Case 1:19-cv-01410-MN Document 289 Filed 11/08/23 Page 1 of 8 PageID #: 11103
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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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`Defendant.
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`Plaintiff,
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`v.
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`C.A. No. 19-1410 (MN)
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`VERDICT FORM
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`In answering the following questions, you are to follow the instructions I have given you
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`in the Court’s jury charge. Your answers to each question must be unanimous. Some of the
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`questions contain legal terms that are defined and explained in detail in the Final Jury Instructions.
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`You should refer to and consider the Final Jury Instructions as you answer these questions in the
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`Verdict Form.
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`VB ASSETS, LLC,
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`
`
`
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`AMAZON.COM SERVICES LLC,
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`
`
`Defendant.
`
`Plaintiff,
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`
`
`v.
`
`
`
`
`
`
`
`
`
`
`
`C.A. No. 19-1410 (MN)
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`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.
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`Case 1:19-cv-01410-MN Document 289 Filed 11/08/23 Page 2 of 8 PageID #: 11104
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`QUESTION 1: INFRINGEMENT
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`Has VB Assets proven, by a preponderance of the evidence, that Amazon infringed any of
`the following claims of the asserted patents?
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`’681 Patent
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`Claim 13
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`’703 Patent
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`Claim 25
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`’176 Patent
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`Claim 40
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`’097 Patent
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`Claim 23
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`YES
`(finding for VB Assets)
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`NO
`(finding for Amazon)
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`If you answered “YES” for any claim(s) in Question 1, proceed to Question 2. If you
`answered “NO” for every claim in Question 1, skip to Question 3.
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`2
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`Case 1:19-cv-01410-MN Document 289 Filed 11/08/23 Page 3 of 8 PageID #: 11105
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`QUESTION 2: WILLFULNESS
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`If you found any claim of the asserted patents infringed in response to Question 1, did
`VB Assets prove, by a preponderance of the evidence, that Amazon’s infringement was
`willful?
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`YES
`(finding for VB Assets)
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`’681 Patent
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`’703 Patent
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`’176 Patent
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`’097 Patent
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`Please proceed to the next question.
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`NO
`(finding for Amazon)
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`3
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`Case 1:19-cv-01410-MN Document 289 Filed 11/08/23 Page 4 of 8 PageID #: 11106
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`QUESTION 3: INVALIDITY
`A. WRITTEN DESCRIPTION
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`Did Amazon prove, by clear and convincing evidence, that the following claims of the
`asserted patents are invalid for lack of adequate written description?
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`YES
`(finding for Amazon)
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`NO
`(finding for VB Assets)
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`’681 Patent
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`Claim 13
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`’703 Patent
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`Claim 25
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`’176 Patent
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`Claim 40
`’097 Patent
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`Claim 23
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`Please proceed to the next question.
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`4
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`Case 1:19-cv-01410-MN Document 289 Filed 11/08/23 Page 5 of 8 PageID #: 11107
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`QUESTION 3: INVALIDITY (CONTINUED)
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`B.
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`OBVIOUSNESS
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`Did Amazon prove, by clear and convincing evidence, that the following claims of the
`asserted patents are invalid as obvious in light of the prior art?
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`YES
`(finding for Amazon)
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`NO
`(finding for VB Assets)
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`’681 Patent
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`Claim 13
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`’703 Patent
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`Claim 25
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`’176 Patent
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`Claim 40
`’097 Patent
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`Claim 23
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`Please proceed to the next question.
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`5
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`Case 1:19-cv-01410-MN Document 289 Filed 11/08/23 Page 6 of 8 PageID #: 11108
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`QUESTION 4: PATENT INELIGIBILITY
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`Did Amazon prove by clear and convincing evidence that, from the perspective of one of
`ordinary skill in the art, when taken individually or as an ordered combination, the following
`claims of the asserted patents only involved activities that were well-understood, routine, and
`conventional as of the time of the invention?
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`’703 Patent
`Claim 25
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`’176 Patent
`Claim 40
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`’097 Patent
`Claim 23
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`YES
`(finding for Amazon)
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`NO
`(finding for VB Assets)
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`Please proceed to the next page.
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`6
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`Case 1:19-cv-01410-MN Document 289 Filed 11/08/23 Page 7 of 8 PageID #: 11109
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`If (1) you answered “YES” for any claim in Question 1, AND (2) you answered “NO” for that
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`same claim in Questions 3A, 3B AND 4, then you should answer Question 5 regarding
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`damages. Otherwise, skip to the end of the verdict form.
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`QUESTION 5: DAMAGES
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`A. What sum of money do you find VB Assets has proven it is entitled to?
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`$
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`B.
`Did you calculate this number based on a running royalty or a one-time lump
`sum (please check only one)?
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`_____ Lump sum
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`_____ Running royalty
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`Please proceed to the final page of the verdict form.
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`7
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`Case 1:19-cv-01410-MN Document 289 Filed 11/08/23 Page 8 of 8 PageID #: 11110
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`FINAL PAGE OF THE JURY VERDICT
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`You have reached the end of the verdict form. Review the completed form to ensure that
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`it accurately reflects your unanimous determinations. All jurors should then sign and date the
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`verdict form in the space below and notify the Court Security Officer that you have reached a
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`verdict.
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`Dated:
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`Foreperson
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`Juror
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`Juror
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