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IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALLDIVISION
`
`CIVIL ACTION NO. 2:19-CV-00395-JIRG
`
`§ §
`
`:
`§
`§
`:
`
`§ §
`
`BRIGHT DATALTD.,
`
`Plaintiff,
`
`‘
`
`y
`TTESO LT, UAB, METACLUSTERLT,
`UAB, OXYSALES, UAB,
`
`Defendants.
`
`§
`
`JURY VERDICT FORM
`
`In answering the following questions and completing this Verdict Form, you
`
`are to follow all
`
`the instructions I have given you in the Court’s Final Jury
`
`Instructions. Your answers to each question must be unanimous. Some ofthe
`
`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
`
`answerthe questions in this Verdict Form.
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, EX. 2028
`10f8
`The Data Company TechnologiesInc, v. Bright Data Ltd.
`IPR2022-00138, EX. 2028
`1 of 8
`
`

`

`Asused herein, the following terms have the following meanings:
`
`e
`
`“Bright Data” refers to Plaintiff Bright Data, Ltd. (formerly knownas
`
`Luminati NetworksLtd.)
`
`e
`
`“Oxylabs” refers collectively to Defendants Teso LT, UAB, Oxysales,
`
`UAB,and Metacluster LT, UAB.
`
`e The “’319 Patent” refers to U.S. Patent No. 10,257,319.
`
`e The “’510 Patent” refers to U.S. Patent No. 10,484,510.
`
`e The “’614 Patent” refers to U.S. Patent No. 10,469,614.
`
`e “Asserted Patents” refers collectively to the *319 Patent,
`
`the °510
`
`Patent, and the ’614 Patent.
`
`e The “Asserted Claims”refers collectively to:
`
`o Claims | and 26 of the ’319 Patent;
`
`o Claims | and 22 of the 510 Patent; and
`
`o Claims1, 11, 16, and 20 of the ’614 Patent.
`
`2
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, EX. 2028
`20f8
`The Data Company TechnologiesInc, v. Bright Data Ltd.
`IPR2022-00138, EX. 2028
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`
`

`

`IT IS VERY IMPORTANT THAT YOU FOLLOW THE
`
`INSTRUCTIONS PROVIDED IN THIS VERDICT FORM.
`
`READ THEM CAREFULLY AND
`
`ENSURE YOUR VERDICT COMPLIES WITH THEM.
`
`3
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, EX. 2028
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00138, EX. 2028
`3 of 8
`
`

`

`QUESTIONNO.1
`
`Did Bright Data prove by a preponderance of the evidence that Oxylabs infringed
`
`ANYof the Asserted Claims?
`
`Yes:
`
`Yo
`
`No:
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, EX. 2028
`40f8
`The Data Company TechnologiesInc, v. Bright Data Ltd.
`IPR2022-00138, EX. 2028
`40f8
`
`

`

`QUESTION NO.2
`
`Did Oxylabs prove by clear and convincing evidence that any of the following
`
`Asserted Claims are invalid?
`
`4 ~ 4
`
`No:
`
`Ss
`
`Y v
`
`O
`4
`
`Claim | of the ‘319 Patent
`
`Yes:
`
`Claim 26 of the ’319 Patent
`
`Yes:
`
`Claim 1 of the 510 Patent
`
`Yes:
`
`Claim 22 of the °510 Patent
`
`Yes:
`
`Claim 1 of the 614 Patent
`
`Yes:
`
`Claim 11 of the ’614 Patent
`
`Yes:
`
`Claim 16 of the ’614 Patent
`
`Yes:
`
`Claim 20 ofthe ’614 Patent
`
`No:_
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, EX. 2028
`5 of 8
`The Data Company TechnologiesInc, v. Bright Data Ltd.
`IPR2022-00138, EX. 2028
`5 of 8
`
`

`

`If you answered “No” to Question No. 1, OR “YES” to ALL Asserted Claimsin
`Question No. 2, then DO NOT answer Question No.3.
`
`Answer Question No. 3 ONLY as to any Asserted Claim that you have found
`BOTHto be infringed AND notinvalid.
`
`QUESTION NO.3
`
`Did Bright Data prove by a preponderance of the evidence that Oxylabs willfully
`
`infringed ANY of the Asserted Claims that you found were infringed?
`
`Yes: J
`
`No:
`
`6
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, EX. 2028
`6 of 8
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00138, EX. 2028
`6 of 8
`
`

`

`If you answered “No” to Question No. 1, OR “YES” to ALL Asserted Claimsin
`Question No. 2, then DO NOT answer Question No.4.
`
`Answer Question No. 4 ONLYas to any Asserted Claim that you have found
`BOTHto be infringed AND not invalid.
`
`QUESTION NO.4
`
`What sum of money, if any, has Bright Data proven by a preponderance of the
`
`evidencethatit is entitled to receive from Oxylabsaslost profits?
`
`Answerin United States Dollars and Cents,if any:
`
`s FUT $76.”ey
`
`7
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, EX. 2028
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`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00138, EX. 2028
`7 of 8
`
`

`

`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, EX. 2028
`8 of 8
`
`

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