IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`IOENGINE, LLC,
`
`Plaintiff,
`
`v.
`
`INTERACTIVE MEDIA CORP. D/B/A
`KANGURU SOLUTIONS,
`
`Defendant.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Civil Action No. 14-1571-GMS
`
`VERDICT FORM
`
`Instructions: When answering the following.questions and filling out this Verdict Form,
`
`please follow the directions provided throughout the form. Your answer to each question must
`
`be unanimous. Please refer to the Jury Instructions for guidance on the law applicable to the
`
`subject matter covered by each question.
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2022
`Page 1 of 11
`
`
`FOR THE DISTRICT OF DELAWARE
`
`IOENGINE, LLC,
`
`Plaintiff,
`
`v.
`
`INTERACTIVE MEDIA CORP. D/B/A
`KANGURU SOLUTIONS,
`
`Defendant.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Civil Action No. 14-1571-GMS
`
`VERDICT FORM
`
`Instructions: When answering the following.questions and filling out this Verdict Form,
`
`please follow the directions provided throughout the form. Your answer to each question must
`
`be unanimous. Please refer to the Jury Instructions for guidance on the law applicable to the
`
`subject matter covered by each question.
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2022
`Page 1 of 11
`
`
`
`We, the jury, unanimously agree to the answers to the following questions and
`
`return them under the instructions of this Court as our verdict in this case:
`
`I.
`
`Infringement
`
`1.
`
`Do you find that IOENGINE has proven that it is more likely than not that the
`
`Accused IMC Products infringe the Asserted Claims of the '047 Patent?
`
`Checking "Yes" below indicates a finding for IO ENGINE.
`
`Checking "No " below indicates a finding for IMC
`
`J(
`y;
`
`,><
`
`Do the Accused IMC Products infringe Independent Claim 1 of the '047 Patent or .any of
`.the Asserted Claims that depend upon 1t (Claims 2, 7, 8, 14, 15, 21or23)?
`Product Name
`Yes (for IOENGINE)
`No (for IMC)
`x
`Defender 3000
`x
`Defender 2000
`x
`Defender Elite 300
`Defender Elite 200
`,X
`.Defender Elite 30
`Defender HDD
`Defender SSD
`Defender HDD 300
`Defender SSD 300
`Defender Basic
`Defender Basic +
`Defender Dual Trust
`DefenderV2
`Defender Elite
`
`~
`
`/C
`.x.
`x
`x
`x
`)<
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2022
`Page 2 of 11
`
`
`
`Do the Accused IMC Products infringe Independent Claim 24 of the ''047 Patent?
`Product Name
`Yes (for IOENGINE)
`No (for IMC)
`Defender 3 000
`'<
`x.
`Defender 2000
`Defender Elite 300
`x
`x
`Defender Elite 200
`x
`Defender Elite 30
`Defender HDD
`Defender SSD
`Defender HDD 300
`Defender SSD 300
`Defender Basic
`Defender Basic +
`Defender DualTrust
`DefenderV2
`Defender Elite
`
`><
`x
`x
`
`)(
`x
`
`)(
`,x
`
`;(
`
`)'<
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2022
`Page 3 of 11
`
`
`
`Do the Accused IMC Products infringe Independent Claim 27 of the '047 Patent or any
`of the Asserted Claims that depend upon it (Claim 28)?
`Product Name
`Yes (for IOENGINE)
`No (for IMC)
`x:
`Defender 3000
`Defender 2000
`Defender Elite 300
`Defender Elite 200
`Defender Elite 30
`Defender HDD
`Defender SSD
`Defender HDD 300
`Defender SSD 300
`Defender Basic
`Defender Basic +
`Defender DualTrust
`DefenderV2
`Defender Elite
`
`)(
`
`>(
`x
`>(
`
`x
`x
`x
`><.
`
`x.
`
`.>(
`><
`x
`x
`
`Please proceed to Question 2.
`
`2.
`
`If you answered "Yes" for any Accused IMC Product, has IOENGINE proven, by
`
`dear and convincing evidence, that the infringement was willful?
`
`No
`
`Please proceed to Question 3.
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2022
`Page 4 of 11
`
`
`
`Il.
`
`Validity
`
`3.
`
`Do you find that IMC has proven, by clear .and convincing evidence, that any
`
`Asserted Claim of the '047 Patent is invalid as being anticipated, and, if so, specify what prior art
`
`reference(s) IMC has proven, by clear and convincing evidence, renders the claim anticipated:
`
`Checking "Not Invalid" below indicates a finding for IOENGINE.
`
`Checking "Invalid" below indicates a finding for IMC. If you find for IMC on any claim,
`
`you must list the.specific prior art reference(s) that render that claim Anticipated.
