Fujitsu Limited v. Belkin International, Inc. et al

Filing 552

VERDICT FORM. Signed by Judge Lucy H. Koh on 12/13/12. (lhklc3, COURT STAFF) (Filed on 12/13/2012)

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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FUJITSU LIMITED,

)
)
Plaintiff,
)
)
v.
)
BELKIN INTERNATIONAL, INC.; BELKIN, )
INC.; D-LINK CORPORATION; D-LINK
)
SYSTEMS, INC.; and NETGEAR, INC.,
)
)
Defendants.
)
)

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Case No.: 10-CV-03972-LHK

VERDICT FORM

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Dated: December 13, 2012

_______________________________
LUCY H. KOH
United States District Judge

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Case No: 10-CV-03972-LHK
VERDICT FORM
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When answering the following questions and filling out this Verdict Form, please follow the
directions provided throughout the form. Your answers 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.
Throughout this form, “Fujitsu” refers to Plaintiff Fujitsu Limited; “Belkin” refers to
Defendants Belkin International, Inc. and Belkin, Inc.; “D-Link Corporation” refers to
Defendant D-Link Corporation; “D-Link Systems” refers to Defendant D-Link Systems, Inc.;
and “NETGEAR” refers to Defendant NETGEAR, Inc.
We, the jury, unanimously agree to the answers to the following questions and return them
under the instructions of this Court as our verdict in this case.

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FUJITSU’S INDUCED INFRINGEMENT CLAIMS
AGAINST BELKIN, D-LINK SYSTEMS, D-LINK CORP., AND NETGEAR

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(These questions should be answered regardless of your findings with respect to the validity or
invalidity of the claims of the patent.)
1a.

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Please answer in each box with a “Y” for “yes” (for Fujitsu), or with an “N” for “no”
(for Belkin).

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For each product below, has Fujitsu proven by a preponderance of the evidence
that Belkin induced infringement of the claims below?

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Product
Belkin F5D7230 Router
Belkin F5D8230 Router
Belkin F5D6130 Router
Belkin F5D8236 Router

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1b.

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Claim 20

Claim 47

Claim 48

For each product below, has Fujitsu proven by a preponderance of the evidence
that D-Link Systems induced infringement of the claims below?
Please answer in each box with a “Y” for “yes” (for Fujitsu), or with an “N” for “no”
(for D-Link Systems).

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Product
D-Link DI-524 Router
D-Link DWL-900AP+ Access Point
D-Link DWL-1000AP Access Point
D-Link DWL-2100AP Access Point

Claim 20

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Case No: 10-CV-03972-LHK
VERDICT FORM
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Claim 47

Claim 48

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1c.

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Please answer in each box with a “Y” for “yes” (for Fujitsu), or with an “N” for “no”
(for D-Link Corporation).

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For each product below, has Fujitsu proven by a preponderance of the evidence
that D-Link Corporation induced infringement of the claims below?

Product
D-Link DI-524 Router
D-Link DWL-900AP+ Access Point
D-Link DWL-1000AP Access Point
D-Link DWL-2100AP Access Point

Claim 20

Claim 47

Claim 48

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1d.

For each product below, has Fujitsu proven by a preponderance of the evidence
that NETGEAR induced infringement of the claims below?
Please answer in each box with a “Y” for “yes” (for Fujitsu), or with an “N” for “no”
(for NETGEAR).

Product
NETGEAR WGR614 Router
NETGEAR WAB102 Access Point
NETGEAR ME102 Access Point
NETGEAR WNR834B Router

Claim 20

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Case No: 10-CV-03972-LHK
VERDICT FORM
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Claim 47

Claim 48

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DEFENDANTS’ INVALIDITY DEFENSES
(These questions should be answered regardless of your findings with respect to inducement.)

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ANTICIPATION
2a.

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For each claim below, have Defendants proven by clear and convincing evidence
that the claim is anticipated by a single prior art reference?

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Claim 2

No

(for Fujitsu)

Yes

(for Defendants)

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Claim 4

No

(for Fujitsu)

Yes

(for Defendants)

Claim 20

No

(for Fujitsu)

Yes

(for Defendants)

Claim 41

No

(for Fujitsu)

Yes

(for Defendants)

Claim 47

No

(for Fujitsu)

Yes

(for Defendants)

Claim 48

No

(for Fujitsu)

Yes

(for Defendants)

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OBVIOUSNESS

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2b.

For each claim below, have Defendants proven by clear and convincing evidence
that the claim would have been obvious to a person of ordinary skill in the art as of
April 30, 1991?

Claim 2

No

(for Fujitsu)

Yes

(for Defendants)

Claim 4

No

(for Fujitsu)

Yes

(for Defendants)

Claim 20

No

(for Fujitsu)

Yes

(for Defendants)

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Claim 41

No

(for Fujitsu)

Yes

(for Defendants)

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Claim 47

No

(for Fujitsu)

Yes

(for Defendants)

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Claim 48

No

(for Fujitsu)

Yes

(for Defendants)

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Case No: 10-CV-03972-LHK
VERDICT FORM
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DAMAGES TO FUJITSU (IF APPLICABLE)

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3.

