`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 13-919-JLH
`
`))))))))))
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`
`
`ARENDI S.A.R.L.,
`
`
`Plaintiff,
`
`
`v.
`
`GOOGLE LLC,
`
`
`Defendant.
`
`
`
`
`
`
`
`
`LETTER TO THE HONORABLE JENNIFER L. HALL FROM NEAL BELGAM
`REGARDING PRELIMINARY JURY INSTRUCTIONS
`
`SMITH, KATZENSTEIN & JENKINS LLP
`Neal C. Belgam (No. 2721)
`Daniel Taylor (No. 6934)
`1000 West Street, Suite 1501
`Wilmington, DE 19801
`(302) 652-8400
`nbelgam@skjlaw.com
`dtaylor@skjlaw.com
`
`Attorneys for Plaintiff Arendi S.A.R.L.
`
`
`Of Counsel:
`
`SUSMAN GODFREY LLP
`Seth Ard (pro hac vice)
`Max Straus (pro hac vice)
`1301 Avenue of the Americas, 32nd Floor
`New York, NY 10019
`sard@susmangodfrey.com
`mstraus@susmangodfrey.com
`
`John Lahad (pro hac vice)
`1000 Louisiana Street, Suite 5100
`Houston, TX 77002-5096
`jlahad@susmangodfrey.com
`
`Kalpana Srinivasan (pro hac vice)
`1900 Avenue of the Stars, Suite 1400
`Los Angeles, CA 90067
`ksrinivasan@susmangodfrey.com
`
`Kemper Diehl (pro hac vice)
`401 Union Street, Suite 3000
`Seattle, WA 98101-3000
`kdiehl@susmangodfrey.com
`
`Dated: April 20, 2023
`
`
`
`
`
`Case 1:13-cv-00919-JLH Document 474 Filed 04/20/23 Page 2 of 2 PageID #: 49962
`
`Dear Judge Hall:
`
`We write on behalf of Arendi S.A.R.L. and Google LLC pursuant to the Court’s Order
`(D.I. 471) that the parties shall file a joint letter setting forth any corrections or objections to the
`Court’s Proposed Preliminary Jury Instructions.
`
`Arendi will not be asserting at trial the method claims (claims 1 and 8) of U.S. Patent No.
`7,917,843. Accordingly, the listing of asserted claims in Section II (“Overview of the Case”)
`should be modified to state: “Plaintiff alleges that the Defendant infringes Claims 23 and 30 of the
`’843 Patent.”
`
`Arendi maintains that there are no other changes or objections to the Court’s Proposed
`Preliminary Jury Instructions.
`
`Google maintains that the following two underlined sentences from “Section VII. Burdens
`of Proof” (p. 7) should also be removed. The first underlined sentence is redundant, and the second
`should drop out with the removal of the method claims. Arendi opposes the removal.
`
`
`“Plaintiff Arendi asserts that Defendant Google infringes the ’843 Patent. Plaintiff Arendi
`alleges that Defendant Google infringes the ’843 Patent directly. Plaintiff Arendi also alleges that
`Defendant Google induced others to infringe the ’843 Patent and contributed to others’
`infringement of the ’843 Patent. Plaintiff Arendi alleges that the Defendant’s infringement of
`the’843 Patent was willful. Plaintiff Arendi bears the burden of proof on each of these issues by a
`preponderance of the evidence.”
`
`Arendi would not oppose Google’s proposed deletion of the two sentences provided that
`such removal is without prejudice to the infringement claims themselves and does not constitute a
`waiver of any claims.
`
`
`The parties are available at the Court’s convenience to address any questions or concerns.
`
`Respectfully,
`
`/s/ Neal C. Belgam
`
`Neal C. Belgam (No. 2721)
`
`cc:
`
`Clerk of Court (via CM/ECF)
`All Counsel of Record (via CM/ECF)
`
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