Case 1:19-cv-01410-MN Document 240 Filed 09/28/23 Page 1 of 9 PageID #: 9615
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`VB ASSETS, LLC,
`
`Plaintiff,
`
`v.
`
`AMAZON.COM, INC., AMAZON.COM LLC,
`AMAZON WEB SERVICES, INC., A2Z
`DEVELOPMENT CENTER, INC. d/b/a LAB126,
`RAWLES LLC, AMZN MOBILE LLC, AMZN
`MOBILE 2 LLC, AMAZON.COM SERVICES, INC.
`f/k/a AMAZON FULFILLMENT SERVICES, INC.,
`and AMAZON DIGITAL SERVICES LLC,
`
`Defendants.
`
`C.A. No. 1:19-cv-01410-MN
`
`[PLAINTIFF’S PROPOSED] VERDICT FORM
`
`In answering the following questions, you are to follow the instructions I have given you
`
`in the Court’s jury charge. Your answers to each question must be unanimous. Some of the
`
`questions contain legal terms that are defined and explained in detail in the Final Jury Instructions.
`
`You should refer to and consider the Final Jury Instructions as you answer these questions in the
`
`Verdict Form.
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`VB ASSETS, LLC,
`
`Plaintiff,
`
`v.
`
`AMAZON.COM, INC., AMAZON.COM LLC,
`AMAZON WEB SERVICES, INC., A2Z
`DEVELOPMENT CENTER, INC. d/b/a LAB126,
`RAWLES LLC, AMZN MOBILE LLC, AMZN
`MOBILE 2 LLC, AMAZON.COM SERVICES, INC.
`f/k/a AMAZON FULFILLMENT SERVICES, INC.,
`and AMAZON DIGITAL SERVICES LLC,
`
`Defendants.
`
`C.A. No. 1:19-cv-01410-MN
`
`[PLAINTIFF’S PROPOSED] VERDICT FORM
`
`In answering the following questions, you are to follow the instructions I have given you
`
`in the Court’s jury charge. Your answers to each question must be unanimous. Some of the
`
`questions contain legal terms that are defined and explained in detail in the Final Jury Instructions.
`
`You should refer to and consider the Final Jury Instructions as you answer these questions in the
`
`Verdict Form.
`
`
`
`Case 1:19-cv-01410-MN Document 240 Filed 09/28/23 Page 2 of 9 PageID #: 9616
`
`QUESTION NO. 1: Has VB Assets proven, by a preponderance of the evidence, that Amazon
`
`INFRINGEMENT
`
`infringed any of the following claims of the asserted patents?
`
`Answer “Yes” or “No” for each claim.
`
`“Yes” is a finding for VB Assets. “No” is a finding for Amazon.
`
`’681 Patent
`
`’703 Patent
`
`’176 Patent
`
`’536 Patent
`
`’097 Patent
`
`Claim 1:
`
`YES____
`
`NO____
`
`Claim 13:
`
`YES____
`
`NO____
`
`Claim 25:
`
`YES____
`
`NO____
`
`Claim 29:
`
`YES____
`
`NO____
`
`Claim 15:
`
`YES____
`
`NO____
`
`Claim 25:
`
`YES____
`
`NO____
`
`Claim 40:
`
`YES____
`
`NO____
`
`Claim 46:
`
`YES____
`
`NO____
`
`Claim 38:
`
`YES____
`
`NO____
`
`Claim 23:
`
`YES____
`
`NO____
`
`Please proceed to the next question.
`
`2
`
`
`
`Case 1:19-cv-01410-MN Document 240 Filed 09/28/23 Page 3 of 9 PageID #: 9617
`
`WILLFULNESS (IF APPLICABLE)
`
`QUESTION NO. 2: If you found any patent infringed, did VB Assets prove, by a preponderance
`
`of the evidence, that Amazon’s infringement of that patent was willful?
`
`Answer “Yes” or “No” for each claim.
`
`“Yes” is a finding for VB Assets. “No” is a finding for Amazon.
`
`’681 Patent: YES____
`
`NO____
`
`’703 Patent: YES____
`
`NO____
`
`’176 Patent: YES____
`
`NO____
`
`’536 Patent: YES____
`
`NO____
`
`’097 Patent: YES____
`
`NO____
`
`Please proceed to the next question.
`
`3
`
`
`
`Case 1:19-cv-01410-MN Document 240 Filed 09/28/23 Page 4 of 9 PageID #: 9618
`
`QUESTION NO. 3: Did Amazon prove, by clear and convincing evidence, that the following
`
`OBVIOUSNESS
`
`claims of the asserted patents are obvious?
`
`Answer “Yes” or “No” for each claim.
`
`“Yes” is a finding for Amazon. “No” is a finding for VB Assets.