What is the total dollar amount that Fujitsu is entitled to receive from Belkin for its
infringement of the asserted claims of the patent?

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$______________________________________.

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3a.

For the total dollar amount in your answer to Question 3, please provide the
breakdown for direct infringement by product below.

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Product
Belkin F5D7010 Card
Belkin F5D8010 Card
Belkin F5D6020 Card
Belkin F5D9013 Kit

Royalty Rate

Damages Amount

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3b.
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For the total dollar amount in your answer to Question 3, please provide the
breakdown for induced infringement by product below.

Product
Belkin F5D7230 Router
Belkin F5D8230 Router
Belkin F5D6130 Router
Belkin F5D8236 Router

Royalty Rate

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Case No: 10-CV-03972-LHK
VERDICT FORM
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Damages Amount

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$______________________________________.
4a.

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What is the total dollar amount that Fujitsu is entitled to receive from D-Link
Systems for its infringement of the asserted claims of the patent?

For the total dollar amount in your answer to Question 4, please provide the
breakdown for direct infringement by product below.

Product
D-Link DWL-G630 Card
D-Link DWL-650+ Card
D-Link DWL-650 Card
D-Link DWL-923 Kit
4b.

Royalty Rate

Damages Amount

For the total dollar amount in your answer to Question 4, please provide the
breakdown for induced infringement by product below.

Product
D-Link DI-524 Router
D-Link DWL-900AP+ Access Point
D-Link DWL-1000AP Access Point
D-Link DWL-2100AP Access Point

Royalty Rate

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Case No: 10-CV-03972-LHK
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Damages Amount

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$______________________________________.
5a.

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What is the total dollar amount that Fujitsu is entitled to receive from D-Link
Corporation for its infringement of the asserted claims of the patent?

For the total dollar amount in your answer to Question 5, please provide the
breakdown for direct infringement by product below.

Product
D-Link DWL-G630 Card
D-Link DWL-650+ Card
D-Link DWL-650 Card
D-Link DWL-923 Kit
5b.

Royalty Rate

Damages Amount

For the total dollar amount in your answer to Question 5, please provide the
breakdown for induced infringement by product below.

Product
D-Link DI-524 Router
D-Link DWL-900AP+ Access Point
D-Link DWL-1000AP Access Point
D-Link DWL-2100AP Access Point

Royalty Rate

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Case No: 10-CV-03972-LHK
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Damages Amount

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$______________________________________.
6a.

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United States District Court
For the Northern District of California

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What is the total dollar amount that Fujitsu is entitled to receive from NETGEAR for
its infringement of the asserted claims of the patent?

For the total dollar amount in your answer to Question 6, please provide the
breakdown for direct infringement by product below.

Product
NETGEAR WG511 Card
NETGEAR WAB501 Card
NETGEAR MA401 Card
NETGEAR WGB511 Kit
6b.

Royalty Rate

Damages Amount

For the total dollar amount in your answer to Question 6, please provide the
breakdown for induced infringement by product below.

Product
NETGEAR WGR614 Router
NETGEAR WAB102 Access Point
NETGEAR ME102 Access Point
NETGEAR WNR834B Router

Royalty Rate

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Case No: 10-CV-03972-LHK
VERDICT FORM
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Damages Amount

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FUJITSU’S WILLFUL INFRINGEMENT CLAIMS
AGAINST BELKIN, D-LINK SYSTEMS, D-LINK CORPORATION, AND NETGEAR

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(This question should be answered if you find any of the claims of the patent to be valid.)

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7.

Has Fujitsu proven by clear and convincing evidence that Belkin’s infringement of the
patent was willful?

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Yes

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(for Fujitsu)

No

(for Belkin)

Has Fujitsu proven by clear and convincing evidence that D-Link Systems’s
infringement of the patent was willful?

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Yes

(for Fujitsu)

No

(for D-Link Systems)

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United States District Court
For the Northern District of California

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9.

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Has Fujitsu proven by clear and convincing evidence that D-Link Corporation’s
infringement of the patent was willful?
Yes

(for Fujitsu)

No

(for D-Link Corporation)

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10.

Has Fujitsu proven by clear and convincing evidence that NETGEAR’s infringement
of the patent was willful?
Yes

(for Fujitsu)

No

(for NETGEAR)

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You have now reached the end of the verdict form and should review it to ensure it accurately
reflects your unanimous determinations. The Jury Foreperson should then sign and date the verdict
form in the spaces below and notify the Bailiff 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.

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DATED: _________________, 2012

By:___________________________
Jury Foreperson

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Case No: 10-CV-03972-LHK
VERDICT FORM
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