 9023164, at *1 (N.D. Cal. Dec. 16, 2015) (internal citation
`omitted). Because the documents attached to non-dispositive motions “are often unrelated, or only
`tangentially related, to the underlying cause of action,” parties moving to seal must meet the lower
`“good cause” standard of the Federal Rules of Civil Procedure Rule 26(c). Id. (internal quotation
`marks omitted). The “good cause” standard requires a “particularized showing” that “specific
`prejudice or harm will result” if the information is disclosed. Phillips ex rel. Estates of Byrd v. Gen.
`Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002) (internal quotation marks omitted); see Fed.
`R. Civ. P. 26(c). “Broad allegations of harm, unsubstantiated by specific examples of articulated
`reasoning” will not suffice. Beckman Indus., Inc. v. Int'l Ins. Co., 966 F.2d 470, 476 (9th Cir. 1992).
`Sealing is appropriate where the requesting party “establishes that the document, or portions thereof
`is privileged or protectable as a trade secret or otherwise entitled to protection under the law.” N.D.
`Cal. Civ. L.R. 79–5(a). A party must “narrowly tailor” its request to sealable material only. Id.
`
`B.
`
`SonicWall’s Administrative Motion to Seal Is Supported By Good Cause and Is
`Narrowly Tailored
`As noted in the table above, SonicWall seeks to seal select portions of its Responses to
`Finjan’s Motions in Limine Nos. 2, 4 and 5 (“Responses”) at the pages listed in the table above and
`Exhibits 36-51 and 54 to the Declaration of Jarrad Gunther. SonicWall’s Motions quote from or
`reference the one or more exhibits that SonicWall is filing under seal which were designated as
`“CONFIDENTIAL”, “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY” or “HIGHLY
`CONFIDENTIAL – ATTORNEY’S EYES ONLY – SOURCE CODE” pursuant to the terms of the
`Stipulated Protective Order in this case or the Stipulated Protective Order in the Cisco case (Finjan
`LLC v. Cisco Systems, Inc., Case No. 5:17-cv-00072 (N.D. Ca.)) (“the Cisco case”). See Declaration
`
`
`
`7
`SONICWALL INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
`CASE NO. 5:17-CV-04467-BLF-VKD
`
`

`

`Case 5:17-cv-04467-BLF Document 404 Filed 03/11/21 Page 9 of 11
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`of Nicole E. Grigg in Support of Administrative Motion to File Documents Under Seal (“Grigg
`Declaration”), ¶¶ 2-5. Pursuant to Civil Local Rule 79-5, SonicWall has publicly filed the relevant
`excerpts of information that are not confidential. Attached hereto are redacted and unredacted
`versions of SonicWall’s Motions and unredacted versions of the exhibits in support thereof that
`SonicWall seeks to seal.
`SonicWall seeks to seal Exhibits 37, 38, 39, 42, 43, and 44 to the Declaration of Jarrad
`Gunther because they reflect or contain information that SonicWall has designated as “Confidential”,
`“Highly Confidential – Attorneys’ Eyes Only”, or “Highly Confidential – Attorney’s Eyes Only –
`Source Code” pursuant to the Stipulated Protective Order. If filed publicly, this confidential
`information could be used to SonicWall’s disadvantage by competitors as it concerns the
`identification, organization, and or operation of SonicWall’s proprietary products as well as
`SonicWall’s confidential business information. See Grigg Declaration, ¶¶ 2-5.
`SonicWall is sealing Exhibits 36-38, 41, 45, 46-51, and 54 because they were designated by
`Finjan as “Confidential” or “Highly Confidential – Attorneys’ Eyes Only” or contain information
`designated by Finjan as “Confidential” or “Highly Confidential – Attorneys’ Eyes Only” pursuant to
`the Stipulated Protective Order in this case or in the Cisco case.
`SonicWall contends that public disclosure of this information would cause irreparable harm
`to these Parties. Id.; see also Andrx Pharms., LLC v. GlaxoSmithKline, 236 F.R.D. 583, 586 (S.D.
`Fla. 2006) (“Courts dress technical information with a heavy cloak of judicial protection because of
`the threat of serious economic injury to the disclosure of scientific information.”); Network
`Appliance, Inc. v. Sun Microsys. Inc., 2010 WL 841274, at *5 (N.D. Cal. Mar. 10, 2010) (granting
`application to seal “information regarding NetApp’s internal usability testing of its software”).
`SonicWall’s administrative motion is narrowly tailored and only seeks to seal the exhibits
`associated with SonicWall’s Motions that were either designated in their entirety by Plaintiff Finjan
`or Defendant SonicWall as “CONFIDENTIAL”, “HIGHLY CONFIDENTIAL – ATTORNEYS’
`EYES ONLY” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY – SOURCE CODE”
`or reflect information from which confidential and proprietary technical or financial information of
`SonicWall could be ascertained. See Kowalsky v. Hewlett-Packard Co., 2012 WL 892427, at *2
`
`8
`SONICWALL INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
`CASE NO. 5:17-CV-04467-BLF-VKD
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`Case 5:17-cv-04467-BLF Document 404 Filed 03/11/21 Page 10 of 11
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`(N.D. Cal. Mar. 14, 2012) (finding sealing appropriate where “[t]he proposed redactions contain[ed]
`. . . confidential product development information, the disclosure of which could harm [the
`defendant's] competitive advantage in the marketplace.”).
`III. CONCLUSION
`For these reasons, SonicWall respectfully requests that the Court grant its Administrative
`Motion to Seal.
`Dated: March 11, 2021
`
`DUANE MORRIS LLP
`
`
`
`/s/ Nicole E. Grigg
`Nicole E. Grigg
`D. Stuart Bartow
`Matthew C. Gaudet (admitted pro hac vice)
`Robin McGrath (admitted pro hac vice)
`David C. Dotson (admitted pro hac vice)
`Jennifer H. Forte (admitted pro hac vice)
`Joseph A. Powers (admitted pro hac vice)
`Jarrad M. Gunther (admitted pro hac vice)
`
`Attorneys for Defendant
`SONICWALL INC.
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`9
`SONICWALL INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
`CASE NO. 5:17-CV-04467-BLF-VKD
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`Case 5:17-cv-04467-BLF Document 404 Filed 03/11/21 Page 11 of 11
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`/s/ Nicole E. Grigg
` Nicole E. Grigg
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a true and correct copy of the above and foregoing
`document has been served on March 11, 2021, to all counsel of record who are deemed to have
`consented to electronic service via the Court’s CM/ECF system.
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`SONICWALL INC.’S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL
`CASE NO. 5:17-CV-04467-BLF-VKD
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