`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 13-919-JLH
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`))))))))))
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`ARENDI S.A.R.L.,
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`Plaintiff,
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`v.
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`GOOGLE LLC,
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`Defendant.
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`PLAINTIFF’S NOTICE OF APPEAL
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`Plaintiff Arendi S.A.R.L. respectfully submits this notice of its appeal to the United States
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`Court of Appeals for the Federal Circuit. Plaintiff appeals from the District Court’s Judgment
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`Following Verdict, D.I. 545, entered on May 10, 2023, and all interlocutory orders that gave rise
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`to that final judgment.1
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`Arendi is concurrently pursuing motions under Federal Rules of Civil Procedure 50(b) and
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`59(a). Therefore, this notice of appeal is timely under Federal Rule of Appellate Procedure
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`4(a)(1)(A) and 4(a)(4), and “becomes effective . . . when the order disposing of the last such
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`remaining motion is entered.” Fed. R. App. P. 4(a)(4)(B)(i). Arendi reserves the right to file an
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`amended notice of appeal following entry of such order. Fed. R. App. P. 4(a)(4)(B)(ii).
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`1 Appeal of this judgment includes, but is not limited to, appeal of the accompanying jury verdicts
`of non-infringement, anticipation, and obviousness, D.I. 530 & 531; the Court’s predicate Claim
`Construction Order of August 19, 2019, D.I. 144; see also D.I. 145 (memorandum opinion
`regarding claim construction); the Court’s granting of partial summary judgment against Arendi,
`D.I. 393, 394 (March 31, 2022); the Court’s denial of Arendi’s motions regarding IPR estoppel,
`e.g., D.I. 391 (March 31, 2022); Draft Trial Tr. (May 1, 2023) at 4:19-14:11; and the Court’s
`refusal to admit evidence of IPR proceedings, e.g., Trial Tr. (Apr. 24, 2023) at 37:24-39:10, Trial
`Tr. (Apr. 25, 2023) at 274:14-275:21; Trial Tr. (May 1, 2023) at 1195:15-17. Arendi reserves the
`right to raise all appropriate issues on appeal.
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`Case 1:13-cv-00919-JLH Document 567 Filed 06/09/23 Page 2 of 2 PageID #: 56900
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`As part of this notice of appeal, Plaintiff submits the required filing fee and respectfully
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`requests the district clerk to prepare the record on appeal pursuant to Federal Rule of Appellate
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`Procedure 10(a). Plaintiff will order from the reporter a transcript of such part of the proceedings
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`not already on file as the appellant considers necessary, as required by Federal Rule of Appellate
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`Procedure 10(b)(1)(A).
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`Dated: June 9, 2023
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`Of Counsel:
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`SUSMAN GODFREY LLP
`Seth Ard (pro hac vice)
`Max Straus (pro hac vice)
`Beatrice Franklin (pro hac vice)
`SUSMAN GODFREY, L.L.P.
`1301 Avenue of the Americas, 32nd Floor
`New York, New York 10019
`Tel: (212) 336-8330
`sard@susmangodfrey.com
`mstraus@susmangodfrey.com
`bfranklin@susmangodfrey.com
`
`John Lahad (pro hac vice)
`1000 Louisiana Street, Suite 5100
`Houston, TX 77002-5096
`jlahad@susmangodfrey.com
`
`Kalpana Srinivasan (pro hac vice)
`1900 Avenue of the Stars, Suite 1400
`Los Angeles, CA 90067
`ksrinivasan@susmangodfrey.com
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`Kemper Diehl (pro hac vice)
`401 Union Street, Suite 3000
`Seattle, WA 98101-3000
`kdiehl@susmangodfrey.com
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`SMITH, KATZENSTEIN & JENKINS LLP
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`/s/ Daniel Taylor
`Neal C. Belgam (No. 2721)
`Daniel Taylor (No. 6934)
`1000 West Street, Suite 1501
`Wilmington, DE 19801
`(302) 652-8400
`nbelgam@skjlaw.com
`dtaylor@skjlaw.com
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`Attorneys for Plaintiff Arendi S.A.R.L.
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`2
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