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`Juanita Brooks (SBN 75934) brooks@fr.com
`Roger A. Denning (SBN 228998) denning@fr.com
`Jason W. Wolff (SBN 215819) wolff@fr.com
`Michael A. Amon (SBN 226221) amon@fr.com
`FISH & RICHARDSON P.C.
`12860 El Camino Real, Suite 400
`San Diego, CA 92130
`Tel: (858) 678-5070 / Fax: (858) 678-5099
`
`Lawrence Jarvis (pro hac vice)
`FISH & RICHARDSON P.C.
`1180 Peachtree St., NE
`21st Floor
`Atlanta, GA 30309
`Tel: (404) 891-5005 / Fax: (404) 892-5002
`
`Attorneys for Plaintiff Finjan, Inc.
`
`
`IN THE UNITED STATES DISTRICT COURT
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`FINJAN, INC.,
`
` Plaintiffs,
`
`v.
`
`
`ESET, LLC and ESET SPOL. S.R.O.,
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`
`
`
`
` Defendants.
`
`
`
`
`SOUTHERN DISTRICT OF CALIFORNIA
`
`
`Case No. 17-cv-0183 CAB (BGS)
`
`DECLARATION OF JASON W.
`WOLFF IN SUPPORT OF FINJAN,
`INC.’S RESPONSE TO
`DEFENDANTS’ MOTION FOR
`ADDITIONAL DISCOVERY AND
`ISSUANCE OF LETTER OF
`REQUEST
`
`District Judge: Hon. Cathy Ann
`Bencivengo
`Magistrate Judge: Hon. Bernard G.
`Skomal
`
`
`
`
`DECLARATION OF WOLFF ISO RESPONSE TO MOTION
`Case No. 17-cv-0183 CAB (BGS)
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`Case 3:17-cv-00183-CAB-BGS Document 834-1 Filed 11/30/20 PageID.39989 Page 2 of 4
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`
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`I, Jason W. Wolff, declare as follows:
`
`1.
`
`I am a member of Fish & Richardson P.C., counsel of record in this
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`action for Plaintiff Finjan, Inc. (“Finjan”). I am a member of the Bar of the State of
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`California and of this Court. I have personal knowledge of the matters stated in this
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`declaration and would testify truthfully to them if called upon to do so.
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`2.
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`I make this declaration in support of Finjan’s Response to Defendants’
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`Motion for Additional Discovery and Issuance of Letter of Request:
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`3.
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`Attached hereto as Exhibit A is a true and correct copy of excerpts from
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`the transcript of the videotaped deposition Mr. Shlomo Touboul taken July 23, 2018
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`in Tel Aviv, Israel.
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`4.
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`Attached hereto as Exhibit B is a true and correct copy of ESET, LLC
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`and ESET SPOL. S.R.O.’s Notice of Subpoena and Subpoenas to Shlomo Touboul
`
`dated March 28, 2018.
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`5.
`
`Attached hereto as Exhibit C is a true and correct copy of email
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`correspondence from James Hannah (counsel for Finjan, Inc.) and Scott Penner
`
`(counsel for ESET, LLC, ESET SPOL. S.R.O.) dated July 5, 2019.
`
`I declare under penalty of perjury under the laws of the United States that the
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`forgoing is true and correct.
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`Executed at San Diego, California on November 30, 2020.
`
` /s/ Jason W. Wolff
`Jason W. Wolff
`
`
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`DECLARATION OF WOLFF ISO RESPONSE TO MOTION
`Case No. 17-cv-0183 CAB (BGS)
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`
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`Case 3:17-cv-00183-CAB-BGS Document 834-1 Filed 11/30/20 PageID.39990 Page 3 of 4
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`
`
`Exhibit No.
`A
`
`B
`
`C
`
`EXHIBITS – TABLE OF CONTENTS
`
`Description
`Excerpts from the transcript of the videotaped
`deposition Mr. Shlomo Touboul taken July 23,
`2018
`ESET, LLC and ESET SPOL. S.R.O.’s Notice
`of Subpoena of Shlomo Touboul dated
`March 28, 2018
`Email correspondence from James Hannah
`dated July 5, 2019
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`Page Nos.
`1 - 43
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`44 - 65
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`66 - 69
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`DECLARATION OF WOLFF ISO RESPONSE TO MOTION
`Case No. 17-cv-0183 CAB (BGS)
`
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`Case 3:17-cv-00183-CAB-BGS Document 834-1 Filed 11/30/20 PageID.39991 Page 4 of 4
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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
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`foregoing document has been served on November 30, 2020, to all counsel of record
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`who are deemed to have consented to electronic service via the Court’s CM/ECF
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`system per Civil Local Rule 5.4. Any other counsel of record will be served by
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`electronic mail, facsimile and/or overnight delivery.
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`
`
`/s/ Jason W. Wolff
`Jason W. Wolff
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`DECLARATION OF WOLFF ISO RESPONSE TO MOTION
`Case No. 17-cv-0183 CAB (BGS)
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`
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