Case 3:17-cv-00183-CAB-BGS Document 849-15 Filed 01/06/21 PageID.40477 Page 1 of
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`EXHIBIT A
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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
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`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
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`Attorneys for Plaintiff Finjan, Inc.
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`IN THE UNITED STATES DISTRICT COURT
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`SOUTHERN DISTRICT OF CALIFORNIA
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`FINJAN, INC.,
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`Case No. 17-cv-0183 CAB (BGS)
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` Plaintiff,
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`v.
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`ESET, LLC and ESET SPOL. S.R.O.,
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` Defendants.
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`PLAINTIFF FINJAN, INC.’S
`OBJECTIONS AND RESPONSES TO
`DEFENDANTS ESET, LLC’S AND
`ESET SPOL. S.R.O.’S SEVENTH SET
`OF REQUEST FOR PRODUCTION
`OF DOCUMENTS AND THINGS
`(NOS 222-236)
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`District Judge: Hon. Cathy Ann
`Bencivengo
`Magistrate Judge: Hon. Bernard G.
`Skomal
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`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`

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`Pursuant to Fed. R. Civ. P. 34, Plaintiff Finjan LLC (formerly Finjan, Inc.)
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`(“Plaintiff” or “Finjan”) hereby provides these objections and responses to
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`Defendants ESET, LLC’s and ESET SPOL. S.R.O. (together, “ESET” or
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`“Defendants”) Seventh Set of Requests for Production (“Requests”). Finjan makes
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`these objections and responses herein (collectively, “Responses”) based solely on its
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`current knowledge, understanding, and belief as to the facts and information
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`reasonably available to it as of the date of the Responses.
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`Finjan’s response that it will produce documents means that Finjan will
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`produce relevant, responsive, and non-privileged documents located after a
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`reasonable search of documents in its custody and control, to the extent such
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`documents exist. Finjan’s response that it will produce documents does not mean that
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`any responsive documents actually exist; only that Finjan has made, and will continue
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`to make, a reasonable, good faith effort to locate responsive documents.
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`Additional discovery and investigation may lead to additions to, changes in, or
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`modifications of these Responses. The Responses, therefore, are given without
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`prejudice to Finjan’s right to supplement these Responses pursuant to Fed. R. Civ. P.
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`26(e), or to provide subsequently discovered information and to introduce such
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`subsequently discovered information at the time of any trial or proceeding in this
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`action.
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`GENERAL OBJECTIONS
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`1.
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`Finjan hereby incorporates by reference each and every general objection
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`set forth below into each and every specific Response. From time to time, a specific
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`Response may repeat a general objection for emphasis or for some other reason. The
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`failure to include a general objection in a specific Response shall not be interpreted
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`as a waiver of that general objection to that Response.
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`2.
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`Finjan objects to each and every Request, Definition, and Instruction to
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`the extent that they are vague, ambiguous, unintelligible, or compound.
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`3.
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`Finjan objects to each and every Request, Definition, and Instruction to
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`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`

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`the extent that they are overly broad, unduly burdensome, seek information not
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`relevant to the claim or defense of any party, and/or are not proportional to the needs
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`of this case.
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`4.
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`Finjan objects to each and every Request, Definition and Instruction to
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`the extent they are overly broad because they are not properly limited in time.
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`5.
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`Finjan objects to each and every Request, Definition, and Instruction to
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`the extent that they are unduly burdensome and oppressive, to the extent they subject
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`Finjan to unreasonable and undue effort or expense.
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`6.
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`Finjan objects to each and every Request, Definition, and Instruction to
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`the extent that they seek information beyond Finjan’s actual possession, knowledge,
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`custody, or control.
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`7.
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`Finjan objects to each and every Request, Definition, and Instruction to
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`the extent they are unreasonably cumulative or duplicative.
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`8.
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`Finjan objects to each and every Request, Definition, and Instruction to
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`the extent they seek information that is obtainable from some other source that is more
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`convenient, less burdensome, or less expensive.
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`9.
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`Finjan objects to each and every Request, Definition, and Instruction to
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`the extent that they seek information within Defendants’ possession, knowledge
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`custody or control.
