Case 6:21-cv-01296-ADA Document 292-1 Filed 08/30/23 Page 1 of 7
`
`THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`IOENGINE, LLC,
`Plaintiff/Counterclaim Defendant,
`
`v.
`
`ROKU, INC.,
`Defendant/Counterclaim Plaintiff.
`
`C.A. No. 6:21-cv-01296-ADA-DTG
`
`JURY TRIAL DEMANDED
`
`PROPOSED JURY VERDICT FORM
`
`1
`
`
`
`THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`IOENGINE, LLC,
`Plaintiff/Counterclaim Defendant,
`
`v.
`
`ROKU, INC.,
`Defendant/Counterclaim Plaintiff.
`
`C.A. No. 6:21-cv-01296-ADA-DTG
`
`JURY TRIAL DEMANDED
`
`PROPOSED JURY VERDICT FORM
`
`1
`
`
`
`Case 6:21-cv-01296-ADA Document 292-1 Filed 08/30/23 Page 2 of 7
`
`Instructions: When answering the following questions and filling out this Jury Verdict
`
`Form, please follow the directions provided throughout the Form. Your answer to each question
`
`must be unanimous. Some of the questions contain legal terms that are defined and explained in
`
`detail in the Jury Instructions. Please refer to the Jury Instructions if you are unsure about the
`
`meaning or usage of any legal term that appears in the questions below.
`
`As used herein, “IOENGINE” means IOENGINE, LLC, and “Roku” means Roku, Inc. As
`
`used herein:
`
`“’819 Patent” refers to U.S. Patent No. 10,447,819.
`
`“’584 Patent” refers to U.S. Patent No. 10,972,584.
`
`The “Asserted Patents” collectively refer to the ’819 Patent and the ’584 Patent.
`
`2
`
`
`
`Case 6:21-cv-01296-ADA Document 292-1 Filed 08/30/23 Page 3 of 7
`
`We, the jury, unanimously agree to the answers to the following questions and return them
`as our verdict in this case:
`
`QUESTION 1:
`
`INFRINGEMENT
`
`[Has]1 [For each asserted patent claim, has]2 IOENGINE proven by a preponderance of the
`
`evidence that Roku has infringed [the following asserted claims of the Asserted Patents]?
`
`In answering the questions below, please check “Yes” or “No” for each listed asserted
`
`claim in the space provided.
`
`Checking “Yes” below indicates a finding for IOENGINE.
`
`Checking “No” below indicates a finding for Roku.
`
`Claim
`
`Yes
`(for IOENGINE)
`
`No
`(for Roku)
`
`’819 Patent Claim 187
`’819 Patent Claim 192
`’584 Patent Claim 10
`’584 Patent Claim 11
`’584 Patent Claim 18
`’584 Patent Claim 20
`’584 Patent Claim 26
`’584 Patent Claim 27
`’584 Patent Claim 29
`’584 Patent Claim 48
`’584 Patent Claim 60
`’584 Patent Claim 61
`
`Please continue directly to Question 2.
`
`1
`Source: Touchstream Techs., Inc. v. Google LLC, No. 6:21-cv-00569-ADA, Dkt. 247 at
`2 (W.D. Tex. July 21, 2023) (Verdict Form).
`
`2
`Source: VLSI Tech. LLC v. Intel Corp., No. 6:21-cv-00299-ADA, Dkt. 549 at 2 (W.D.
`TEx. Mar. 2, 2021) (Jury Verdict Form); MV3 Partners LLC v. Roku, Inc., No. 6:18-cv-00308-
`ADA, Dkt. 387 at 2 (W.D. Tex. Oct. 14, 2020) (Verdict Form).
`
`3
`
`
`
`Case 6:21-cv-01296-ADA Document 292-1 Filed 08/30/23 Page 4 of 7
`
`QUESTION 2:
`
`INVALIDITY
`
`Has Roku proven, by clear and convincing evidence, that the following claims of the
`
`Asserted Patents are invalid?
