`
`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. 1:18-cv-01519-MN
`
`Jury Trial Demanded
`
`REDACTED VERSION
`Filed on November 13, 2020
`
`DECLARATION OF JOHN R. GIBSON IN SUPPORT OF DEFENDANTS
` RAPID7, INC. AND RAPID7 LLC’S RESPONSE IN OPPOSITION TO FINJAN LLC’S
`MOTION TO PRECLUDE TRIAL TESTIMONY OF RAPID7’S DAMAGES EXPERT
`STEPHEN BECKER
`
`I, John R. Gibson, declare and state the following:
`
`1.
`
`My name is John R. Gibson. I provide this declaration in response to Finjan LLC’s
`
`Motion to Preclude Trial Testimony of Rapid7’s Damages Expert Stephen Becker. I have personal
`
`knowledge of the following based upon my representation of Rapid7 in this matter and, if called
`
`as a witness, I could and would testify competently thereto.
`
`2.
`
`I am a partner at Duane Morris LLP, which represents Rapid7, Inc. and Rapid7
`
`LLC in the above-captioned matter. I am a member of good standing of the State Bar of Georgia
`
`and the Commonwealth of Virginia, and am admitted pro hac vice in the District of Delaware for
`
`this matter.
`
`3.
`
`Attached hereto as Exhibit 1 are excerpts from Finjan’s Response to Interrogatory
`
`No. 14 (served Jan. 21, 2020).
`
`
`
`Case 1:18-cv-01519-MN Document 228 Filed 11/13/20 Page 2 of 2 PageID #: 8400
`
`4.
`
`Attached hereto as Exhibit 2 are excerpts from the Expert Report of Russell L. Parr,
`
`CFA, CLP, dated June 17, 2020.
`
`5.
`
`Attached hereto as Exhibit 3 is a true and correct copy of Finjan-RPD 427541,
`
`which was introduced as Exhibit 9 to Mr. Parr’s deposition.
`
`6.
`
`Attached hereto as Exhibit 4 are excerpts from the September 11, 2020 deposition
`
`of Russell L. Parr.
`
`7.
`
`Attached hereto as Exhibit 5 is a true and correct copy of the Order on Daubert
`
`Motions, Finjan, Inc. v. Cisco Sys., Inc., Case No. 17-cv-00072-BLF, Dkt. 555 (redacted version)
`
`(N.D. Cal. Apr. 21, 2020)
`
`8.
`
`Attached hereto as Exhibit 6 are excerpts from Finjan’s Motion to Exclude
`
`Expert Opinions of Cisco’s Experts Mr. Overby & Dr. Becker, Finjan, Inc. v. Cisco Sys., Inc.
`
`9.
`
`Attached hereto as Exhibit 7 are excerpts from the Expert Report of Stephen Becker
`
`dated August 14, 2019, in the Finjan, Inc. v. Cisco Sys., Inc. matter.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`
`
`Dated this 6th day of November, 2020.
`
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`
`
`/s/ John R. Gibson
`John R. Gibson
`
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`2
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