IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION

DROPBOX, INC.,

Plaintiff / Counterclaim 

Defendant,

v.

MOTION OFFENSE, LLC,

Defendant / Counterclaim 

Plaintiff.

Civil Action No. 6:20-cv-00251-ADA

JURY TRIAL DEMANDED

MOTION OFFENSE, LLC,

Plaintiff,

v.

DROPBOX, INC.,

Defendant.

Civil Action No. 6:21-cv-00758-ADA

JURY TRIAL DEMANDED

JOINT PROPOSED JURY VERDICT FORM

Motion Offense, LLC and Dropbox, Inc. jointly submit this proposed jury verdict form, 

incorporating the guidance received from the Court during an informal jury charge conference. The 

parties stipulate and agree that any objection to the verdict form, as stated by a party in its most recent 

filing with the pretrial order,

1 is preserved and not waived by the filing of this Joint Proposed Jury 

Verdict Form that incorporates guidance from the Court. The proposed verdict form begins on the next 

page. 

 1 See Dkt. 321-12 and 321-14. 

Case 6:20-cv-00251-ADA Document 368 Filed 05/19/23 Page 1 of 9
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When answering the following questions and filling out this 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 here, “Motion Offense” means Motion Offense LLC and “Dropbox” means 

“Dropbox Inc.” As used here, “’158 Patent” refers to U.S. Patent No. 10,013,158, “’052 Patent” 

refers to U.S. Patent No. 10,021,052, “’548 Patent” refers to U.S. Patent No. 10,587,548 and 

“’215 Patent” refers to U.S. Patent No. 11,044,215.

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.

Case 6:20-cv-00251-ADA Document 368 Filed 05/19/23 Page 2 of 9
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I. QUESTIONS OF INFRINGEMENT

Please answer Question 1 separately for each asserted patent claim. 

Q1. For each asserted patent claim, has Motion Offense proven by a 

preponderance of the evidence that Dropbox has infringed?

Please answer in each cell with “Yes” (for Motion Offense) or “No” (for Dropbox).

’158 patent – Claim 3

’158 patent – Claim 6

’158 patent – Claim 14

’052 patent – Claim 12

’052 patent – Claim 20

’052 patent – Claim 27

’548 patent – Claim 46

’215 patent – Claim 18

Case 6:20-cv-00251-ADA Document 368 Filed 05/19/23 Page 3 of 9
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II. QUESTIONS OF PRIORITY DATE

ANSWER QUESTION 2 FOR EACH ASSERTED CLAIM OF THE ’158 PATENT AND 

EACH ASSERTED CLAIM OF THE ’052 PATENT. 

Q2. For each asserted patent claim, has Motion Offense proven by a preponderance 

of the evidence that the claim is entitled to a priority date of September 25, 2012?

Please answer in each cell with “Yes” (for Motion Offense) or “No” (for Dropbox).

’158 patent – Claim 3

’158 patent – Claim 6

’158 patent – Claim 14

’052 patent – Claim 12

’052 patent – Claim 20

’052 patent – Claim 27

ANSWER QUESTION 2 FOR CLAIM 46 OF THE ’548 PATENT AND/OR CLAIM 18 OF 

THE ’215 PATENT ONLY IF YOU ANSWERED “YES” FOR THAT CLAIM IN 

QUESTION 1. 

Q2. For each asserted patent claim, has Motion Offense proven by a preponderance 

of the evidence that the claim is entitled to a priority date of September 25, 2012??

Please answer in each cell with “Yes” (for Motion Offense) or “No” (for Dropbox).

’548 patent – Claim 46

’215 patent – Claim 18

Case 6:20-cv-00251-ADA Document 368 Filed 05/19/23 Page 4 of 9
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III. QUESTIONS OF INVALIDITY

ANSWER QUESTION 3 FOR EACH ASSERTED CLAIM OF THE ’158 PATENT AND 

EACH ASSERTED CLAIM OF THE ’052 PATENT. 

Q3. For each asserted patent claim, has Dropbox proven by clear and convincing

evidence that the claim is invalid as anticipated or obvious in light of the prior art?

Please answer in each cell with “Yes” (for Dropbox) or “No” (for Motion Offense).

’158 patent – Claim 3

’158 patent – Claim 6

’158 patent – Claim 14

’052 patent – Claim 12

’052 patent – Claim 20

’052 patent – Claim 27

ANSWER QUESTION 3 FOR CLAIM 46 OF THE ’548 PATENT AND/OR CLAIM 18 OF 

THE ’215 PATENT ONLY IF YOU ANSWERED “YES” FOR THAT CLAIM IN 

QUESTION 1. 

