throbber
Case 1:18-cv-01519-MN Document 183 Filed 09/03/20 Page 1 of 2 PageID #: 6588
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`FINJAN LLC., a Delaware Limited Liability
`Company,
`
`
`
`
`
`RAPID7, INC., a Delaware Corporation
`and RAPID7 LLC, a Delaware Limited
`Liability Company,
`
`
`
`
`Plaintiff,
`
`Defendants.
`
`
`
`
`
`
`v.
`
`
`
`
`
`
`
`
`
`
`
`
` C.A. No. 1:18-cv-01519-MN
`
` Jury Trial Demanded
`
`
`
`MOTION TO STRIKE PORTIONS OF EXPERT REPORT OF DR. MITZENMACHER
`
`Pursuant to Special Master Order #3 (D.I. 178 at ¶ 3) and the Order Appointing Special
`
`Master (D.I. 167 at ¶ 3a), Defendants Rapid7, Inc. and Rapid7 LLC (collectively, “Rapid7”)
`
`hereby move the Court to Strike Portions of Plaintiff Finjan LLC’s (“Finjan”) Expert Report of
`
`Michael Mitzenmacher, PH.D. Regarding Infringement by Rapid7 of U.S. Patent Nos.
`
`8,141,154; 7,757,289; and 8,225,408 (“the Mitzenmacher Report”). The portions of the
`
`Mitzenmacher Report Rapid7 moves to strike include a direct infringement theory and multiple
`
`Doctrine of Equivalents infringement theories that were not disclosed in Finjan’s Final
`
`Infringement Contentions. A Proposed Order is attached hereto.
`
`Pursuant to Special Master Order #3, Rapid7 will serve its opening letter brief on this
`
`issue and email it to the Special Master. D.I. 178 at ¶2(a).
`
`[SIGNATURE PAGE FOLLOWS.]
`
`
`
`
`
`

`

`Case 1:18-cv-01519-MN Document 183 Filed 09/03/20 Page 2 of 2 PageID #: 6589
`
`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: September 3, 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
`Joseph A. Powers
`DUANE MORRIS LLP
`30 South 17th St.
`Philadelphia, PA 19103-4196
`Tel.: (215) 979-1837
`Fax: (215) 689-4921
`jmgunther@duanemorris.com
`japowers@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
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket