`Jeff Castellano
`I.M. Pei Building
`1105 North Market St., 12th Floor
`Wilmington, DE 19801
`(302) 298-0703
`jcastellano@shawkeller.com
`
`
`
`
`
`September 13, 2021
`
`BY CM/ECF
`The Honorable Leonard P. Stark
`U.S. District Court for the District of Delaware
`844 N. King Street
`Wilmington, DE 19801
`
`
`Re: Finjan LLC. v. Trustwave Holdings, Inc., C.A. No. 20-371-LPS
`
`
`
`Dear Judge Stark:
`
`Pursuant to the Court’s procedures regarding Discovery Matters, Finjan LLC (“Finjan”)
`
`and Trustwave Holdings, Inc. (“Trustwave”) write to request the scheduling of a discovery
`teleconference in the above-referenced matter.
`
`
`The following attorneys, including at least one Delaware Counsel and at least one Lead
`Counsel per party, participated in a meet-and-confer by telephone on September 3, 2021:
`
`
`Counsel for Finjan
`Delaware Counsel:
`Lead Counsel:
`
`Jeff Castellano, Shaw Keller
`Bijal Vakil, Allen & Overy
`
`
`
`Counsel for Trustwave
`Delaware Counsel:
`Jack Blumenfeld, Morris Nichols
`Lead Counsel:
`Jared Brandyberry, BakerHostetler
`
`1. Finjan’s disclosures pursuant to Paragraph 7(a) of the Scheduling Order as to the
`basis for Finjan’s inclusion of certain Trustwave products as accused products.
`
`2. Trustwave’s responses to Finjan’s First Set of Interrogatories, Nos. 1-4, 6.
`
`3. Trustwave’s production of documents responsive to Finjan’s First Set of Requests
`for Production of Documents, Nos. 1, 3, 5, 11, 13, 15, 17, 18, 19, 20, 25, 26.
`
`4. Trustwave’s disclosures pursuant to Paragraph 7(b) of the Scheduling Order as to
`11 of the 15 accused products and sales information.
`
`
`The parties also met and conferred on August 12, 2021. The parties were unable to
`
`resolve certain matters during the telephonic meet-and-confer. The disputes requiring judicial
`attention are listed below:
`
`
`
`
`
`
`
`
`We respectfully request that the Court set a discovery teleconference for resolution of
`these issues.
`
`
`
`
`
`
`
`Case 1:20-cv-00371-LPS Document 104 Filed 09/13/21 Page 2 of 2 PageID #: 3626
`SHAW KELLER LLP
`The Honorable Leonard P. Stark
`Page 2
`
`
`
`
`
`Respectfully,
`
`/s/ Jeff Castellano
`
`Jeff Castellano (No. 4837)
`
`Clerk of the Court (by CM/ECF)
`All counsel of record (by CM/ECF and email)
`
`
`cc:
`
`
`
`
`
`
`
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