`
`In answering the questions below, please check “Yes” or “No” for each listed asserted
`
`claim in the space provided.
`
`Checking “No” below indicates a finding for IOENGINE.
`
`Checking “Yes” below indicates a finding for Roku.
`
`Claim
`
`No
`(for IOENGINE)
`
`Yes
`(for Roku)
`
`’819 Patent Claim 187
`’819 Patent Claim 192
`’584 Patent Claim 10
`’584 Patent Claim 11
`’584 Patent Claim 18
`’584 Patent Claim 20
`’584 Patent Claim 26
`’584 Patent Claim 27
`’584 Patent Claim 29
`’584 Patent Claim 48
`’584 Patent Claim 60
`’584 Patent Claim 61
`
`Please continue to Questions 3 and 4 only if there is at least one claim of the Asserted Patents
`for which you answered “Yes” in Question 1, and for the same claim you answered “No” in
`Question 2. Otherwise, please skip Questions 3 and 4 and go directly to the last page to sign the
`form.
`
`4
`
`
`
`Case 6:21-cv-01296-ADA Document 292-1 Filed 08/30/23 Page 5 of 7
`
`QUESTION 3:
`
`DAMAGES
`
`[What is the total amount of damages that you find IOENGINE is entitled to for Roku’s
`
`infringement of the Asserted Patent(s)?]3 [If you found that Roku infringed the Asserted Patents
`
`and that the Asserted Patents are valid, what sum of money has IOENGINE proven by a
`
`preponderance of the evidence would fairly and reasonably compensate it?]4
`
`$ _____________________________
`
`Please continue directly to Question 4.
`
`3
`Source: Touchstream Techs., Inc. v. Google LLC, No. 6:21-cv-00569-ADA, Dkt. 247 at
`2 (W.D. Tex. July 21, 2023) (Verdict Form).
`
`4
`Source: Hafeman v. LG Elecs. Inc., No. 6:21-cv-00696-ADA, Dkt. 248 at 9 (W.D. Tex.
`Apr. 28, 2023) (Verdict Form); Repeat Precision, LLC v. DynaEnergetics Europe GMBH, No.
`6:21-cv-00104-ADA, Dkt. 170 at 5 (Apr. 3, 2023) (Verdict Form); VideoShare, LLC v. Google
`LLC, No. 6:19-cv-00633-ARA, Dkt. 217 at 5 (W.D. Tex. Nov. 17, 2021) (Verdict Form).
`
`5
`
`
`
`Case 6:21-cv-01296-ADA Document 292-1 Filed 08/30/23 Page 6 of 7
`
`QUESTION 4:
`
`WILLFUL INFRINGEMENT
`
`Has IOENGINE proven by a preponderance of the evidence that Roku’s infringement was
`
`willful?
`
`Checking “Yes” below indicates a finding for IOENGINE.
`
`Checking “No” below indicates a finding for Roku.
`
`Yes (for IOENGINE) _________
`
`
`
`No (for Roku) _________
`
`Please continue directly to the next page and sign the form.
`
`6
`
`
`
`Case 6:21-cv-01296-ADA Document 292-1 Filed 08/30/23 Page 7 of 7
`
`You have now reached the end of the verdict form and should review it to ensure it
`
`accurately reflects your unanimous determinations. After you are satisfied that your unanimous
`
`answers are correctly reflected above, your Jury Foreperson should then sign and date this Verdict
`
`Form in the spaces below. Once that is done, notify the Court Security Officer that you have
`
`reached a verdict. The Jury Foreperson should retain possession of the Verdict Form and bring it
`
`when the jury is brought back into the courtroom.
`
`I certify that the jury unanimously concurs in every element of the above verdict.
`
`______________
`
`
`
`______________________________________
`
`Date
`
`
`
`Jury Foreperson
`
`7
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
