Case 1:13-cv-00919-LPS Document 324-1 Filed 03/12/21 Page 1 of 131 PageID #: 34074
`Case 1:13-cv-00919—LPS Document 324-1 Filed 03/12/21 Page 1 of 131 PageID #: 34074
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`EXHIBIT 1
`EXHIBIT 1
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`Case 1:13-cv-00919-LPS Document 324-1 Filed 03/12/21 Page 2 of 131 PageID #: 34075
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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`Plaintiff,
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`v.
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`ARENDI S.A.R.L.,
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`GOOGLE LLC
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`Defendant.
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`CONFIDENTIAL – OUTSIDE
`COUNSEL ONLY
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`Case No: 13-919-LPS
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`EXPERT REPORT OF ROY WEINSTEIN
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`CONFIDENTIAL – OUTSIDE COUNSEL ONLY
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`CONTENTS
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`V.
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`VI.
`VII.
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`CONTENTS ................................................................................................................................... i
`TABLES ........................................................................................................................................ iv
`I.
`Introduction ......................................................................................................................... 1
`II.
`Assignment ......................................................................................................................... 2
`III.
`Summary and Conclusions ................................................................................................. 3
`IV.
`Background ......................................................................................................................... 4
`A. Arendi S.A.R.L. .................................................................................................... 4
`B. Google .................................................................................................................. 4
`Patent-in-Suit ...................................................................................................................... 6
`i. U.S. Patent No. 7,917,843 .................................................................................... 6
`ii.
`Invalidity Challenges ............................................................................................ 7
`Technology Background ..................................................................................................... 8
`Infringement Contentions and Accused Products ............................................................. 10
`A. Accused Products ............................................................................................... 10
`B. Asserted Claims .................................................................................................. 11
`VIII. Analytical Framework for Damages ................................................................................. 11
`A. Hypothetical Negotiation Framework ................................................................ 12
`B. Hypothetical Negotiation between Arendi and Google ...................................... 17
`C. Damages Period .................................................................................................. 17
`Georgia-Pacific Analysis .................................................................................................. 17
`Georgia-Pacific No. 1: The royalties received by the patentee for the licensing
`of the Patent-in-Suit, proving or tending to prove an
`established royalty .................................................................. 18
`a. Microsoft Corporation ........................................................................................ 18
`b. Samsung Electronics Co. Ltd. ............................................................................ 20
`c. Microsoft Mobile, Inc. ........................................................................................ 21
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`IX.
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`Expert Report of Roy Weinstein
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`d. Conclusion .......................................................................................................... 22
`Georgia-Pacific No. 2: The rates paid by the licensee for the use of other patents
`comparable to the Patent-in-Suit ............................................. 27
`Georgia-Pacific No. 3: The nature and scope of the license, as exclusive or non-
`exclusive; or as restricted or non-restricted in terms of
`territory or with respect to whom the manufactured
`product may be sold ................................................................ 29
`Georgia-Pacific No. 4: The licensor’s established policy and marketing program
`to maintain his patent monopoly by not licensing others
`to use the invention or by granting licenses under special
`conditions designed to preserve that monopoly ...................... 30
`Georgia-Pacific No. 5: The commercial relationship between the licensor and
`licensee, such as, whether they are competitors in the
`same territory in the same line of business; or whether
`they are inventor and promoter ............................................... 30
`Georgia-Pacific No. 6: The effect of selling the patented specialty in promoting
`sales of other products of the licensee; that existing value
`of the invention to the licensor as a generator of sales of
`his non-patented items; and the extent of such derivative
`or convoyed sales .................................................................... 31
`Georgia-Pacific No. 7: The duration of the patent and the term of the license ............ 32
`Georgia-Pacific No. 8: The established profitability of the products made under
`the Patent-In-Suit, their commercial success, and their
`current popularity .................................................................... 33
`i. Established Profitability ..................................................................................... 33
`ii. Commercial Success and Current Popularity ..................................................... 34
`Georgia-Pacific No. 9: The utility and advantages of the patent property over the
`old modes or devices, if any, that had been used for
`working out similar results ...................................................... 36
`Georgia-Pacific No. 10: The nature of the patented invention; the character of the
`commercial embodiment of it as owned and produced by
`the licensor; and the benefits to those who have used the
`invention ................................................................................. 36
`i. Patented Benefits ................................................................................................ 36
`ii. Conclusions Regarding Non-Infringing Alternatives ......................................... 40
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`Georgia-Pacific No. 11: The extent to which the infringer has made use of the
`invention; and any evidence probative of the value of
`that use .................................................................................... 41
`Georgia-Pacific No. 12: The portion of the profit or of the selling price that may
`be customary in the particular business or in comparable
`businesses to allow for the use of the invention or
`analogous inventions ............................................................... 42
