Case 1:19-cv-01410-MN Document 276 Filed 11/03/23 Page 1 of 5 PageID #: 10890
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`VB ASSETS, LLC,
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`AMAZON.COM SERVICES LLC,
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`Plaintiff,
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`v.
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`
`Defendant.
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`C.A. No. 19-1410 (MN)
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`VOIR DIRE QUESTIONS
`
`Good morning. My name is Maryellen Noreika, and I am the Judge who will be presiding
`
`over the trial in this civil case for which a jury is about to be selected. I am going to ask you some
`
`questions, the purpose of which is to: (1) enable us to determine whether any prospective juror
`
`should be excused for cause; and (2) enable counsel for the parties to exercise their individual
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`judgment with respect to what are called peremptory challenges, that is, challenges that counsel
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`can make to a potential juror without giving any reason.
`
`Before I ask any questions, I am going to ask my Deputy to swear the jury panel to answer
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`all questions truthfully. (Panel sworn.)
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`You each have a list of the questions that I am also going to read out loud. If you answer
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`“yes” to any of the questions that I ask, please make a note of that on the list. At the end of the
`
`questions, I will ask whether you answered yes to any question and, if you did, take you out into
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`my conference room where you will talk with the lawyers and me about your answers.
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`We are having jury selection for a case that will begin today and last up to 5 days – until
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`Wednesday November 8, 2023. The trial will be timed, so the attorneys must complete their
`
`presentations in that time. It is possible, however, that jury deliberations may require you to be
`
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`VB ASSETS, LLC,
`
`
`
`
`
`AMAZON.COM SERVICES LLC,
`
`
`
`Plaintiff,
`
`
`
`v.
`
`
`
`Defendant.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`C.A. No. 19-1410 (MN)
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`VOIR DIRE QUESTIONS
`
`Good morning. My name is Maryellen Noreika, and I am the Judge who will be presiding
`
`over the trial in this civil case for which a jury is about to be selected. I am going to ask you some
`
`questions, the purpose of which is to: (1) enable us to determine whether 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 Deputy to swear the jury panel to answer
`
`all questions truthfully. (Panel sworn.)
`
`You each have a list of the questions that I am also going to read out loud. If you answer
`
`“yes” to any of the questions that I ask, please make a note of that on the list. At the end of the
`
`questions, I will ask whether you answered yes to any question and, if you did, take you out into
`
`my conference room where you will talk with the lawyers and me about your answers.
`
`We are having jury selection for a case that will begin today and last up to 5 days – until
`
`Wednesday November 8, 2023. The trial will be timed, so the attorneys must complete their
`
`presentations in that time. It is possible, however, that jury deliberations may require you to be
`
`
`
`
`
`Case 1:19-cv-01410-MN Document 276 Filed 11/03/23 Page 2 of 5 PageID #: 10891
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`
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`here longer than the scheduled number of days. Our trial days will run approximately from
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`9:00 a.m. to 4:30 p.m. each day.
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`With that introduction, my questions are:
`
`you?
`
`1.
`
`2.
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`Does the schedule that I have just mentioned present a special problem to any of
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`VB Assets, LLC (“VB Assets”) filed this lawsuit asserting that Amazon.com
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`Services LLC, which I will refer to as “Amazon,” infringes four patents. Amazon has responded
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`by asserting that it does not infringe VB Assets’ patents and that the patents are invalid. Have
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`you heard anything about this case prior to today?
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`3.
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`This case involves voice-enabled speakers, such as Echo, and personal assistants
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`such as Alexa. Do you have any strong opinions about this type of technology that would make
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`it difficult for you to be a fair and impartial juror in this case?
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`4.
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`The lawyers and law firms involved in this case are listed here. Please carefully
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`review the list.
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` Ashby & Geddes, P.A.
` Fenwick & West LLP
` Smith, Katzenstein & Jenkins LLP
` Wilson Sonsini Goodrich & Rosati, P.C.