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`10. Finjan objects to each and every Request, Definition, and Instruction to
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`the extent they seek information in the public domain, information equally available
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`to Defendants from another source, and/or information that can be obtained more
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`efficiently by Defendants through other means of discovery. Defendants can ascertain
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`such information from its own records or from other sources at least as readily as
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`Finjan.
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`11. Finjan objects to each and every Request, Definition, and Instruction to
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`the extent that they seek confidential, business, financial, proprietary or sensitive
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`information, or trade secrets of third parties, which may be subject to pre-existing
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`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`protective order(s) and/or confidentiality agreements or in which any third party has
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`an expectation of privacy. Such information shall not be provided absent an express
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`order to the contrary from a court of competent jurisdiction, or an authorization from
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`the third party having the interest in the information’s confidentiality.
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`12. Finjan objects to each and every Request, Definition, and Instruction to
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`the extent they seek information protected by the attorney-client privilege, the work
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`product doctrine, or any other applicable law, privilege, doctrine or immunity. Finjan
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`will not disclose any information so protected, and the inadvertent disclosure or
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`identification of any such information is not intended as, and will not constitute, a
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`waiver of such privilege, doctrine, or immunity.
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`13. Finjan objects to each and every Request, Definition, and Instruction to
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`the extent they call for a legal conclusion. Finjan’s responses shall not be construed
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`as providing legal conclusions concerning the meaning or application of any terms
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`used in Defendants’ Requests.
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`14. Finjan objects to each and every Request, Definition, and Instruction to
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`the extent that they are premature and/or cumulative, as they seek documents that are
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`set to be disclosed on scheduled dates directed by the Court or the Southern District
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`of California Local Rules, including the Local Patent Rules.
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`15. Finjan objects to each and every Request, Definition, and Instruction as
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`premature to the extent they seek information that will be the subject of expert
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`opinion, reports, and testimony.
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`16. Finjan objects to each and every Request, Definition, and Instruction to
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`the extent that they impose obligations inconsistent with the ESI order, protective
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`order or any other stipulation or order entered in this case.
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`17. Finjan objects to each and every Request, Definition, and Instruction to
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`the extent they assume or mischaracterize any facts. Finjan’s responses shall not be
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`construed as agreeing to any facts or characterizations contained in Defendants’
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`Requests.
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`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`18. Finjan objects to each and every Request, Definition, and Instruction to
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`the extent that they purport to impose any requirement or discovery obligation greater
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`than or different from those imposed by the Federal Rules of Civil Procedure, the
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`Local Rules of this Court, or orders of the Court governing these proceedings.
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`19. Finjan objects to each and every Request, Definition, and Instruction to
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`the extent that they are unduly burdensome and oppressive on the grounds that they
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`purport to require Finjan to search its facilities and inquire of its employees other than
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`those facilities and employees that would reasonably be expected to have responsive
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`information. Finjan’s Responses and productions are based upon: (1) a search of
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`facilities and files that could reasonably be expected to contain responsive information
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`and (2) inquiries of Finjan’s employees and/or representatives who could reasonably
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`be expected to possess responsive information and/or know where responsive
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`information might be maintained.
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`20. Finjan’s written responses and production of documents are not intended
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`to waive, and do not constitute waiver of, any objection that Finjan may have to the
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`admissibility, authenticity, competency, relevance, or materiality of any documents
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`produced or referred to in response to a Request. For any and all written responses
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`and production of documents, Finjan reserves all objections or other questions
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`regarding the admissibility, authenticity, competency, relevance, or materiality of any
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`documents produced or referred to in response to a Request, as evidence in this
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`Litigation or any other proceeding, action, or trial.
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`21. Finjan’s written responses and production of documents, if any, are
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`based upon information and writings available to and located by its attorneys as of
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`service of these Responses. Finjan has not completed its investigation of the facts
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`relating to this case, has not completed discovery in this action, and has not completed
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`preparation for trial. All the information supplied and documents and things produced
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`are based only on such information and documents that are reasonably available and
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`specifically known to Finjan and its attorneys as of the date of service of these
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`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`

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`Responses. Therefore, Finjan’s written responses and production of documents are
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`without prejudice to its right to supplement and/or amend its written objections and
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`responses, and production of documents, and to present at trial or other proceeding
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`evidence discovered hereafter.