`Georgia-Pacific No. 13: The portion of the realizable profit that should be
`credited to the invention .......................................................... 42
`Georgia-Pacific No. 14: The opinion testimony of qualified experts ............................ 47
`Georgia-Pacific No. 15: The amount that a licensor (such as the patentee) and a
`licensee (such as the infringer) would have agreed upon
`(at the time the infringement began) if both had been
`reasonably and voluntarily trying to reach an agreement ....... 47
`i. Form of the Royalty ............................................................................................ 48
`ii. Reasonable Royalty ............................................................................................ 50
`(1) Context of the Agreements .................................................................. 50
`(2) Rates agreed to by Arendi .................................................................... 51
`(3) Rates agreed to by Google ................................................................... 53
`(4) Geographic Scope of Patent Coverage ................................................. 53
`(5) Timing and Duration of the License .................................................... 53
`(6) Established Profitability and Commercial Success .............................. 54
`(7) Licensed Technology and Patented Benefits ....................................... 55
`(8) Conclusions .......................................................................................... 55
`Quantification of Damages ............................................................................................... 59
`Summary and Conclusions ............................................................................................... 60
`Prejudgment Interest ......................................................................................................... 61
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`X.
`XI.
`XII.
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`TABLES
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`Table 1: Asserted Claims ........................................................................................................... 11
`Table 2: Unit Sales of Accused Google Devices ....................................................................... 34
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`Table 3: Downloads of Accused Google Apps ......................................................................... 35
`Table 4: Sales of Accused Google Devices ............................................................................... 41
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`Table 5: Reasonable Royalty Damages .................................................................................... 59
`Table 6: Reasonable Royalty Damages .................................................................................... 60
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`I.
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`CONFIDENTIAL – OUTSIDE COUNSEL ONLY
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`INTRODUCTION
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`1.
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`I am an economist and Managing Director at Micronomics, an economic
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`research and consulting firm located in Los Angeles, California. I have been engaged in economic
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`research and consulting for approximately 50 years.
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`2.
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`A significant portion of my professional experience has involved the
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`valuation of intellectual property and the calculation of patent infringement damages. My
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`publications dealing with intellectual property rights and the calculation of patent damages have
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`appeared in les Nouvelles, the Federal Circuit Bar Journal, the Journal of the Patent and
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`Trademark Office Society, The Journal of Law and Technology, and The Licensing Journal. I also
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`have spoken on issues relating to economics and economic theory before professional groups,
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`including the Los Angeles County Bar Association, the National Association of Attorneys General,
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`the American Bar Association, the Steering Committee of the California Society of Certified
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`Public Accountants, and the Midwest Economics Association. I have appeared as a panelist on
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`several occasions at the Annual Conference on Intellectual Property Law at Plano, Texas to speak
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`on subjects relating to the calculation of patent damages. I also was asked to speak on “Taming
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`Complex Intellectual Property Compensation Problems” at the TTI Vanguard Conference on
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`Taming Complexity in Washington, D.C., and have delivered lectures dealing with patents and
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`intellectual property at Peking University in Beijing, China and the Baruch College of City
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`University of New York.
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`3.
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`Companies with whom I have consulted on patent damages issues include
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`Intel, USAA, Ericsson, Barr Laboratories, eBay, Mitsubishi, Hynix, VirnetX, and Southern
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`California Gas Company. Prior engagements include the valuation of semiconductor patents,
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`telecommunications patents, and other intellectual property used in technology markets and high
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`technology applications.
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`4.
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`Exhibit 1 sets forth biographical information, including a list of matters in
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`which I have given testimony in the past four years, either at deposition or at trial. My billing rate
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`for work on this matter is $750 per hour. Work on this assignment has also been performed by
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`members of my staff, acting under my direction.
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`II.
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`ASSIGNMENT
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`5.
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`I have been asked by counsel for Arendi S.A.R.L. (“Arendi”) to calculate
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`damages adequate to compensate Arendi for infringement by Google LLC (“Google”) of U.S.
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`Patent No. 7,917,843 (the “’843 patent”). I understand that I also may be asked to review expert
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`reports submitted by experts retained by Google, and if appropriate, may respond to their opinions.
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`6.
