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Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 1 of 7 PageID #: 52206
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 13-919-JLH
`
`))))))))))
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`
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`VERDICT FORM
`
`ARENDI S.A.R.L.,
`
`
`Plaintiff,
`
`
`v.
`
`GOOGLE LLC,
`
`
`Defendant.
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`
`
`Instructions: When answering the following questions and completing this Verdict
`
`Form, please follow the directions provided and follow the Jury Instructions that you have been
`
`given. Your answer to each question must be unanimous. Some of the questions contain legal
`
`terms that are defined and explained in the Jury Instructions. Please refer to the Jury Instructions if
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`you are unsure about the meaning or usage of any legal term that appears in the questions below.
`
`As used herein:
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`1. “Arendi” refers to Plaintiff Arendi S.A.R.L.;
`
`2. “Google” refers to Defendant Google LLC;
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`3. The “’843 Patent” refers to U.S. Patent No. 7,917,843.
`
`1
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`

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`Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 2 of 7 PageID #: 52207
`
`QUESTION 1:
`
`
`
`Did Arendi prove by a preponderance of the evidence that Google [Google’s proposal: directly]
`
`infringed any of the following claims of the ’843 Patent?
`
`“Yes” is a finding for Arendi.
`
`“No” is a finding for Google.
`
`
`
`Claim 23
`
`Claim 30
`
`
`
`YES
`
`NO
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`[Arendi’s Proposal:
`
`QUESTION 2:
`
`
`
`Did Google prove by clear and convincing evidence that any of the following claims of the ’843
`
`Patent are invalid?
`
`“Yes” is a finding for Google.
`
`
`
`“No” is a finding for Arendi.
`
`
`
`Claim 23
`
`Claim 30
`
`
`
`
`
`
`
`YES
`
`NO
`
`
`
`
`
`2
`
`
`
`
`
`
`
` ]
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`
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`
`

`

`Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 3 of 7 PageID #: 52208
`
`[Google’s Proposal:
`
`QUESTION 2:
`Did Google prove by clear and convincing evidence that any of the following claims of the ’843
`
`Patent are invalid as anticipated by prior art?
`
`
`
`
`
`“Yes” is a finding in favor of Google.
`
`
`
`“No” is a finding in favor of Arendi.
`
`
`
`Claim 23
`
`Claim 30
`
`
`
`
`
`YES
`
`NO
`
`
`
`
`
`
`QUESTION 3:
`Did Google prove by clear and convincing evidence that any of the following claims of the ’843
`
`Patent are invalid as obvious in view of prior art?
`
`“Yes” is a finding in favor of Google.
`
`
`
`“No” is a finding in favor of Arendi.
`
`
`
`Claim 23
`
`Claim 30
`
`
`
`
`
`YES
`
`NO
`
`
`
`
`
`3
`
`
`
`
`
`
`
` ]
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`
`
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`
`
`

`

`Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 4 of 7 PageID #: 52209
`
`[Arendi’s Proposal:
`
`Instructions: Only answer Question 3 if you:
`
` Answered “Yes” for any of the claims in Question 1; and
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` Answered “No” for one or more of those same claims in Question 2.
`
`]
`
`[Google’s Proposal:
`
`Instructions: Only answer Questions 4, 5, and 6 if you:
`
` Answered “Yes” for any of the claims in Question 1; and
`
` Answered “No” for any of those same claims in Question 2 and Question 3.
`
`Otherwise, skip and DO NOT answer Questions 4, 5, and 6 and instead please proceed directly
`
`to the final page of this Verdict Form and sign and date that page.]
`
`
`
`[Arendi’s Proposal:
`
`QUESTION 3:
`
`
`
`What sum of money has Arendi proven by a preponderance of the evidence that it is entitled to as
`
`a reasonable royalty for Google’s infringement of the ’843 Patent?
`
`]
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`
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`
`
`Answer: $ _________________________
`
`4
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`

`

`Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 5 of 7 PageID #: 52210
`
`[Google’s Proposal:
`
`QUESTION 4:
`For any infringement you found in Question 1 what is the earliest possible date of first
`
`infringement?
`
`“August 21, 2017” is a finding in favor of Arendi.
`
`“December 5, 2017” is a finding in favor of Google.
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`
`
`
`
`August 21, 2017: ___________ or December 5, 2017: _____________
`
`
`
`QUESTION 5:
`What amount of damages, if any, has Arendi proven, by a preponderance of the evidence, that it
`
`is entitled to as a reasonable royalty for Google’s infringement of the ’843 Patent?
`
`
`
`Answer: $ ______________
`
`
`QUESTION 6:
`Does the amount you have determined in response to Question No. 4 include damages for Google
`
`apps installed on Samsung devices?
`
`“Yes” is a finding in favor of Arendi.
`
`“No” is a finding in favor of Google.
`
`
`
`
`
`Yes: ______________
`
`No: ______________
`
`
`
` ]
`
`
`
`[Arendi: Arendi opposes Google’s proposed questions regarding the date of first infringement
`
`and the Samsung license, including because Arendi understood that the Court rejected them on
`
`
`
`5
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`

`

`Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 6 of 7 PageID #: 52211
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`April 28, 2023.]
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`[Google: During the 4/28/2023 hearing, the Court indicated its inclination regarding Google’s
`
`questions on the date of first infringement and the Samsung license, and asked the parties to
`
`discuss them. See 4/28 Trial Tr. (Rough) at 1117:25-1118:7. The parties discussed further but
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`have not reached agreement.]
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`
`
`
`
`QUESTION 4:
`
`
`
`[numbering to be updated as needed]
`
`Did Arendi prove by a preponderance of the evidence that Google’s infringement of any of the
`
`claims of the ’843 Patent was willful?
`
`“Yes” is a finding for Arendi.
`
`“No” is a finding for Google.
`
`Yes: _________________
`
`
`
`No: _________________
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`
`
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`6
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`
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`

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`Case 1:13-cv-00919-JLH Document 505 Filed 04/29/23 Page 7 of 7 PageID #: 52212
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`
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`You have now reached the end of the verdict form and you should review it to ensure that
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`it entirely reflects your unanimous determinations. The Foreperson should then sign the verdict
`
`form in the space below and notify the Court Security Officer that you have reached a verdict. The
`
`Foreperson should retain possession of the verdict form and bring it to the courtroom with the jury.
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`
`
`Signed: ____________________________________
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`
`
`Dated: ___________________
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`
`
`
`
`7
`
`

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