`
`’681 Patent
`
`’703 Patent
`
`’176 Patent
`
`’536 Patent
`
`’097 Patent
`
`Claim 1:
`
`YES____
`
`NO____
`
`Claim 13:
`
`YES____
`
`NO____
`
`Claim 25:
`
`YES____
`
`NO____
`
`Claim 29:
`
`YES____
`
`NO____
`
`Claim 15:
`
`YES____
`
`NO____
`
`Claim 25:
`
`YES____
`
`NO____
`
`Claim 40:
`
`YES____
`
`NO____
`
`Claim 46:
`
`YES____
`
`NO____
`
`Claim 38:
`
`YES____
`
`NO____
`
`Claim 23:
`
`YES____
`
`NO____
`
`Please proceed to the next question.
`
`4
`
`
`
`Case 1:19-cv-01410-MN Document 240 Filed 09/28/23 Page 5 of 9 PageID #: 9619
`
`WRITTEN DESCRIPTION
`
`QUESTION NO. 4: Did Amazon prove, by clear and convincing evidence, that the following
`
`claims of the asserted patents lack any written description?
`
`Answer “Yes” or “No” for each claim.
`
`“Yes” is a finding for Amazon. “No” is a finding for VB Assets.
`
`’681 Patent
`
`’703 Patent
`
`’176 Patent
`
`’536 Patent
`
`’097 Patent
`
`Claim 1:
`
`YES____
`
`NO____
`
`Claim 13:
`
`YES____
`
`NO____
`
`Claim 25:
`
`YES____
`
`NO____
`
`Claim 29:
`
`YES____
`
`NO____
`
`Claim 15:
`
`YES____
`
`NO____
`
`Claim 25:
`
`YES____
`
`NO____
`
`Claim 40:
`
`YES____
`
`NO____
`
`Claim 46:
`
`YES____
`
`NO____
`
`Claim 38:
`
`YES____
`
`NO____
`
`Claim 23:
`
`YES____
`
`NO____
`
`Please proceed to the next question.
`
`5
`
`
`
`Case 1:19-cv-01410-MN Document 240 Filed 09/28/23 Page 6 of 9 PageID #: 9620
`
`PATENT INELIGIBILITY
`
`QUESTION NO. 5: Did Amazon prove by clear and convincing evidence that the following
`
`claims of the asserted patents only involved activities that were well-understood, routine, and
`
`conventional?
`
`Answer “Yes” or “No” for each claim.
`
`“Yes” is a finding for Amazon “No” is a finding for VB Assets.
`
`’681 Patent
`
`’703 Patent
`
`’176 Patent
`
`’536 Patent
`
`’097 Patent
`
`Claim 1:
`
`YES____
`
`NO____
`
`Claim 13:
`
`YES____
`
`NO____
`
`Claim 25:
`
`YES____
`
`NO____
`
`Claim 29:
`
`YES____
`
`NO____
`
`Claim 15:
`
`YES____
`
`NO____
`
`Claim 25:
`
`YES____
`
`NO____
`
`Claim 40:
`
`YES____
`
`NO____
`
`Claim 46:
`
`YES____
`
`NO____
`
`Claim 38:
`
`YES____
`
`NO____
`
`Claim 23:
`
`YES____
`
`NO____
`
`Please proceed to the next question.
`
`6
`
`
`
`Case 1:19-cv-01410-MN Document 240 Filed 09/28/23 Page 7 of 9 PageID #: 9621
`
`If you have reached this point in the Verdict Form, you should have answered Questions 1
`
`through 5. If you have not answered Questions 1 through 5, please go back and answer them
`
`before proceeding.
`
`If you answered “NO” for ALL parts in Question 1, OR “YES” to ALL parts of Questions
`
`3, 4, or 5 then do not answer any further questions. Proceed to the last page, have your Jury
`
`Foreperson sign and date this Verdict Form, and then deliver it to the Court Security Officer.
`
`You should not pay attention to any other instructions between this point and the signature
`
`page found at the end of this Verdict Form.
`
`You should only proceed to answer Question 6 if you (1) answered “YES” for any claim in
`
`Question 1, and (2) you answered “NO” for the same claim in Questions 3, 4 and 5.
`
`7
`
`
`
`Case 1:19-cv-01410-MN Document 240 Filed 09/28/23 Page 8 of 9 PageID #: 9622
`
`QUESTION 6: DAMAGES (IF APPLICABLE)
`
`What sum of money do you find VB Assets has proven it is entitled to for past infringement?
`
`$
`
`Please proceed to the Final Page of the Verdict Form.
`
`8
`
`
`
`Case 1:19-cv-01410-MN Document 240 Filed 09/28/23 Page 9 of 9 PageID #: 9623
`
`FINAL PAGE OF THE JURY VERDICT
`
`You have now reached the end of the Verdict Form and should review it to ensure it
`
`accurately reflects your unanimous determinations. The Jury Foreperson should then sign
`
`and date the Verdict Form in the spaces below. Once this is done, notify the Court Security
`
`Officer that you have reached a verdict. The Jury Foreperson should keep the Verdict Form
`
`and bring it when the jury is brought back to the court room.
`
`Signed this
`
`
`
` day of
`
`, 2023.
`
`Jury Foreperson
`
`9
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