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`Arendi originally brought this action against Google on May 22, 2013 in
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`U.S. District Court for the District of Delaware.1 While I understand that the infringement
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`allegations are a matter of contention, I have been asked to assume that the ’843 patent (the “Patent-
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`in-Suit”) is valid, enforceable and infringed by Google.
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`7.
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`In conducting my analysis, I have reviewed and considered the Patent-in-
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`Suit, financial information, license agreements, presentations, business records, and other
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`documents produced by Google and third parties. I also have reviewed and considered pleadings,
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`deposition testimony, written discovery, and other information furnished by counsel, and
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`independently obtained trade press, and other publicly available information. I have spoken with
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`Atle Hedløy, Dr. William Wecker, and Dr. Trevor Smedley in connection with my work on this
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`matter. A summary of information I have considered in connection with my assignment is set
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`forth at Exhibit 2.
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`Complaint, Arendi S.A.R.L. v. Google LLC, C.A. No. 13-919-LPS, May 22, 2013.
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`8.
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`My understanding is that additional discovery or other information may be
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`obtained in this case. Accordingly, the results set forth herein are subject to modification as my
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`investigation continues.
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`III.
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`SUMMARY AND CONCLUSIONS
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`9.
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`In the event that the Patent-in-Suit is found to be valid, and infringed by
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`Google, Arendi is entitled to damages adequate to compensate for infringement, but in no event
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`less than a reasonable royalty.2 In the context of litigation, a reasonable royalty typically reflects
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`the amount that a willing licensee would have agreed to pay and a willing licensor would have
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`agreed to accept for a license to the Patent—in—Suit assuming both parties had access to all relevant
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`information, had been reasonable in trying to reach an agreement, and had agreed that the Patent-
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`in—Suit is valid and infringed without a license.
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`In that connection, my analysis includes an
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`assessment of factors that would have been considered by the negotiating parties had they
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`participated in a hypothetical negotiation at the time infringement commenced.
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`10.
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`I have calculated reasonable royalty damages due Arendi on accused sales
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`and downloads of Google products.
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`11.
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`Assuming that Arendi is entitled to reasonable royalty damages based on
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`infringement of accused Google products (e.g., US. sales and downloads), liability would begin
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`on March 29, 2011, the date the ’843 patent issued.3 I have concluded that damages adequate to
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`compensate Arendi for infringement by Google are at least_ through expiration of
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`the Patent-in-Suit.
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`2
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`3
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`The Patent Act of 1952 (35 U.S.C. § 284).
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`Us. Patent No. 7.917.843.
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`12. My analysis reflects a) the amount that Arendi, as the hypothetical licensor,
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`would have been willing to accept in exchange for granting a non-exclusive license to the Patent-
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`in-Suit, and b) the amount Google would have been willing to pay given:
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`1) The Patent-in-Suit would have been understood to be valid,
`enforceable, and infringed;
`2) Google’s willingness to pay for access to intellectual
`property;
`3) the popularity of the accused products;
`4) absence of non-infringing alternatives to the Patent-in-Suit;
`and
`5) my analysis of the Georgia-Pacific Factors.
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`If asked, I am prepared to calculate pre- and post-judgment interest.
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`13.
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`IV.
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`BACKGROUND
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`A.
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`Arendi S.A.R.L.
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`14.
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`Arendi is a corporation organized under the laws of Luxembourg.4 It was
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`formed in 2009 to manage Arendi’s intellectual property.5
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`B.
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`Google
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`15.
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`Google incorporated in 1998 and its stated mission is “to organize the
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`world’s information and make it universally accessible and useful.”6 It is the largest subsidiary of
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`Alphabet Inc. (“Alphabet”), a holding company created in 2015, and Google is the only reportable
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`segment operating within Alphabet.7 Google’s products and services include various Google Web
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`Search functions; applications such as Gmail, Chrome, Hangouts Chat, Google Play, Drive, Maps,
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`Complaint, Arendi S.A.R.L., v. Google Inc., C.A. No. 13-919-LPS, May 22, 2013.
`4
`Deposition of Atle Hedløy (Arendi) October 29, 2019, pp. 158-159.
`5
`6 Google website, “About” (https://about.google/).
`Google website, “How we started and where we are today” (https://about.google/our-story/).
`Alphabet Inc. Form 10-K for the fiscal year ended December 31, 2018, pp. 3, 8, and 26.
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`7
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`and YouTube; the Android software platform; and mobile phone applications and software.8
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`Google claims that its brand is “one of the most recognized in the world.”9
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`16.