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`OBJECTIONS TO DEFINITIONS AND INSTRUCTIONS
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`1.
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`In addition to the objections set forth below, Finjan hereby specifically
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`incorporates each and every general objection set forth above in its objections to
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`Defendants’ Definitions and Instructions.
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`2.
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`Finjan objects to Defendants’ Definitions of the terms “Plaintiff,”
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`“Finjan Inc.,” “Finjan,” “You,” and “Your,” and to each Request that incorporates
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`any of these terms, to the extent they are overly broad and unduly burdensome and
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`seek information that is not relevant and/or not proportional to the needs of the case.
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`Finjan objects to these Definitions to the extent they are overbroad and seek
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`information that exceeds the requirements of the Federal Rules of Civil Procedure.
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`Finjan objects to these Definitions, and to each Request that incorporates any of these
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`terms, to the extent they require beyond a reasonable search within Finjan’s
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`possession, custody and control. Finjan further objects to these Definitions, and to
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`each Request that incorporates any of these terms, to the extent that they call for a
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`legal conclusion or seek documents or information protected from discovery by the
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`attorney-client privilege, the work product doctrine, or any other applicable law,
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`privilege, doctrine or immunity. Finjan further objects to these Definitions, and to
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`each Request that incorporates any of these terms, to the extent they include entities
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`and persons over whom Finjan has no control. Finjan will limit the scope of this term
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`to Finjan, Inc.1
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`3.
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`Finjan objects to Defendants’ Definitions of the terms “Finjan Holdings”
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`and “Finjan Mobile” and to each Request that incorporates any of these terms, to the
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` Finjan, Inc. was converted to a limited liability company, and thus, Finjan interprets Finjan, Inc. to include the
`converted entity, Finjan LLC.
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`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`extent they are overly broad and unduly burdensome and seek information that is not
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`relevant and/or not proportional to the needs of the case. Finjan objects to these
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`Definitions, and to each Request that incorporates any of these terms, to the extent
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`they are overbroad and seek information that exceeds the requirements of the Federal
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`Rules of Civil Procedure. Finjan objects to these Definitions, and to each Request that
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`incorporates any of these terms, to the extent they require beyond a reasonable search
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`within Finjan’s possession, custody and control. Finjan further objects to these
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`Definitions, and to each Request that incorporates any of these terms, to the extent
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`that they call for a legal conclusion or seek documents or information protected from
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`discovery by the attorney-client privilege, the work product doctrine, or any other
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`applicable law, privilege, doctrine or immunity. Finjan further objects to these
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`Definitions, and to each Request that incorporates any of these terms, to the extent
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`they include entities and persons over whom Finjan has no control.
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`4.
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`Finjan objects to Defendants’ Definitions of the terms “Related
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`Application(s)” and “Related Patent(s)” and to each Request that incorporates this
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`term, to the extent it is overbroad, unduly burdensome, and seek information that is
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`not relevant and/or not proportional to the needs of the case. Finjan objects to these
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`Definitions, and to each Request that incorporates any of these terms, to the extent it
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`is overbroad and seeks information that exceeds the scope of relevance to the Patents-
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`in-Suit. Finjan objects to these Definitions, and to each Request that incorporates any
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`of these terms, to the extent it requires beyond a reasonable search within Finjan’s
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`possession, custody and control. Finjan will interpret “Related Patent(s)” as used
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`herein as patent(s) that claim priority to the Patents-in-Suit or patents in the priority
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`chain of the Patents-in-Suit. Finjan will interpret “Related Application(s)” as used
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`herein as applications resulting in patent(s) that claim priority to the Patents-in-Suit
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`or patents in the priority chain of the Patents-in-Suit and as further defined in the
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`August 25, 2017 email from C. Martinez to J. Grey, et. al.
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`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`

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`5.
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`Finjan objects to Defendants’ Definition of “Asserted Claim(s),” and to
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`each Request that incorporates this term, to the extent it includes claims beyond those
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`that Finjan is actually asserting in this action.
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`6.
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`Finjan objects to Defendants’ Definitions of “Accused Instrumentality,”
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`“Accused Instrumentalities,” “Accused Product,” or “Accused Products,” and to each
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`Request that incorporates any of these terms, to the extent they include
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`instrumentalities beyond those that Finjan accuses of infringement in this action.
