Case 1:13-cv-00919-JLH Document 465-1 Filed 04/18/23 Page 1 of 5 PageID #: 49312
`Case 1:13-cv-00919-JLH Document 465-1 Filed 04/18/23 Page 1 of 5 PagelD #: 49312
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`EXHIBIT A
`EXHIBIT A
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`Case 1:13-cv-00919-JLH Document 465-1 Filed 04/18/23 Page 1 of 5 PagelD #: 49312
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`EXHIBIT A
`EXHIBIT A
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`Case 1:13-cv-00919-JLH Document 465-1 Filed 04/18/23 Page 2 of 5 PageID #: 49313
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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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`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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`JOINT REVISED PROPOSED VOIR DIRE
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`Good morning, ladies and gentlemen. I am Judge Hall. We are going to select a jury in a
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`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 make a note to yourself about which
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`questions you had “yes” answers to. At the end of the questions, the Courtroom Deputy may ask
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`some of you whether you had any “yes” answers and, after that, the lawyers and I may ask those
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`of you who answered “yes” to one or more questions to come back to the jury room 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. We will start next week on Monday and
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`1
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`Case 1:13-cv-00919-JLH Document 465-1 Filed 04/18/23 Page 3 of 5 PageID #: 49314
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`continue through Thursday. We will take Friday off, and then we will conclude with the last day of the
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`presentation of evidence on the following Monday. The schedule that I expect to keep over the days of
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`evidence presentation will include a morning break of fifteen minutes, a lunch break of an hour, and
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`an afternoon break of fifteen minutes. We will start at 9:00 a.m. and finish at approximately 4:30 p.m.
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`each day. Now I will read the questions. Remember, make a note on your paper if you have a “yes”
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`answer to a particular question.
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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, or opinions about Arendi or Google, that might keep you from being a
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`fair and impartial juror in this case?
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`8.
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`The lawyers and the law firms involved in this case are as follows:
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`2
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`Case 1:13-cv-00919-JLH Document 465-1 Filed 04/18/23 Page 4 of 5 PageID #: 49315
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`From Smith, Katzenstein & Jenkins: Neal Belgam and Daniel Taylor.
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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 Susman Godfrey: Kalpana 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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`Do any of you know any of these attorneys or law firms I have just named, or have any of you
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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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`or someone close to you had any business dealings with, or been employed by, any of these
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`attorneys or law firms?
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`9. Have any of you owned a Google Pixel smartphone?
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`10. 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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`11. The potential witnesses in this case are:
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`- Ted Choc
`- Anind Dey
`- Brahim Elbouchikhi
`- Edward Fox
`- Atle Hedløy
`- Douglas Kidder
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`Jim Miller
`- Martin Rinard
`- Earl Sacerdoti
`- Trevor Smedley
`- Abodunrinwa Toki
`- Roy Weinstein
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`Are any of you familiar with any of these individuals?
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`3
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`Case 1:13-cv-00919-JLH Document 465-1 Filed 04/18/23 Page 5 of 5 PageID #: 49316
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`12. Have any of you or someone close to you ever had any experience with patents,
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`patent law, patent licenses, a dispute about patent rights, or the U.S. Patent and Trademark
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`Office?
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`13. 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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`14. Have any of you served on a jury in a civil case within the last fifteen years or
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`have you ever been a plaintiff, a defendant, or a witness in a lawsuit?
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`15. 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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`16.
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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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`17.
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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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`18. 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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`19.
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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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`20. 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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`21.
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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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`4
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