`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALLDIVISION
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`CIVIL ACTION NO. 2:19-CV-00395-JIRG
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`§ §
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`:
`§
`§
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`§ §
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`BRIGHT DATALTD.,
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`Plaintiff,
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`‘
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`y
`TTESO LT, UAB, METACLUSTERLT,
`UAB, OXYSALES, UAB,
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`Defendants.
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`§
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`JURY VERDICT FORM
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`In answering the following questions and completing this Verdict Form, you
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`are to follow all
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`the instructions I have given you in the Court’s Final Jury
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`Instructions. Your answers to each question must be unanimous. Some ofthe
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`questions contain legal terms that are defined and explained in detail in the Final
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`Jury Instructions. You should refer to and consider the Final Jury Instructions as you
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`answerthe questions in this Verdict Form.
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`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, EX. 2028
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`The Data Company TechnologiesInc, v. Bright Data Ltd.
`IPR2022-00138, EX. 2028
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`Asused herein, the following terms have the following meanings:
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`e
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`“Bright Data” refers to Plaintiff Bright Data, Ltd. (formerly knownas
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`Luminati NetworksLtd.)
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`e
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`“Oxylabs” refers collectively to Defendants Teso LT, UAB, Oxysales,
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`UAB,and Metacluster LT, UAB.
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`e The “’319 Patent” refers to U.S. Patent No. 10,257,319.
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`e The “’510 Patent” refers to U.S. Patent No. 10,484,510.
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`e The “’614 Patent” refers to U.S. Patent No. 10,469,614.
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`e “Asserted Patents” refers collectively to the *319 Patent,
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`the °510
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`Patent, and the ’614 Patent.
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`e The “Asserted Claims”refers collectively to:
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`o Claims | and 26 of the ’319 Patent;
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`o Claims | and 22 of the 510 Patent; and
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`o Claims1, 11, 16, and 20 of the ’614 Patent.
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`2
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`IT IS VERY IMPORTANT THAT YOU FOLLOW THE
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`INSTRUCTIONS PROVIDED IN THIS VERDICT FORM.
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`READ THEM CAREFULLY AND
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`ENSURE YOUR VERDICT COMPLIES WITH THEM.
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`3
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`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, EX. 2028
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`QUESTIONNO.1
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`Did Bright Data prove by a preponderance of the evidence that Oxylabs infringed
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`ANYof the Asserted Claims?
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`Yes:
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`Yo
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`No:
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`The Data Company Technologies Inc. v. Bright Data Ltd.
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`QUESTION NO.2
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`Did Oxylabs prove by clear and convincing evidence that any of the following
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`Asserted Claims are invalid?
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`4 ~ 4
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`No:
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`Ss
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`Y v
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`O
`4
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`Claim | of the ‘319 Patent
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`Yes:
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`Claim 26 of the ’319 Patent
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`Yes:
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`Claim 1 of the 510 Patent
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`Yes:
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`Claim 22 of the °510 Patent
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`Yes:
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`Claim 1 of the 614 Patent
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`Yes:
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`Claim 11 of the ’614 Patent
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`Yes:
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`Claim 16 of the ’614 Patent
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`Yes:
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`Claim 20 ofthe ’614 Patent
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`No:_
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`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, EX. 2028
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`If you answered “No” to Question No. 1, OR “YES” to ALL Asserted Claimsin
`Question No. 2, then DO NOT answer Question No.3.
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`Answer Question No. 3 ONLY as to any Asserted Claim that you have found
`BOTHto be infringed AND notinvalid.
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`QUESTION NO.3
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`Did Bright Data prove by a preponderance of the evidence that Oxylabs willfully
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`infringed ANY of the Asserted Claims that you found were infringed?
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`Yes: J
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`No:
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`6
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`If you answered “No” to Question No. 1, OR “YES” to ALL Asserted Claimsin
`Question No. 2, then DO NOT answer Question No.4.
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`Answer Question No. 4 ONLYas to any Asserted Claim that you have found
`BOTHto be infringed AND not invalid.
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`QUESTION NO.4
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`What sum of money, if any, has Bright Data proven by a preponderance of the
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`evidencethatit is entitled to receive from Oxylabsaslost profits?
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`Answerin United States Dollars and Cents,if any:
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`s FUT $76.”ey
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`7
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