Finjan, Inc. v. Zscaler, Inc.

Filing 28

STIPULATION AND ORDER re 27 STIPULATION WITH PROPOSED ORDER filed by Zscaler, Inc. Case Management Statement due by 4/9/2018. Initial Case Management Conference set for 4/18/2018 at 2:00 PM in San Francisco, Courtroom 09, 19th Floor. Signed by Judge Jon S. Tigar on March 15, 2018. (wsn, COURT STAFF) (Filed on 3/15/2018)

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DURIE TANGRI LLP
SONAL N. MEHTA (SBN 222086)
[e-mail]
JOSEPH C. GRATZ (SBN 240676)
[e-mail]
SONALI D. MAITRA (SBN 254896)
[e-mail]
ANDREW L. PERITO (SBN 269995)
[e-mail]
217 Leidesdorff Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
ZSCALER, INC.

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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FINJAN, INC.,

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Case No. 3:17-cv-06946-JST
Plaintiff,

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v.

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ZSCALER, INC.,

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STIPULATION AND [PROPOSED] ORDER
REGARDING CASE MANAGEMENT
CONFERENCE
Ctrm: 9, 19th Floor
Judge: Honorable Jon S. Tigar

Defendant.

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STIPULATION AND [PROPOSED] ORDER REGARDING CASE MANAGEMENT CONFERENCE /
CASE NO. 3:17-CV-06946-JST

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Pursuant to Civil L.R. 7-12, Defendant Zscaler, Inc. (“Zscaler”) and Plaintiff Finjan, Inc.

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(“Finjan”) (collectively, the “Parties”) respectfully submit the following Stipulation and [Proposed]

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Order Regarding the Case Management Conference (“CMC”).

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Zscaler requests and Finjan does not oppose that the date of the CMC be changed to April 18,

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2018 at 2:00 p.m. This stipulated request is supported by the Declaration of Sonal N. Mehta in Support

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of Stipulation and [Proposed] Order Regarding Case Management Conference (“Mehta Decl.”). In

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support of the stipulated request, Zscaler states as follows:

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1.

The Court set the CMC hearing in this matter for March 14, 2018. See Dkt. 15.

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2.

The Court sua sponte continued the CMC hearing in this matter for April 4, 2018 at 2:00

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p.m. Id.

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3.

The Parties request that the CMC in this matter be set for April 18, 2018 at 2:00 p.m.

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Mehta Decl. ¶ 3.

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4.

The request is made for good cause and not for purposes of delay. Lead counsel for

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Zscaler, Sonal N. Mehta, intends to attend the Case Management Conference but has a dispositive

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motions hearing scheduled for April 4, 2018 in Los Angeles on another matter. Mehta Decl. ¶ 4.

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5.

There has been only one prior request for extension in this case—a stipulated request for a

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31-day extension of time for Zscaler’s response to the complaint, from January 12, 2018 to February 18,

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2018. Mehta Decl. ¶ 5.

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6.

The requested 2-week continuance is not expected to affect any other currently scheduled

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deadlines in the case, except the deadlines for the Rule 26(f) conference and the filing of the Case

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Management Conference Statement, which would be continued accordingly by 2 weeks.

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Mehta Decl. ¶ 6.

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For the foregoing reasons, the parties respectfully request that the Court enter an order that the
CMC in the above-captioned cases be set for April 18, 2018 at 2:00 p.m.

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STIPULATION AND [PROPOSED] ORDER REGARDING CASE MANAGEMENT CONFERENCE /
CASE NO. 3:17-CV-06946-JST

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Dated: March 14, 2018

DURIE TANGRI LLP

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/s/ Sonal N. Mehta
SONAL N. MEHTA

By:
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Attorney for Defendant
ZSCALER, INC.

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Dated: March 14, 2018

KRAMER LEVIN NAFTALIS & FRANKEL LLP

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/s/ James Hannah
JAMES HANNAH

By:

Attorney for Plaintiff
FINJAN, INC.

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STIPULATION AND [PROPOSED] ORDER REGARDING CASE MANAGEMENT CONFERENCE /
CASE NO. 3:17-CV-06946-JST

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FILER’S ATTESTATION
Pursuant to Civil L.R. 5-1(i)(3), regarding signatures, I, Sonal N. Mehta, attest that concurrence in

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the filing of this document has been obtained.

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Dated: March 14, 2018
/s/ Sonal N. Mehta
SONAL N. MEHTA

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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March 15
Dated: ______________, 2018

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HONORABLE JON S. TIGAR
UNITED STATES DISTRICT JUDGE

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STIPULATION AND [PROPOSED] ORDER REGARDING CASE MANAGEMENT CONFERENCE /
CASE NO. 3:17-CV-06946-JST