Case 1:13-cv-00919-JLH Document 450 Filed 03/31/23 Page 1 of 5 PageID #: 48501
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 13-919-JLH
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`))))))))))
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`PROPOSED VOIR DIRE
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`ARENDI S.A.R.L.,
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`Plaintiff,
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`v.
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`GOOGLE LLC,
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`Defendant.
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`Good morning, ladies and gentlemen. I am Magistrate Judge Jennifer Hall. We are going
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`to select a jury in a case called Arendi S.A.R.L. v. Google LLC.
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`I am going to ask you some questions, the purpose of which is to: (1) enable the Court to
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`determine whether or not any prospective juror should be excused for cause; and (2) enable counsel
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`for the parties to exercise their individual judgment with respect to what are called peremptory
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`challenges, that is, challenges that counsel can make to a potential juror without giving any reason.
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`Before I ask any questions, I am going to ask my Courtroom Deputy to swear the jury panel
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`to answer all questions truthfully. [To Deputy, Please swear the panel.]
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`You each have a list of the questions that I am also going to read out loud. If any of you
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`answer “yes” to any of the questions that I ask, please raise your hand, and, when recognized by
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`me, please stand, state your name and your jury number. At the end of the questions, the Courtroom
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`Deputy will ask some of you to take seats in the jury box, and, after that, the lawyers and I may
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`ask those of you who answered “yes” to one or more questions to come up to the bench to discuss
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`your answers with the lawyers and me.
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`The presentation of evidence in this case is expected to take five (5) days but jury
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`deliberations could extend your service beyond that. The schedule that I expect to keep over the
`1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`
`
`
`C.A. No. 13-919-JLH
`
`))))))))))
`
`
`
`PROPOSED VOIR DIRE
`
`ARENDI S.A.R.L.,
`
`
`Plaintiff,
`
`
`v.
`
`GOOGLE LLC,
`
`
`Defendant.
`
`
`
`
`
`Good morning, ladies and gentlemen. I am Magistrate Judge Jennifer Hall. We are going
`
`to select a jury in a case called Arendi S.A.R.L. v. Google LLC.
`
`I am going to ask you some questions, the purpose of which is to: (1) enable the Court to
`
`determine whether or not any prospective juror should be excused for cause; and (2) enable counsel
`
`for the parties to exercise their individual judgment with respect to what are called peremptory
`
`challenges, that is, challenges that counsel can make to a potential juror without giving any reason.
`
`Before I ask any questions, I am going to ask my Courtroom Deputy to swear the jury panel
`
`to answer all questions truthfully. [To Deputy, Please swear the panel.]
`
`You each have a list of the questions that I am also going to read out loud. If any of you
`
`answer “yes” to any of the questions that I ask, please raise your hand, and, when recognized by
`
`me, please stand, state your name and your jury number. At the end of the questions, the Courtroom
`
`Deputy will ask some of you to take seats in the jury box, and, after that, the lawyers and I may
`
`ask those of you who answered “yes” to one or more questions to come up to the bench to discuss
`
`your answers with the lawyers and me.
`
`The presentation of evidence in this case is expected to take five (5) days but jury
`
`deliberations could extend your service beyond that. The schedule that I expect to keep over the
`1
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`Case 1:13-cv-00919-JLH Document 450 Filed 03/31/23 Page 2 of 5 PageID #: 48502
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`days of evidence presentation will include a morning break of fifteen minutes, a lunch break of an
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`hour, and an afternoon break of fifteen minutes. We will start at 9:00 a.m. and finish at
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`approximately 5:30 p.m. each day.
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`you?
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`1.
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`2.
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`Does the schedule that I have just mentioned present a special problem to any of
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`This is a patent lawsuit involving smartphones and smartphone apps. The
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`Plaintiff is Arendi S.A.R.L, which I will call Arendi. Arendi has sued Google LLC for alleged
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`patent infringement. Google denies that claim. Have any of you heard or read anything about
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`this case?
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`3.
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`Have any of you or someone close to you ever been employed by Arendi or
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`Google?
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`4.
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`5.
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`Alphabet?
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`Have any of you or someone close to you ever been employed by Alphabet Inc.?
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`Have any of you or someone close to you ever owned stock in Google or
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`6.
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`Have any of you or someone close to you ever had a business relationship with
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`Arendi or Google?
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`7.
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`Have any of you or someone close to you ever had any experience, good or bad,
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`with Arendi or Google that might keep you from being a fair and impartial juror in this case?
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`8.
