EXHIBIT 6

Redacted

Case 5:17-cv-00072-BLF Document 682-7 Filed 07/31/20 Page 1 of 3
MATTHEW C. GAUDET

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June 15, 2020 

VIA E-MAIL

Juanita R. Brooks 

FISH & RICHARDSON P.C. 

12390 El Camino Real, Suite 100 

San Diego, CA 92130 

Re: Finjan, Inc. v. Cisco Systems Inc.

Case No. 5:17-cv-00072-BLF (N.D. Cal.)

Dear Juanita: 

It has come to our attention based on public reports that Finjan Holdings, Inc. (“Finjan”) 

has entered into an agreement (the “Agreement”) with affiliates of Fortress Investment Group LLC 

(“Fortress”), including but not limited to CFIP Goldfish Holdings LLC and CFIP Goldfish Merger 

Sub Inc., for all outstanding shares of common stock for $1.55 per share in cash, representing an 

aggregate equity value of approximately $43.9 million. 

It also appears from public reports that, in return for this purchase price, Finjan has agreed 

to transfer to Fortress, among other things: (i) almost $30 million of cash; plus (ii) the IBM patent 

portfolio that Finjan acquired for almost ; plus (iii) all of the legacy Finjan patent 

portfolio, including all of the patents-in-suit; plus (iv) the rights to the claims in all existing 

lawsuits, including the lawsuit against Cisco . These facts would place a value on the entire Finjan 

patent portfolio of less than . The value of a license to the 5 patents-in-suit against 

Cisco would obviously be a small fraction of that amount. 

These facts are highly relevant to the damages issues in this case. Pursuant to Federal Rule 

of Civil Procedure 26(e), therefore, Cisco requests that Finjan, Inc. supplement its responses to the 

relevant Cisco interrogatories and requests for production and supplement its document production 

to provide the Agreement and any information, communications, and documents related to or 

arising from the Agreement, including Finjan’s communications with Finjan’s shareholders, 

Finjan’s communications with Fortress or any related entity, any other document or agreement 

Case 5:17-cv-00072-BLF Document 682-7 Filed 07/31/20 Page 2 of 3
Juanita R. Brooks 

June 15, 2020 

Page 2 

with Finjan’s shareholders, and any other document or agreement with Fortress or any related 

entity. These discovery requests include but are not limited to interrogatories 4, 8, and 17 and 

requests for production 17, 20, 21, 22, 23, 24, 28, 31, 33, 38, 39, 41, 42, 43, 44, and 51. 

Cisco further requests that Finjan supplement its email productions, using the same search 

terms as before, for custodians Chinn, Mar-Spinola, Hartstein, and Garland for the time period 

from the beginning of the negotiations with Fortress or its affiliates through present. 

In addition, please confirm that Finjan will not challenge Cisco’s issuance of documents 

and deposition subpoenas pursuant to Federal Rule of Civil Procedure 45 to Fortress and the 

relevant affiliates, nor challenge Cisco’s use of any information, documents, or testimony during 

trial received in response to or in connection with these subpoenas. 

Please promptly inform us of any objections Finjan may have as to the requested 

information and documents so that we can schedule a meet and confer as soon as possible. Cisco 

reserves the right to supplement its pretrial documents, to refile pretrial motions, and to seek any 

other relief from the Court as necessary. 

Very truly yours, 

/s/ Matthew C. Gaudet

Matthew C. Gaudet 

MCG/cap 

Case 5:17-cv-00072-BLF Document 682-7 Filed 07/31/20 Page 3 of 3