Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 1 of 7 PageID #: 52206
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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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`VERDICT FORM
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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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`Instructions: When answering the following questions and completing this Verdict
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`Form, please follow the directions provided and follow the Jury Instructions that you have been
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`given. Your answer to each question must be unanimous. Some of the questions contain legal
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`terms that are defined and explained in the Jury Instructions. Please refer to the Jury Instructions if
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`you are unsure about the meaning or usage of any legal term that appears in the questions below.
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`As used herein:
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`1. “Arendi” refers to Plaintiff Arendi S.A.R.L.;
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`2. “Google” refers to Defendant Google LLC;
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`3. The “’843 Patent” refers to U.S. Patent No. 7,917,843.
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`1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 13-919-JLH
`
`))))))))))
`
`
`
`
`VERDICT FORM
`
`ARENDI S.A.R.L.,
`
`
`Plaintiff,
`
`
`v.
`
`GOOGLE LLC,
`
`
`Defendant.
`
`
`
`Instructions: When answering the following questions and completing this Verdict
`
`Form, please follow the directions provided and follow the Jury Instructions that you have been
`
`given. Your answer to each question must be unanimous. Some of the questions contain legal
`
`terms that are defined and explained in the Jury Instructions. Please refer to the Jury Instructions if
`
`you are unsure about the meaning or usage of any legal term that appears in the questions below.
`
`As used herein:
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`1. “Arendi” refers to Plaintiff Arendi S.A.R.L.;
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`2. “Google” refers to Defendant Google LLC;
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`3. The “’843 Patent” refers to U.S. Patent No. 7,917,843.
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`1
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`Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 2 of 7 PageID #: 52207
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`QUESTION 1:
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`Did Arendi prove by a preponderance of the evidence that Google [Google’s proposal: directly]
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`infringed any of the following claims of the ’843 Patent?
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`“Yes” is a finding for Arendi.
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`“No” is a finding for Google.
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`Claim 23
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`Claim 30
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`YES
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`NO
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`[Arendi’s Proposal:
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`QUESTION 2:
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`Did Google prove by clear and convincing evidence that any of the following claims of the ’843
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`Patent are invalid?
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`“Yes” is a finding for Google.
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`“No” is a finding for Arendi.
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`Claim 23
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`Claim 30
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`YES
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`NO
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`2
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`Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 3 of 7 PageID #: 52208
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`[Google’s Proposal:
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`QUESTION 2:
`Did Google prove by clear and convincing evidence that any of the following claims of the ’843
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`Patent are invalid as anticipated by prior art?
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`“Yes” is a finding in favor of Google.
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`“No” is a finding in favor of Arendi.
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`Claim 23
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`Claim 30
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`YES
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`NO
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`QUESTION 3:
`Did Google prove by clear and convincing evidence that any of the following claims of the ’843
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`Patent are invalid as obvious in view of prior art?
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`“Yes” is a finding in favor of Google.
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`“No” is a finding in favor of Arendi.
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`Claim 23
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`Claim 30
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`YES
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`NO
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`3
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`Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 4 of 7 PageID #: 52209
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`[Arendi’s Proposal:
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`Instructions: Only answer Question 3 if you:
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` Answered “Yes” for any of the claims in Question 1; and
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` Answered “No” for one or more of those same claims in Question 2.
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`]
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`[Google’s Proposal:
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`Instructions: Only answer Questions 4, 5, and 6 if you:
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` Answered “Yes” for any of the claims in Question 1; and
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` Answered “No” for any of those same claims in Question 2 and Question 3.
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`Otherwise, skip and DO NOT answer Questions 4, 5, and 6 and instead please proceed directly
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`to the final page of this Verdict Form and sign and date that page.]
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`[Arendi’s Proposal:
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`QUESTION 3:
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`What sum of money has Arendi proven by a preponderance of the evidence that it is entitled to as
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`a reasonable royalty for Google’s infringement of the ’843 Patent?
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`]
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`Answer: $ _________________________
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`4
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`Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 5 of 7 PageID #: 52210
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`[Google’s Proposal:
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`QUESTION 4:
`For any infringement you found in Question 1 what is the earliest possible date of first
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`infringement?
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`“August 21, 2017” is a finding in favor of Arendi.
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`“December 5, 2017” is a finding in favor of Google.
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`August 21, 2017: ___________ or December 5, 2017: _____________
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`QUESTION 5:
`What amount of damages, if any, has Arendi proven, by a preponderance of the evidence, that it
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`is entitled to as a reasonable royalty for Google’s infringement of the ’843 Patent?
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`Answer: $ ______________
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`QUESTION 6:
`Does the amount you have determined in response to Question No. 4 include damages for Google
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`apps installed on Samsung devices?
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`“Yes” is a finding in favor of Arendi.
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`“No” is a finding in favor of Google.
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`Yes: ______________
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`No: ______________
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` ]
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`[Arendi: Arendi opposes Google’s proposed questions regarding the date of first infringement
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`and the Samsung license, including because Arendi understood that the Court rejected them on
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`5
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`Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 6 of 7 PageID #: 52211
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`April 28, 2023.]
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`[Google: During the 4/28/2023 hearing, the Court indicated its inclination regarding Google’s
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`questions on the date of first infringement and the Samsung license, and asked the parties to
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`discuss them. See 4/28 Trial Tr. (Rough) at 1117:25-1118:7. The parties discussed further but
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`have not reached agreement.]
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`QUESTION 4:
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`[numbering to be updated as needed]
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`Did Arendi prove by a preponderance of the evidence that Google’s infringement of any of the
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`claims of the ’843 Patent was willful?
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`“Yes” is a finding for Arendi.
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`“No” is a finding for Google.
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`Yes: _________________
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`No: _________________
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`6
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`Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 7 of 7 PageID #: 52212
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`You have now reached the end of the verdict form and you should review it to ensure that
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`it entirely reflects your unanimous determinations. The Foreperson should then sign the verdict
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`form in the space below and notify the Court Security Officer that you have reached a verdict. The
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`Foreperson should retain possession of the verdict form and bring it to the courtroom with the jury.
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`Signed: ____________________________________
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`Dated: ___________________
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`7
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