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`Do any of you have any opinions about Arendi or Google that might keep you
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`from being an impartial juror in this case?
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`9.
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`The lawyers and the law firms involved in this case are as follows:
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`Plaintiffs are represented by lawyers from Smith, Katzenstein & Jenkins LLP and
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`Susman Godfrey LLP.
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`From Smith, Katzenstein & Jenkins: Neal Belgam and Daniel Taylor.
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`2
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`Case 1:13-cv-00919-JLH Document 450 Filed 03/31/23 Page 3 of 5 PageID #: 48503
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`From Susman Godfrey: Kalpana1 Srinivasan, John Lahad, Seth Ard, Kemper Diehl
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`and Max Straus.
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`Google is represented by lawyers from Potter Anderson & Corroon LLP and Paul
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`Hastings LLP.
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`Roberts.
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`From Potter Anderson & Corroon LLP: David Moore and Bindu Palapura
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`From Paul Hastings: Robert Unikel, Chad Peterman, Matthias Kamber, and Andrea
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`10. Do any of you know any of these attorneys or law firms I have just named?
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`11. Have any of you or someone close to you had any business dealings with, or been
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`employed by, any of these attorneys or law firms?
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`12. Have any of you owned a Google Pixel smartphone?
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`13. Do any of you use any of the following apps on an Android smartphone: Chrome,
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`Google Docs, Google Sheets, Google Slides, Inbox by Gmail, Google News, Google Messages,
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`Google Tasks, Google Calendar, Google Contacts, Gmail, Google Keep, or Google Hangouts?
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`14. The potential witnesses in this case are:
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`- Syed Albiz
`- Clara Bayarri
`- Ted Choc
`- Anind Dey
`- Brahim Elbouchikhi
`- Thomas Faulhaber
`- Edward Fox
`- Atle Hedløy
`- Violette Hedløy
`- Walter Jang
`- Evelyn Kao
`- Douglas Kidder
`-
`James Maccoun
`- Sai Marri
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`Jim Miller
`- Giulia Pagallo
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`1 Pronounced kәl.pә.nɑ:
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`3
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`Case 1:13-cv-00919-JLH Document 450 Filed 03/31/23 Page 4 of 5 PageID #: 48504
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`- Kishore Papineni
`- Mike Pinkerton
`- Martin Rinard
`- Earl Sacerdoti
`- Trevor Smedley
`- Abodunrinwa Toki
`- Roy Weinstein
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`a) Are any of you familiar with any of these individuals?
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`15. Have any of you or someone close to you ever had any experience with patents,
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`patent law, or the U.S. Patent and Trademark Office?
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`16. Have any of you, someone close to you, or your employer (current or previous)
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`ever been involved in a dispute about patent rights?
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`17. Have any of you, someone close to you, or your employer (current or previous)
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`ever been a party to a patent license or negotiated a license agreement?
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`18. Do any of you have strong opinions about patents, patent rights, or the U.S. Patent
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`and Trademark Office?
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`19. Have any of you or your immediate family ever had an experience in which you
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`felt someone used an idea you had without your permission, or you were accused of using an
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`idea without permission?
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`20. Have any of you served on a jury in a civil case within the last fifteen years?
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`21. Have any of you ever been a plaintiff, a defendant, or a witness in a lawsuit?
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`22. Have any of you or your immediate family owned or run a business?
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`23. Do any of you have any education, training or work experience in the fields of
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`software development, computer science, economics, or finance?
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`24.
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`If you are selected as a juror in this case, are any of you aware of any reason why
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`you would be unable to render a verdict based solely on the evidence presented at trial?
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`Case 1:13-cv-00919-JLH Document 450 Filed 03/31/23 Page 5 of 5 PageID #: 48505
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`25.
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`If you are selected as a juror in this case, are any of you aware of any reason why
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`you would not be able to follow the law as I give it to you?
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`26. Do any of you have strong feelings either way about your ability to follow my
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`instructions in a civil case like this where one party is seeking money damages from another?
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`27.
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`Is there anything, such as poor vision, difficulty hearing or difficulty
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`understanding spoken or written English, that would make it difficult for any of you to serve on
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`this jury?
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`28. Have any of you ever had any experience with the legal system that might prevent
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`you from being a fair and impartial juror?
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`29.
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`Is there anything else, including something you have remembered in connection
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`with one of the earlier questions, or that any of you think may prevent you from rendering a fair
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`and impartial verdict based solely upon the evidence and my instructions as to the law?
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`5
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