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`Google generates most of its revenue through advertising, such as
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`delivering relevant ads targeted at its users and assisting advertisers with marketing campaigns.10
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`Google also generates revenue from the sale of digital content through Google Play, sales of
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`hardware devices, and the use of its cloud services.11
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`17.
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`As of December 31, 2018, Alphabet had 98,771 employees.12 Alphabet is
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`headquartered in Mountain View, California.13 Alphabet owns and leases business space and
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`research and development facilities around the world and operates and owns data centers in the
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`U.S., Europe, South America, and Asia.14
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`18.
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`Revenue from Google’s business operations amounted to $136.2 billion for
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`its fiscal year ended December 31, 2018.15 Google had revenue of $89.9 billion and $110.4 billion
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`for the 2016 and 2017 fiscal years, respectively.16 Google accounted for at least 99.6 percent of
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`Alphabet’s total revenue for each of the 2016, 2017, and 2018 fiscal years.17
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`19.
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`Alphabet generated revenue of $90.3 billion, $110.9 billion, and $136.8
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`billion in fiscal years 2016, 2017, and 2018, respectively. It realized an operating margin of 26.3
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`Google website, “Our products” (https://about.google/products/).
`8
`Alphabet Inc. Form 10-K for the fiscal year ended December 31 2018, p. 4.
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`9 Alphabet Inc. Form 10-K for the fiscal year ended December 31 2018, p. 3.
`10 Alphabet Inc. Form 10-K for the fiscal year ended December 31 2018, pp. 4-5.
`11 Alphabet Inc. Form 10-K for the fiscal year ended December 31 2018, p. 5.
`12 Alphabet Inc. Form 10-K for the fiscal year ended December 31, 2018, p. 6.
`13 Alphabet Inc. Form 10-K for the fiscal year ended December 31, 2018, p. 20.
`14 Alphabet Inc. Form 10-K for the fiscal year ended December 31, 2018, p. 20.
`15 Alphabet Inc. Form 10-K for the fiscal year ended December 31, 2018, p. 27.
`16 Alphabet Inc. Form 10-K for the fiscal year ended December 31, 2018, p. 27.
`17 Alphabet Inc. Form 10-K for the fiscal year ended December 31, 2018, p. 27.
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`percent, 23.6 percent, and 19.2 percent during those years. A summary of Alphabet’s financial
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`performance is set forth at Exhibit 3.
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`V.
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`PATENT-IN-SUIT
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`i.
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`U.S. Patent No. 7,917,843
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`20.
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`The ’843 patent is titled “Method, Systems and Computer Readable
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`Medium for Addressing Handling from a Computer Program.”18 It issued on March 29, 2011,
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`from an application that was filed on July 29, 2008, and claims priority to an application that was
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`filed on November 10, 1998.19 It is my understanding that the ’843 patent expired on November
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`10, 2018.20
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`21.
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`The abstract of the ’843 patent states:
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`A method, system and computer readable medium for providing for
`providing a function item, such as a key, button, icon, or menu, tied
`to a user operation in a computer, whereby a single click on the
`function item in a window or program on a computer screen, or one
`single selection in a menu in a program, initiates retrieval of name
`and addresses and/or other person or company related information,
`while the user works simultaneously in another program, e.g., a
`word processor. The click on the function item initiates a program
`connected to the button to search a database or file available on or
`through the computer, containing the person, company or address
`related data, in order to look up data corresponding to what the user
`types, or partly typed, e.g., name and/or address in the word
`processor, the correct data from the database, data related to the
`typed data, e.g., the name of the person, company, or the traditional
`or electronic address, or other person, or company, or address
`related data, and alternatively the persons, companies, or addresses,
`
`
`
`18 U.S. Patent No. 7,917,843.
`19 U.S. Patent No. 7,917,843.
`20
`For U.S. patent applications filed after June 8, 1995, the patent term is typically 20 years from the filing date of
`the earliest U.S. application to which priority is claimed (excluding provisional applications). The application
`that issued as the ’843 patent was filed on July 29, 2008, however, the application for the ’843 patent claims
`priority to an application filed November 10, 1998. Hence, I understand that the ’843 patent expired on
`November 10, 2018, which is 20 years after the filing date of U.S. patent 6,323,853.
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`are displayed and possibly entered into the word processor, if such
`related data exists.21
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`ii.
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`Invalidity Challenges
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`22.