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`7.
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`Finjan objects to Defendants’ Definition of “Finjan, Inc. Product,” and
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`to each Request that incorporates this term, to the extent it is overly broad and unduly
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`burdensome and seeks information that is not relevant and/or not proportional to the
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`needs of the case. Finjan objects to this Definition, and to each Request that
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`incorporates this term, to the extent it is overbroad and seeks information that exceeds
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`the requirements of the Federal Rules of Civil Procedure. Finjan further objects to this
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`Definition, and to each Request that incorporates this term, to the extent that it calls
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`for a legal conclusion or seek documents or information protected from discovery by
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`the attorney-client privilege, the work product doctrine, or any other applicable law,
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`privilege, doctrine or immunity.
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`8.
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`Finjan objects to Defendants’ Definition of “Finjan Product,” and to each
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`Request that incorporates any of these terms, to the extent it is overly broad and
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`unduly burdensome and seeks information that is not relevant and/or not proportional
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`to the needs of the case. Finjan objects to this Definition, and to each Request that
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`incorporates this term, to the extent it is overbroad and seeks information that exceeds
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`the requirements of the Federal Rules of Civil Procedure. Finjan objects to this
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`Definition, and to each Request that incorporates this term, to the extent it requires
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`beyond a reasonable search within Finjan’s possession, custody and control. Finjan
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`further objects to this Definition, and to each Request that incorporates this term, to
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`the extent that it calls for a legal conclusion or seeks documents or information
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`protected from discovery by the attorney-client privilege, the work product doctrine,
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`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`

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`or any other applicable law, privilege, doctrine or immunity. Finjan further objects to
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`this Definition, and to each Request that incorporates this term, to the extent it
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`includes entities and persons over whom Finjan has no control.
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`9.
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`Finjan
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`objects
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`to Defendants’ Definitions
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`of
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`the
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`terms
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`“Communication(s),” “Document(s),” and “Thing(s),” and to each Request that
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`incorporates any of these terms, to the extent they are overbroad and seek to impose
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`obligations greater or different than those imposed by the Federal Rules of Civil
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`Procedure and/or the Federal Rules of Evidence. Finjan further objects to these
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`Definitions, and to each Request that incorporates any of these terms, to the extent
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`that they call for the production of information inconsistent with the ESI order or
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`protective order entered in this action. Finjan further objects to these Definitions, and
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`to each Request that incorporates any of these terms, to the extent they use terms that
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`are vague, ambiguous and unintelligible. Finjan further objects to these Definitions,
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`and to each Request that incorporates any of these terms, to the extent they are
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`overbroad, unduly burdensome, and seek information that is not relevant and/or not
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`proportional to the needs of the case. Finjan further objects to these Definitions, and
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`to each Request that incorporates any of these terms, to the extent they require more
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`than a reasonable search within Finjan’s possession, custody and control.
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`10. Finjan objects to “Person(s),” “People,” “Entity,” or “Entities” and to
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`each Request that incorporates any of these terms, to the extent they are overly broad
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`and unduly burdensome and seek information that is not relevant and/or not
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`proportional to the needs of the case. Finjan objects to these Definitions, and to each
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`Request that incorporates any of these terms, to the extent they are overbroad and seek
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`information that exceeds the requirements of the Federal Rules of Civil Procedure.
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`Finjan further objects to these Definitions, and to each Request that incorporates any
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`of these terms, to the extent that they call for a legal conclusion.
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`11. Finjan objects to “Prior Art” and to each Request that incorporates this
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`term to the extent it is vague, ambiguous, unintelligible and/or calls for a legal
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`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`conclusion, and to the extent that it is broader than the meaning of prior art pursuant
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`to 35 U.S.C. §101 et seq. and related case law.
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`12. Finjan objects to Defendants’ Definitions of the terms “relate to,”
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`“relating to,” “refer to,” “referring to,” “concern,” and “concerning,” and to each
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`Request that incorporates these terms, to the extent it is overbroad, unduly
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`burdensome, and seeks information that is not relevant and/or not proportional to the
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`needs of the case. Finjan objects to these Definitions, and to each Request that
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`incorporates any of these terms, to the extent they are overbroad and seek information
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`that exceeds the requirements of the Federal Rules of Civil Procedure.
