`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`FINJAN LLC, a Delaware Limited Liability
`Company,
`
`Plaintiff,
`
`v.
`
`RAPID7, INC., a Delaware Corporation and
`RAPID7 LLC, a Delaware Limited Liability
`Company,
`
`Defendants.
`
`C.A. No. 18-1519-MN
`
`
`
`
`
`FINJAN LLC’S MOTION TO PRECLUDE TRIAL TESTIMONY OF RAPID7’S
`DAMAGES EXPERT STEPHEN BECKER
`
`Plaintiff Finjan LLC respectfully moves, pursuant to Federal Rules of Evidence 702 and
`
`
`
`
`Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (1993), to preclude the Trial Testimony of
`
`Rapid7’s damages expert, Dr. Stephen Becker. The grounds for this Motion are set forth in the
`
`Opening Brief in support thereof, filed contemporaneously herewith.
`
`Dated: October 23, 2020
`
`
`
`
`
`FISH & RICHARDSON P.C.
`
`/s/ Susan E. Morrison
`By:
`Susan E. Morrison (#4690)
`222 Delaware Avenue, 17th Floor
`Wilmington, DE 19801
`(302) 652-5070
`morrison@fr.com
`
`
`
`
`
`
`
`Case 1:18-cv-01519-MN Document 201 Filed 10/23/20 Page 2 of 3 PageID #: 6913
`
`Proshanto Mukherji
`Fish & Richardson P.C.
`One Marina Park Drive
`Boston, MA 02210
`(617) 542-5070
`mukherji@fr.com
`
`Lawrence Jarvis
`Fish & Richardson P.C.
`1180 Peachtree Street NE, 21st Floor
`Atlanta, GA 30309
`(404) 892-5005
`jarvis@fr.com
`
`
`
`
`
`
`
`
`
`Juanita R. Brooks
`Roger Denning
`
`Jason W. Wolff
`Fish & Richardson P.C.
`12860 El Camino Real, Suite 400
`San Diego, CA 92130
`(858) 678-5070
`brooks@fr.com
`denning@fr.com
`wolff@fr.com
`
`ATTORNEYS FOR
`PLAINTIFF FINJAN LLC
`
`
`
`Case 1:18-cv-01519-MN Document 201 Filed 10/23/20 Page 3 of 3 PageID #: 6914
`
`CERTIFICATION PURSUANT TO LOCAL RULE 7.1.1
`
`I hereby certify, pursuant to D. Del. LR 7.1.1, that reasonable efforts have been made to
`reach agreement with opposing counsel on the matters set forth in the foregoing Motion, and that
`no agreement could be reached.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` /s/ Susan E. Morrison
`
`Susan E. Morrison (#4690)
`
`
`
`
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