`
`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 20, 2020
`
`DECLARATION OF JOHN R. GIBSON IN SUPPORT OF DEFENDANTS
` RAPID7, INC. AND RAPID7 LLC’S REPLY IN SUPPORT OF THEIR MOTION TO
`EXCLUDE OPINIONS AND TESTIMONY OF PLAINTIFF’S EXPERTS, RUSSELL L.
`PARR, MICHAEL MITZENMACHER, NENAD MEDVIDOVIC, ERIC COLE
`AND MICHAEL GOODRICH
`
`I, John R. Gibson, declare and state the following:
`
`1.
`
`My name is John R. Gibson. I provide this declaration in support of Defendants
`
`Rapid7, Inc. and Rapid7 LLC’s (“Rapid7”) Reply in Support of Their Motion to Exclude Opinions
`
`and Testimony of Plaintiff’s Experts, Russell L. Parr, Michael Mitzenmacher, Nenad Medvidovic,
`
`Eric Cole and Michael Goodrich. 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.
`
`
`
`Case 1:18-cv-01519-MN Document 239 Filed 11/20/20 Page 2 of 2 PageID #: 8720
`
`3.
`
`Attached hereto as Exhibit 10 are additional excerpts from the September 11, 2020
`
`deposition of Russell L. Parr, which were not included in my original Declaration.
`
`4.
`
`Attached hereto as Exhibit 11 is the redacted copy of Plaintiff Finjan, Inc.’s
`
`Opposition to Sophos’ Daubert Motion and Motions in Limine, Finjan, Inc. v. Sophos, Inc., Case
`
`No. 14-cv-01197-WHO, Dkt. 227 (N.D. Cal. Aug. 1, 2016), not including the exhibits.
`
`5.
`
`Attached hereto as Exhibit 12 are additional excerpts from the expert report of
`
`Dr. Stephen Becker dated July 31, 2020, which are not otherwise included in the current record.
`
`6.
`
`Attached hereto as Exhibit 13 are excerpts from of Finjan’s Form 10-K (Finjan-
`
`RPD 427541).
`
`7.
`
`Attached hereto as Exhibit 14 are additional excerpts from the Expert Report of
`
`Russell L. Parr, CFA, CLP, dated June 17, 2020, which are not otherwise included in the current
`
`record.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Dated this 13th day of November, 2020.
`
`/s/ John R. Gibson
`John R. Gibson
`
`2
`
`
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