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`13. Finjan objects to Defendants’ Definition of the terms “any,” “each,” “all”
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`and “each and every” and to each Request that incorporates these terms, to the extent
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`they are overly broad, unduly burdensome, and seek information that is not relevant
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`and/or not proportional to the needs of the case.
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`14. Finjan objects to each of Defendants’ Definition of “Identify” and
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`“Identifying” and Instruction Nos. 1–15 to the extent that they seek to impose any
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`requirement or obligation greater or different than those imposed by the Federal Rules
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`of Civil Procedure, the Local Rules of this Court, and/or orders of the Court governing
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`these proceedings. Finjan further objects to each of Defendants’ Definition of
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`“Identify” and “Identifying” and Instruction Nos. 1–15 to the extent that they are
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`overbroad, unduly burdensome, and seek information that is not relevant and/or not
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`proportional to the needs of the case. Finjan objects to each of Defendants’ Definition
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`of “Identify” and “Identifying” and Instruction Nos. 1–15 to the extent that they are
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`vague, ambiguous and/or unintelligible. Finjan further objects to each of Defendants’
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`Definition of “Identify” and “Identifying” and Instruction Nos. 1–15 to the extent that
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`they impose obligations inconsistent with the ESI order, protective order or any other
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`stipulation or order entered in this case. Finjan further objects to Defendants’
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`Definition of “Identify” and “Identifying” and Instruction Nos. 1–15 to the extent that
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`they seek information protected by the attorney-client privilege, the work product
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`9
`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`

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`doctrine, or any other applicable law, privilege, doctrine or immunity.
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`RESPONSES TO REQUESTS FOR PRODUCTION
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`OF DOCUMENTS AND THINGS
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`Subject to and without waiving any of the general objections and objections to
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`definitions and instructions set forth above, each of which is specifically incorporated
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`into the specific Responses contained below, Finjan responds to Defendants’
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`Requests as follows:
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`REQUEST FOR PRODUCTION NO. 222:
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`All Communications between Finjan, Inc. or Finjan Holdings, Inc. and Fortress
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`Investment Group LLC regarding any valuation of the Patents-in-Suit or the Finjan
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`patent portfolio as a whole.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 222:
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`Finjan objects to this Request as seeking information protected from discovery
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`by the attorney-client privilege, the work product immunity, the common-interest
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`privilege, and/or any other applicable privilege or immunity. Finjan further objects to
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`this Request’s use of the term “valuation” as vague and ambiguous. Finjan further
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`incorporates its general objections to the terms “Finjan, Inc.” and “Finjan Holdings,
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`Inc.” Finjan further objects to this Request to the extent it seeks documents and/or
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`information not within Finjan, Inc.’s possession, custody, or control. Finjan objects
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`to this Request as unduly burdensome because it seeks “All Communications.” Finjan
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`further objects to this request as seeking information not relevant to any claims or
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`defenses in this litigation, and for which the burden of production substantially
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`outweighs the needs for that information to this case. Finjan objects to this request as
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`seeking information unrelated to the ’305 patent, and therefore beyond the discovery
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`authorized by the Court for this stage of the litigation.
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`Subject to the foregoing general and specific objections, and to the extent that
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`Finjan understands this Request, Finjan responds that it will not produce documents
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`in response to this Request.
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`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`REQUEST FOR PRODUCHON NO. 223:
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`All Documents provided to Fortress Investment Group LLC prior to the
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`acquisition of Finjan referring or relating to any of Patents-in-Suit.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 223:
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`Finjan objects to this request as seeking information protected from discovery
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`by the attorney-client privilege, the work product immunity, the common-interest
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`privilege, and/or any other applicable privilege or immunity. Finjan objects to this
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`Request as seeking information not relevant to any claims or defenses in this
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`litigation. Finjan objects to this request as overbroad and unduly burdensome because
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`it seeks production of “All Documents.” Finjan further objects to this request because
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`the burden of production substantially outweighs any need related to the issues in this
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`case. Finjan objects to this request as seeking information unrelated to the ’305 patent,
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`and therefore beyond the discovery authorized by the Court for this stage of the
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`litigation. Finjan further objects to this Request to the extent it seeks documents and/or
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`information not within Finjan, Inc.’s possession, custody, or control. Finjan objects
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`to the Request’s use of the phrase “prior to the acquisition” as vague and ambiguous.