`
`The Leahy-Smith America Invents Act (“AIA”) was signed into law on
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`September 16, 2011. Among other modifications to patent law in the United States, the AIA
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`instituted a process by which the validity of issued intellectual property could be challenged.22
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`The new review process titled inter partes review (“IPR”) replaced the prior inter partes
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`reexamination method.23 The new IPR process became available one year after the AIA was
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`signed into law.24 It is my understanding that IPR is a proceeding conducted by the Patent Trial
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`and Appeal Board (“PTAB”) of the United States Patent and Trademark Office (“USPTO”) which
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`has the mandate to review the patentability of patent claims.25
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`21 U.S. Patent No. 7,917,843.
`22 McKeown, Scott, “America Invents Act To Be Enacted September 16th,” Ropes & Gray, September 13, 2011
`(https://www.patentspostgrant.com/america-invents-act-to-be-enacted-september-16th/).
`“Inter Partes Review,” United States Patent and Trademark Office website (https://www.uspto.gov/patents-
`application-process/appealing-patent-decisions/trials/inter-partes-review).
`“Inter Partes Review and Inter Partes Reexamination: More Than Just a Name Change,” McDonnell Boehnen
`Hulbert & Berghoff LLP, Fall 2013 (https://www mbhb.com/intelligence/snippets/inter-partes-review-and-
`inter-partes-reexamination-more-than-just-a-name-change).
`“Inter Partes Review and Inter Partes Reexamination: More Than Just a Name Change,” McDonnell Boehnen
`Hulbert & Berghoff LLP, Fall 2013 (https://www mbhb.com/intelligence/snippets/inter-partes-review-and-
`inter-partes-reexamination-more-than-just-a-name-change).
`24 McKeown, Scott, “Inter Partes Patent Reexamination Standard to Tighten in 30 Days,” Ropes & Gray, August
`22, 2011 (https://www.patentspostgrant.com/important-patent-reexamination-standard-to-change-in-30-days/).
`“Inter Partes Review,” United States Patent and Trademark Office website (https://www.uspto.gov/patents-
`application-process/appealing-patent-decisions/trials/inter-partes-review).
`“Please Login to PTAB,” USPTO website (https://ptab.uspto.gov/#/login).
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`23
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`25
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`23.
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`The Patent-in-Suit has been subject to IPR proceedings.26 To date, the
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`PTAB has denied an IPR petition brought by Samsung Electronics, Co. Ltd. (“Samsung”) in
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`connection with the ’843 patent.27 However, the PTAB found certain claims unpatentable in
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`connection with an IPR petition brought by Apple, Google and Motorola against the ’843 patent.28
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`The decision was reversed by the Federal Circuit.29
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`VI.
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`TECHNOLOGY BACKGROUND
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`24. Mobile devices, such as cellphones, smartphones, and the Google products
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`accused in this matter are part of our daily lives. According to statistics provider Statista, around
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`the date the ’843 patent issued in 2011, there were approximately 93 million smartphone users in
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`the United States, representing almost 30 percent of the U.S. population.30 Statista further reported
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`that by 2018 the total number of U.S. smartphone users had increased to 238 million and was
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`forecast to reach 270 million by 2022.31
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`26
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`27
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`28
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`29
`30
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`31
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`
`“Petition for Inter Partes Review Under 35 U.S.C. §§ 311-319 and 37 C.F.R. §42.100 et. seq. Patent No.
`7,917,843, Apple Inc., Google Inc., and Motorola Mobility LLC., Petitioners v. Arendi S.A.R.L. Patent
`Owner, December 2, 2013.
`“Petition for Inter Partes Review of U.S. Patent No. 7,917,843 Under 35 U.S.C. §§ 311-319 and 37 C.F.R.
`§42.100 et. seq., Samsung Electronics CO. LTD, Petitioner v. Arendi S.A.R.L. Patent Owner, July 11, 2014.
`“Decision, Denying Inter Partes and Joinder, 37 C.F.R. §§ 42.108 and 42.122(b),” Case No. IPR2014-01142,
`Patent 7,917,843, October 2, 2014.
`“Final Written Decision, 35 U.S.C. § 318(a) and 37 C.F.R. § 42.73,” Case No. IPR2014-00208, Patent
`7,917,843, June 9, 2015.
`Arendi successfully appealed portions of this decision. See: Arendi S.A.R.L. v. Apple Inc., 832 F.3d 1355 (Fed.
`Cir. 2016).
`Arendi S.A.R.L. v. Apple Inc., 832 F.3d 1355 (Fed. Cir. 2014).
