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Case 1:18-cv-01519-MN Document 170 Filed 07/17/20 Page 1 of 2 PageID #: 6550
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`FINJAN, INC., a Delaware Corporation,
`
`
`
`
`
`RAPID7, INC., a Delaware Corporation
`and RAPID7 LLC, a Delaware Limited
`Liability Company,
`
`
`
`
`
`
`v.
`
`
`
`
`
`
`
`Plaintiff,
`
`Defendants.
`
`
`
`
`
`
` C.A. No. 1:18-cv-01519-MN
`
` Jury Trial Demanded
`
`
`
`
`
`
`MOTION TO COMPEL PRODUCTION OF IBM DOCUMENTS
`
`Pursuant to Special Master Order #1 (D.I. 169 at ¶ 3) and the Order Appointing Special
`
`Master (D.I. 167 at ¶ 3a), Defendants Rapid7, Inc. and Rapid7 LLC (collectively, “Rapid7”)
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`hereby move the Court to Compel Plaintiff Finjan, Inc. (“Finjan”) to produce emails and related
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`documents that hit on Rapid7’s ESI search terms regarding the relationship and patent
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`acquisition and development agreement between Finjan’s wholly owned subsidiary, Finjan Blue,
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`Inc., and IBM (the “IBM Documents”). Alternatively, Rapid7 requests that Finjan stipulate not
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`to refer to its relationship with IBM at trial.
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`This motion relates to Rapid7’s previously-filed Letter Brief on this issue. D.I. 160.
`
`[SIGNATURE PAGE FOLLOWS.]
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`
`
`
`
`

`

`Case 1:18-cv-01519-MN Document 170 Filed 07/17/20 Page 2 of 2 PageID #: 6551
`
`DUANE MORRIS LLP
`
`
`
`/s/ Richard L. Renck -
`Richard L. Renck (I.D. No. 3893)
`222 Delaware Avenue, Suite 1600
`Wilmington, DE 19801
`Tel.: (302) 657-4900
`Fax: (302) 657-4901
`rlrenck@duanemorris.com
`
`Counsel for Defendants
`Rapid7, Inc. and Rapid7 LLC
`
`
`Dated: July 17, 2020
`
`OF COUNSEL:
`L. Norwood Jameson
`Matthew C. Gaudet
`David C. Dotson
`John R. Gibson
`Robin McGrath
`Jennifer H. Forte
`DUANE MORRIS LLP
`1075 Peachtree Street NE, Suite 2000
`Atlanta, GA 30309
`Tel.: (404) 253-6900
`Fax: (404) 253-6901
`wjameson@duanemorris.com
`mcgaudet@duanemorris.com
`dcdotson@duanemorris.com
`jrgibson@duanemorris.com
`rlmcgrath@duanemorris.com
`jhforte@duanemorris.com
`Jarrad M. Gunther
`DUANE MORRIS LLP
`30 South 17th St.
`Philadelphia, PA 19103-4196
`Tel.: (215) 979-1837
`Fax: (215) 689-4921
`jmgunther@duanemorris.com
`
`Jordana Garellek
`DUANE MORRIS LLP
`1540 Broadway
`New York, NY 10036-4086
`Tel.: (212) 471-1829
`Fax: (212) 214-0889
`jgarellek@duanemorris.com
`
`*admitted pro hac vice
`
`
`
`
`
`
`
`2
`
`

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