`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`
` VB ASSETS, LLC
`
` Plaintiff,
`
` v.
`
` AMAZON.COM, INC., et al.,
`
` Defendants.
`
`
`
`
`
`
`
`C.A. No. 19-1410-MN
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`
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`
`
`
`
`
`
`
`
`PLAINTIFF VB ASSETS, LLC’S MOTIONS
`FOR AN ONGOING ROYALTY, PRE-JUDGMENT INTEREST,
`POST-JUDGMENT INTEREST, AND ENHANCED DAMAGES
`
`For the reasons set forth in its Opening Brief in Support of Its Post-Trial Motions, Plaintiff
`
`VB Assets, LLC (“VB Assets”), by and through its undersigned counsel, respectfully moves as
`
`follows:
`
`1.
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`for an ongoing royalty for Amazon’s continuing patent infringement at the same
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`rate that the jury found at trial ($0.40 per net new Alexa user for the ’681 Patent;
`
`$0.22 per net new Alexa Shopping user for the ’176 and ’097 Patents; and $0.22
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`per net new Alexa Shopping purchaser for the ’703 Patent);
`
`2.
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`for pre-judgment interest at the prime rate compounded quarterly on the damages
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`owed by Amazon, including any enhanced damages awarded by the Court, and
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`post-judgment interest on the total award; and
`
`3.
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`for enhanced damages pursuant to 35 U.S.C. § 284, in the amount of a 50% increase
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`of the jury’s damages award, i.e., from $46.7 million to $70.05 million.
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`
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`Case 1:19-cv-01410-MN Document 300 Filed 12/06/23 Page 2 of 2 PageID #: 11174
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`SMITH, KATZENSTEIN & JENKINS LLP
`
`/s/ Neal C. Belgam
`Neal C. Belgam (No. 2721)
`Jason Z. Miller (No. 6310)
`1000 North West Street, Suite 1501
`Wilmington, Delaware 19801
`(302) 652-8400
`ncb@skjlaw.com
`jzm@skjlaw.com
`
`
`Attorneys for Plaintiff VB Assets, LLC
`
`Dated: December 6, 2023
`
`
`Of counsel:
`
`WILSON SONSINI GOODRICH
`& ROSATI P.C.
`
`James C. Yoon
`Ryan R. Smith
`650 Page Mill Road
`Palo Alto, CA 94304
`jyoon@wsgr.com
`rsmith@wsgr.com
`
`Matthew A. Macdonald
`953 East Third Street, Suite 100
`Los Angeles, CA 90013
`matthew.macdonald@wsgr.com
`
`Bradley T. Tennis
`1700 K Street NW, Fifth Floor
`Washington, DC 20006
`btennis@wsgr.com
`
`Mikaela E. Evans-Aziz
`One Market Plaza
`Spear Tower, Suite 3300
`San Francisco, CA 94105
`mevansaziz@wsgr.com
`
`
`
`
`2
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`
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