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`Finjan objects to this request as seeking documents that are publicly available and
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`thus, equally available to ESET as to Finjan.
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`Subject to the foregoing general and specific objections, and to the extent that
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`Finjan understands this Request, Finjan responds that it will not produce documents
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`in response to this Request.
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`REQUEST FOR PRODUCTION NO. 224:
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`All Documents provided to Fortress Investment Group LLC prior to the
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`acquisition of Finjan referring or relating to ESET.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 224:
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`Finjan objects to this request as seeking information protected from discovery
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`by the attorney-client privilege, the work product immunity, the common-interest
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`privilege, and/or any other applicable privilege or immunity. Finjan objects to this
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`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`

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`Case 3:17-cv-00183-CAB-BGS Document 849-15 Filed 01/06/21 PageID.40490 Page 14 of
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`request as overbroad and unduly burdensome because it seeks production of “All
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`Documents.” Finjan further objects to this request as seeking information not relevant
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`to any claims or defenses in this litigation, and for which the burden of production
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`substantially outweighs the needs for that information to this case. Finjan objects to
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`this request as seeking information unrelated to the ’305 patent, and therefore beyond
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`the discovery authorized by the Court for this stage of the litigation. Finjan further
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`objects to this Request to the extent it seeks documents and/or information not within
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`Finjan, Inc.’s possession, custody, or control. Finjan objects to the Request’s use of
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`the phrase “prior to the acquisition” as vague and ambiguous.
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`Subject to the foregoing general and specific objections, and to the extent that
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`Finjan understands this Request, Finjan responds that it will not produce documents
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`in response to this Request.
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`REQUEST FOR PRODUCTION NO. 225:
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`All Documents provided to Fortress Investment Group LLC prior to the
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`acquisition of Finjan referring or relating to substituting Kramer Levin as counsel of
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`record in any Finjan Litigation, including this litigation.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 225:
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`Finjan objects to this request as seeking information protected from discovery
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`by the attorney-client privilege, the work product immunity, the common-interest
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`privilege, and/or any other applicable privilege or immunity. Finjan objects to this
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`Request as seeking information not relevant to any claims or defenses in this
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`litigation. Finjan objects to this request as overbroad and unduly burdensome because
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`it seeks production of “All Documents.” Finjan further objects to this request because
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`the burden of production substantially outweighs any need related to the issues in this
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`case. Finjan objects to this request as seeking information unrelated to the ’305 patent,
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`and therefore beyond the discovery authorized by the Court for this stage of the
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`litigation. Finjan further objects to this Request to the extent it seeks documents and/or
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`information not within Finjan, Inc.’s possession, custody, or control. Finjan objects
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`FINJAN’S RESPONSES TO RFPS SET 7
`Case No. 17-cv-0183 CAB (BGS)
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`

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`Case 3:17-cv-00183-CAB-BGS Document 849-15 Filed 01/06/21 PageID.40491 Page 15 of
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`to the Request’s use of the phrase “prior to the acquisition” as vague and ambiguous.
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`Subject to the foregoing general and specific objections, and to the extent that
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`Finjan understands this Request, Finjan responds that it will not produce documents
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`in response to this Request.
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`REQUEST FOR PRODUCTION NO. 226:
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`All Communications between Finjan, Inc. or Finjan Holdings, Inc. and Fortress
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`Investment Group LLC regarding any valuation assigned to the Patents-in-Suit.
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`RESPONSE TO REQUEST FOR PRODUCTION NO. 226:
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`Finjan objects to this Request as duplicative of Request No. 222 and
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`incorporates its objections to that Request herein in its entirety. Finjan further objects
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`that this request is seeking information protected from discovery by the attorney-client
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`privilege, the work product immunity, the common-interest privilege, and/or any
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`other applicable privilege or immunity. Finjan further objects to this Request’s use of
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`the phrase “valuation assigned to the Patents-in-Suit” as vague and ambiguous. Finjan
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`further incorporates its general objections to the term “Finjan Holdings, Inc.” Finjan
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`further objects to this Request as seeking documents and/or information not within
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`Finjan, Inc.’s possession,