`
`'047 Patent
`
`Not Invalid
`(for IOENGINE)
`
`Invalid
`(for IMC)
`
`(If Invalid)
`Specify What Prior Art Reference(s)
`Renders it Anticipated
`
`Claim 1
`Claim2
`Claim 7
`Claim 8
`Claim 14
`Claim 15
`Claim 21
`Claim23
`Claim 24
`Claim27
`Claim28
`
`)(
`
`>(
`
`I(
`x
`x
`"'
`x
`x
`"""
`
`")(
`
`>(
`
`Please proceed to Question 4.
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2022
`Page 5 of 11
`
`
`
`4.
`
`Do you find that IMC has proven, by clear and convincing evidence, that any
`
`Asserted Claim of the '047 Patent is invalid as obvious, and, if so, specify what prior art
`
`reference or combination of references IMC has proven, by clear and convincing evidence,
`
`renders the claim obvious:
`
`Checking "Not Invalid" below indicates a finding for IOENGINE.
`
`Checking "Invalid" below indicates a finding for IMC. Jf you find for IMC on any claim,
`
`you must list the specific prior art reference(s) that render the claim obvious.
`
`'047 ·Patent
`
`Not Invalid
`(for IOENGINE)
`
`Invalid
`(for IMC)
`
`(If Invalid)
`Specify What Prior Art Reference(s)
`Renders it Obvious
`
`Claim 1
`Claim2
`Claim 7
`Claim 8
`Claim 14
`Claim 15
`Claim 21
`Claim 23
`Claim24
`Claim 27
`Claim 28
`
`JI(
`
`.x.
`x
`
`)(
`x
`K
`;(.
`
`"'
`x
`x
`x
`
`Please proceed to Question 5.
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2022
`Page 6 of 11
`
`
`
`5.
`
`Do you find that IMC has proven, by clear and convincing evidence, that any
`
`Asserted Claim of the '047 Patent is invalid under 35 U.S.C. § 112 for any of the following
`
`reasons?
`
`A.
`
`Enablement
`
`Checldng "Not Invalid" below indicates a finding for IOENGINE.
`
`Checldng "Invalid" below indicates a finding for IMC
`
`'047 Patent
`
`Claim 1
`Claim2
`Claim 7
`Claim 8
`Claim 14
`Claim 15
`Claim 21
`Claim23
`Claim24
`Claim 27
`Claim 28
`
`Not Invalid
`(for IOENGINE)
`x
`x
`
`Invalid
`(for IMC)
`
`'>(
`x
`X'.
`)(
`
`><
`/(
`x
`x
`
`)(
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2022
`Page 7 of 11
`
`
`
`.,
`
`B. Written Description
`
`Checking "Not Invalid" below indicates a finding for IOENGINE.
`
`Checldng "Invalid" below indicates a finding for IMC
`
`'047 Patent
`
`Claim 1
`Claim2
`Claim 7
`Claim 8
`Claim 14
`Claim 15
`Claim21
`Claim 23
`Claim24
`Claim 27
`Claim28
`
`Not Invalid
`(for IOENGINE)
`x
`
`Invalid
`(for IMC)
`
`)(
`
`)<
`
`;<
`x
`x
`
`')('.
`
`)(
`
`k
`
`K
`x
`
`Please proceed to question 6.
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2022
`Page 8 of 11
`
`
`
`..
`
`Ill.
`
`Inventorship
`
`6.
`
`Do you find that IMC has proven, by clear and convincing evidence, that any
`
`individual other than Mr. McNulty made a significant contribution to the idea claimed in one or
`
`more claims of the '047 Patent?
`
`Checking "Yes" below indicates afindingfor IMC.
`
`Checking "No" below indicates afindingfor IOENGINE.
`
`- - - - -
`
`YES
`
`-~N~o __ NO
`
`Please proceed to Question 7.
`
`7.
`
`If you answered "Yes" to Question 6, indicate which individual(s) oth~r than Mr.
`
`McNulty made a significant contribution to the idea claimed in one or more claims of the '04 7
`
`Patent? - - - - - - - - - -
`
`Please proceed to question 8.
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2022
`Page 9 of 11
`
`
`
`IV. Damages
`
`8. ·
`
`If you found that any of the Accused IMC Products infringed at least one
`
`Asserted Claim of the '047 Patent, and that the infringed claim(s) was not invalid, state the
`
`amount of damages that you find IOENGINE is entitled to from IMC.
`
`Damages:
`
`$
`
`l. '1
`
`M. \ \. W''iJ
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2022
`Page 10 of 11
`
`
`
`I
`
`I
`
`For the Jury:
`
`Date
`
`i ..__ __________ _
`
`Jury Foreperson:
`
`PayPal Inc. v. IOENGINE, LLC
`IPR2019-00884 (US 8,539,047)
`Exhibit 2022
`Page 11 of 11
`
`
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