` Neal C. Belgam
` Ryan S. Benyamin
` Johnathan L. Chai
` Dargaye Churnet
` Rebecca A.E. Fewkes
` Todd R. Gregorian
` J. David Hadden
` Johnson Kuncheria
` Su Li
` Matthew Macdonald
` Melanie L. Mayer
` Andrew C. Mayo
` Steven J. Balick
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`2
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`Case 1:19-cv-01410-MN Document 276 Filed 11/03/23 Page 3 of 5 PageID #: 10892
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`
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` Jason Z. Miller
` Jamie Y. Otto
` Ravi Ranganath
` Vigen Salmastlian
` Saina S. Shamilov
` Ryan R. Smith
` Brad Tennis
` Allen Wang
` Jeffrey Ware
` Min Wu
` James C. Yoon
` Eric B. Young
` Eric Zhou
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`Do you or your immediate family members or close friends know of, have any business
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`dealings with, or have any employment or other relationship with any of these attorneys or law
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`firms?
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`list.
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`5.
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`The potential witnesses in this case are listed here. Please carefully review the
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` Larry Baldwin
` Rino Caruccio
` Frederic Deramat
` Adesh Desai
` Philippe Di Cristo
` Cassius Elston
` Tom Freeman
` Scott Hayden
` Björn Hoffmeister
` Michael Johnson
` Todd Kenck
` Mike Kennewick
` Rich Kennewick
` Vinod Krishnan
` David Meckstroth
` Rajiv Mehta
` John Peck
` David Pepper
` Joe Polifroni
` Nathaniel Polish
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`3
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`Case 1:19-cv-01410-MN Document 276 Filed 11/03/23 Page 4 of 5 PageID #: 10893
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`
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` Karthik Ramakrishnan
` Brett Reed
` Nick Siska
` Nikko Ström
` David Thomas
` Ryan Thomas
` Keith Ugone
` Kelly Vanee
` Kuansan Wang
` Matt Wong
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`Are you or is anyone in your immediate family or your close friends related to, or
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`personally acquainted with, any of those individuals?
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`6.
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`Have you or anyone in your immediate family or close friends had any
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`experience with patents, patent law, patented technology, or the United States Patent and
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`Trademark Office?
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`7.
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`Have you or any member of your immediate family or close friends ever applied
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`for or obtained a patent, copyright, and/or trademark?
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`8.
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`Do you have any opinions about patents or the patent system that would make it
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`difficult for you to be a fair and impartial juror in this case?
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`9.
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`Have you or has anyone in your immediate family or close friends been
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`employed by Amazon or any of its affiliated companies, or by VB Assets or VoiceBox?
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`10.
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`Have you or has anyone in your immediate family or close friends had any
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`business dealings with Amazon or any of its affiliated companies, VB Assets or VoiceBox, that
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`would make it difficult for you to be a fair and impartial juror in this case?
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`11.
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`Do you or does anyone in your immediate family or close friends own individual
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`stock (as opposed to holdings in ETFs or in mutual funds) in Amazon or in VB Assets or
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`VoiceBox?
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`4
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`Case 1:19-cv-01410-MN Document 276 Filed 11/03/23 Page 5 of 5 PageID #: 10894
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`12.
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`Do you have any strong feelings, positive or negative, concerning Amazon, VB
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`Assets or VoiceBox, or their products or services, that would make it difficult for you to be a fair
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`and impartial juror in this case?
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`13.
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`Do you have any formal education or training or have you worked in any of the
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`following fields: law, engineering, computer programming, computer science, software
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`development, voice assistant technology or speech processing?
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`14.
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`Have you or any member of your immediate family ever been a plaintiff, a
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`defendant, or a witness in a lawsuit?
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`15.
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`Have you or any member of your immediate family ever served as a juror in a
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`criminal or civil lawsuit?
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`16.
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`Have you or any member of your immediate family ever had any experience
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`with the legal system that would make it difficult for you to be a fair and impartial juror?
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`17.
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`This is the last question. Do you know of any other matter that you believe
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`should be called to the Court’s attention as having some bearing upon your qualifications or
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`ability to sit as a juror, or that you think may prevent you from rendering a fair and impartial
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`verdict based solely upon the evidence and my instructions as to the law?
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`5
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`
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