`
`
`
`
`
`PAUL ANDRE (SBN 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (SBN 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (SBN 237978)
`jhannah@kramerlevin.com
`KRAMER LEVIN NAFTALIS
`& FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`
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`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF CALIFORNIA
`SAN DIEGO DIVISION
`FINJAN, INC., a Delaware Corporation,
`Case No. 3:17-cv-00183-CAB-BGS
`
`
`PLAINTIFF FINJAN, INC.’S NOTICE
`OF MOTION AND MOTION IN
`LIMINE NO. 6 TO PRECLUDE
`DEFENDANTS’ EXPERTS FROM
`RELYING ON REDACTED
`REPORTS FROM ANOTHER CASE
`
`Date: February 21, 2020
`Judge: Hon. Cathy Ann Bencivengo
`
`PER CHAMBERS RULES, NO ORAL
`ARGUMENT UNLESS ORDERED BY
`THE COURT
`
`
`Plaintiff,
`
`v.
`
`
`
`
`ESET, LLC, a California Limited
`Liability Corporation, and ESET SPOL.
`S.R.O., a Slovak Republic Corporation,
`
`
`Defendants.
`ESET, LLC, a California Limited
`Liability Corporation, and ESET SPOL.
`S.R.O., a Slovak Republic Corporation,
`
`
`Counterclaim-Plaintiffs,
`
`v.
`
`
`
`FINJAN, INC., a Delaware Corporation,
`
`
`
`Counterclaim-Defendant.
`
`FINJAN’S NOTICE OF MOTION AND
`MOTION IN LIMINE NO. 6
`
`CASE NO. 3:17-cv-00183-CAB-BGS
`
`
`
`Case 3:17-cv-00183-CAB-BGS Document 752 Filed 02/07/20 PageID.37074 Page 2 of 2
`
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`
`NOTICE OF MOTION AND MOTION IN LIMINE NO. 6
`TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
`PLEASE TAKE NOTICE that on February 21, 2020, or as soon thereafter as this
`matter may be heard by the Honorable Cathy Ann Bencivengo in Courtroom 4C of the
`above-entitled Court, located at 221 West Broadway, Suite 4165, San Diego,
`California, 92101, Plaintiff-Counterclaim-Defendant Finjan, Inc. will and hereby does
`move the Court for an order precluding Defendants-Counterclaim-Plaintiffs Eset, LLC
`and Eset spol. s.r.o. and their experts from relying on redacted invalidity reports from a
`different case addressing different patents.
`This motion is based on this Notice of Motion, the Memorandum of Points and
`Authorities, the Declaration of Kristopher Kastens, the pleadings and papers on file, all
`other arguments submitted in connection with this matter, and all matters of which the
`Court may take judicial notice.
`
`
`
`
`DATED: February 7, 2020
`
`Respectfully submitted,
`
`
`
`
`
`By: s/ Lisa Kobialka
`Paul Andre (State Bar. No. 196585)
`Lisa Kobialka (State Bar No. 191404)
`James Hannah (State Bar No. 237978)
`KRAMER LEVIN NAFTALIS &
`FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`pandre@kramerlevin.com
`lkobialka@kramerlevin.com
`jhannah@kramerlevin.com
`
`Attorneys for Plaintiff
`Finjan, Inc.
`
`FINJAN’S NOTICE OF MOTION AND
`MOTION IN LIMINE NO. 6
`
`1
`
`CASE NO. 3:17-cv-00183-CAB-BGS
`
`
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