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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE DISTRICT OF DELAWARE
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`FINJAN LLC,
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`Plaintiff,
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`v.
`TRUSTWAVE HOLDINGS, INC., and
`SINGAPORE TELECOMMUNICATIONS
`LIMITED,
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`Defendants.
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`C.A. No. 20-371-LPS
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`NOTICE OF DEPOSITION OF QUAH KUNG YANG
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`TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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`PLEASE TAKE NOTICE that, pursuant to Rule 30 of the Federal Rules of Civil
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`Procedure, Plaintiff Finjan LLC, by and through their undersigned counsel, will take the oral
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`examination of Quah Kung Yang on July 6, 2021, beginning at 8:00 p.m. (ET), and continuing
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`for three hours on the record from day to day until completed, by remote audio-video
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`conference and coordinated by Veritext Legal Solutions, whose physical address is 300
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`Delaware Avenue, Suite 815, Wilmington, DE 19801, or at a mutually acceptable location.
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`Please contact the noticing attorney at as soon as possible prior to the deposition to
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`advise that it is your desire to appear via this remote participating means so that the necessary
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`credentials, call-in numbers, firm name, email address, services, testing and information, if
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`necessary, can be arranged and provided to you prior to the proceeding(s).
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`The deposition shall be recorded by stenographic and/or video means before an officer
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`authorized to administer oaths and will be used for all purposes permitted under the Federal
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`Rules of Civil Procedure and the local rules of the District of Delaware.
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`1
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`Case 1:20-cv-00371-LPS Document 84 Filed 06/24/21 Page 2 of 2 PageID #: 2905
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`PLEASE TAKE FURTHER NOTICE that if the deposition(s) is by remote audio-video
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`conference, it will be recorded by stenographic and audiovisual means, and may utilize instant
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`visual display of the testimony, and a paperless virtual display platform. Both the court
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`reporter and digital reporter are authorized to administer the oath and serve as the deposition
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`officer in the State of Delaware. Take note that the deposition officer may also be remote and
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`out of the presence of the deponent via video teleconferencing or telephonically for the
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`purposes of providing the oath/affirmation to the deponent and capturing the proceeding via
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`one of the options above.
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`OF COUNSEL:
`Bijal Vakil
`Jeremy T. Elman
`Henry Y. Huang
`WHITE & CASE LLP
`3000 El Camino Real
`2 Palo Alto Square, Suite 900
`Palo Alto, CA 94306
`(650) 213-0300
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`Dated: June 24, 2021
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`
`
`/s/ Karen E. Keller
`Karen E. Keller (No. 4489)
`Jeff Castellano (No. 4837)
`SHAW KELLER LLP
`I.M. Pei Building
`1105 North Market Street, 12th Floor
`Wilmington, DE 19801
`(302) 298-0700
`kkeller@shawkeller.com
`Attorneys for Plaintiff
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`2
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