Q3. For each asserted patent claim, has Dropbox proven by clear and convincing

evidence that the claim is invalid as anticipated or obvious in light of the prior art?

Please answer in each cell with “Yes” (for Dropbox) or “No” (for Motion Offense).

’548 patent – Claim 46

’215 patent – Claim 18

Case 6:20-cv-00251-ADA Document 368 Filed 05/19/23 Page 5 of 9
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IV. QUESTION OF DAMAGES (ONLY IF APPLICABLE)

IF YOU ANSWERED “NO” FOR ALL CLAIMS IN QUESTION 1 (NOT 

INFRINGED), DO NOT ANSWER QUESTION 4. PROCEED DIRECTLY TO THE 

FINAL SIGNATURE PAGE.

IF YOU ANSWERED “YES” (INFRINGED) FOR AT LEAST ONE CLAIM IN 

QUESTION 1 AND YOU FOUND ANY INFRINGED CLAIM NOT INVALID (“NO” IN 

QUESTION 3), THEN PROCEED TO QUESTION 4. 

Q4. What is the amount of reasonable royalty damages through June 30, 2022, that 

Motion Offense has proved by a preponderance of the evidence as a result of the infringement 

you found in Question No. 1?

Amount of Reasonable Royalty Damages: $______________________

PROCEED TO THE FINAL SIGNATURE PAGE.

Case 6:20-cv-00251-ADA Document 368 Filed 05/19/23 Page 6 of 9
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FINAL PAGE OF JURY VERDICT FORM

You have now reached the end of the Verdict Form and should review it to ensure it 

accurately reflects your unanimous determinations. After you have 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.

SIGNED this day of May 2023.

JURY FOREPERSON

Case 6:20-cv-00251-ADA Document 368 Filed 05/19/23 Page 7 of 9
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May 19, 2023

 /s/ Donald Puckett

Timothy Devlin (DE Bar No. 4241) 

Derek Dahlgren (pro hac vice) 

Alex Chan (Texas Bar No. 

24108051)

Donald Puckett (Texas Bar No. 

24013358)

Srikant Cheruvu (pro hac vice)

Andrew Sherman (pro hac vice)

Jedidiah Phillips (pro hac vice) 

DEVLIN LAW FIRM LLC 

1526 Gilpin Ave., 

Wilmington, DE 19806 

Telephone: (302) 449-9010 

tdevlin@devlinlawfirm.com 

ddahlgren@devlinlawfirm.com 

achan@devlinlawfirm.com 

dpuckett@devlinlawfirm.com

scheruvu@devlinlawfirm.com

asherman@devlinlawfirm.com

jphillips@devlinlawfirm.com

Attorneys for Motion Offense, LLC

Respectfully submitted,

/s/ Gregory H. Lantier

Kelly Ransom

Texas State Bar No. 24109427

KELLY HART & HALLMAN LLP

303 Colorado, Suite 2000

Austin, Texas 78701

Tel: (512) 495-6464

Kelly.ransom@kellyhart.com

Gregory H. Lantier

Amanda L. Major (pro hac vice)

WILMER CUTLER PICKERING

HALE & DORR LLP

2100 Pennsylvania Avenue

Washington DC 20037

Tel: (202) 663-6327

Tel: (202) 663-6304

gregory.lantier@wilmerhale.com

amanda.major@wilmerhale.com

Liv Herriot

WILMER CUTLER PICKERING

HALE & DORR LLP

2600 El Camino Real,

Suite 400 Palo Alto, 

California 94306 Tel: 

(650) 858-6138

liv.herriot@wilmerhale.com

Makenzi G. Herbst (pro hac

vice) Rauvin A. Johl (pro hac 

vice) Jeannette Leopold (pro 

hac vice)

WILMER CUTLER PICKERING

HALE & DORR LLP

60 State Street

Boston, MA 02109

Tel: (617) 526-6171

Tel: (617) 526-6104

Tel: (617) 526-6109

makenzi.herbst@wilmerhale.com

rauvin.johl@wilmerhale.com

jeannette.leopold@wilmerhale.com

Attorneys for Dropbox, Inc.

Case 6:20-cv-00251-ADA Document 368 Filed 05/19/23 Page 8 of 9
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CERTIFICATE OF SERVICE

I hereby certify that all counsel of record are being served with a copy of the foregoing 

document via electronic mail on May 19, 2023.

/s/ Kelly Ransom 

Kelly Ransom

Case 6:20-cv-00251-ADA Document 368 Filed 05/19/23 Page 9 of 9