`“Research Peek of the Week: Smartphone Users in the US Expected to Reach Over 270 Million by 2022,” IIA,
`(https://internetinnovation.org/general/research-peek-of-the-week-smartphone-users-in-the-us-expected-to-
`reach-over-270-million-by-2020/).
`“Research Peek of the Week: Smartphone Users in the US Expected to Reach Over 270 Million by 2022,” IIA,
`(https://internetinnovation.org/general/research-peek-of-the-week-smartphone-users-in-the-us-expected-to-
`reach-over-270-million-by-2020/).
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`Case 1:13-cv-00919-LPS Document 324-1 Filed 03/12/21 Page 15 of 131 PageID #: 34088
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`25.
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`This vast number of devices has produced an even greater number of
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`communications events, both voice and text-based, with texting and text-based interactions
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`outstripping voice as the method of choice on mobile devices. A 2015 study by Pew Research
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`Center found that 97 percent of U.S. smartphone users had sent text messages.32 Another study
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`from 2015 found that 68 percent of smartphone users use text to communicate more than voice.33
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`26.
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`It is my understanding that the ’843 patent provides readers and editors of
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`documents containing textual information a feature that allows computer programs such as
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`Chrome, Gmail, Messages, Docs, Hangouts and several others to identify and utilize textual
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`content constituting certain types of information. These categories of information can include
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`telephone numbers, email addresses, street addresses, or airline flight identifiers (i.e., flight
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`numbers). It is my understanding that the ’843 patent teaches that an input device be set up to
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`make these types of information actionable by the user. The input device may take the form, for
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`example, of a menu item, link or tappable text. When a user taps or clicks on the input device
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`associated with the identified entity, the Patent-in-Suit teaches that at least a part of the identified
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`entity be sent to a second application such as Calendar, Google Maps, Gmail, Contacts, or the
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`Phone Dialer.
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`27.
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`I further understand that the ’843 patent provides for the “linked-to” second
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`application to be used for searching an information source outside of the document such as a
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`contact database, flight information database, or map database for additional information related
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`to the highlighted information.
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`32
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`33
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`
`Smith, Aaron, “U.S. Smartphone Use in 2015,” Pew Research Center, April 1, 2015
`(https://www.pewresearch.org/internet/2015/04/01/us-smartphone-use-in-2015/).
`“Smartphone Users Spend as Much Time on Entertainment as Texting – GFK MRI Study,” GFK.com, March
`2, 2016 (https://www.businesswire.com/news/home/20160203005952/en/Smartphone-Users-Spend-Time-
`Entertainment-Texting-%E2%80%93)
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`Case 1:13-cv-00919-LPS Document 324-1 Filed 03/12/21 Page 16 of 131 PageID #: 34089
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`28.
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`It is my understanding that this search can provide additional useful
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`information, including:
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`• an image associated with a phone number in a contact database
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`the location of the address and information concerning contacts, businesses
`and landmarks associated with the address
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`flight information in transportation database.
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`Once identified, the Patent-in-Suit allows for performing an action, based
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`•
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`•
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`29.
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`in-part, on the type of information comprised in the identified text using the second information if
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`the search returns a result. Examples of these action can include:
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`• calling the contact from the contact database while displaying the image
`associated with the contact
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`• displaying a map of the area near the first address including any venue name
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`retrieving and displaying flight information.
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`•
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`INFRINGEMENT CONTENTIONS AND ACCUSED PRODUCTS
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`Accused Products
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`
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`VII.
`A.
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`30.
`
`Arendi contends that certain Google products infringe the Patent-in-Suit.34
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`The accused Google products include Nexus and Pixel smartphones, Nexus and Pixel tablets, and
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`several Google apps created for the Android operating systems. See Exhibit 4 for a list of accused
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`Google products.
`
`34
`
`
`Plaintiff’s Amended Disclosure of Supplemental Accused Products and Asserted Patents, Arendi S.A.R.L. v.
`Google LLC, C.A. No. 13-919-LPS, February 6, 2019.
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`Case 1:13-cv-00919-LPS Document 324-1 Filed 03/12/21 Page 17 of 131 PageID #: 34090
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`B.
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`Asserted Claims
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`31.
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`I understand that Arendi alleges that Google infringes the following
`
`claims.”
`
`Table l: Asserted Claims
`
`US.
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`Patent No.
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`Issue Date
`
`Asserted Claims
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`l, 8, 23, and 30
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`7,917,843
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`March 29, 2011
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`VIII. ANALYTICAL FRAMEWORK FOR