EXHIBIT 3

Case 1:20-cv-00655-LY Document 287-3 Filed 08/15/22 Page 1 of 10
IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

AUSTIN DIVISION 

VOXER, INC. and VOXER IP LLC, 

Plaintiffs, 

v. 

META PLATFORMS, INC. (F/K/A 

FACEBOOK, Inc.) and INSTAGRAM LLC, 

Defendants 

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Civil Action No. A:20-cv-00655-LY 

JURY TRIAL DEMANDED 

JOINT [PROPOSED] VERDICT FORM 

Case 1:20-cv-00655-LY Document 287-3 Filed 08/15/22 Page 2 of 10
JURY VERDICT FORM 

In answering the following questions, you are to follow the instructions I have given you 

in the Court’s jury charge. Your answers to each question must be unanimous. Some of 

the questions contain legal terms that are defined and explained in detail in the Final Jury 

Instructions. You should refer to and consider the Final Jury Instructions as you answer these 

questions in the Verdict Form. 

The Asserted Patents may be referred to as follows: 

U.S. Patent Number Shorthand Term 

10,142,270 ’270 Patent 

10,511,557 ’557 Patent 

 

Case 1:20-cv-00655-LY Document 287-3 Filed 08/15/22 Page 3 of 10
We, the jury, unanimously agree to the answers to the following questions and return 

them as our verdict in this case: 

QUESTION 1: INFRINGEMENT 

Did Voxer Inc. and Voxer IP LLC (collectively, “Voxer”) prove, by a preponderance of 

the evidence, that Meta Platforms, Inc. (formerly known as Facebook, Inc.) and Instagram LLC 

(collectively, “Facebook”) infringe one or more of the following claims of the Asserted Patents? 

 Check “Yes” or “No” for each claim. 

 “Yes” is a finding for Voxer. “No” is a finding for Facebook. 

 

Case 1:20-cv-00655-LY Document 287-3 Filed 08/15/22 Page 4 of 10
’270 Patent Facebook Live Instagram Live 

Claim 34 YES NO YES NO 

Claim 47 YES NO YES NO 

Claim 48 YES NO YES NO 

Claim 51 YES NO YES NO 

’557 Patent Facebook Live Instagram Live 

Claim 1 YES NO YES NO 

Claim 9 YES NO YES NO 

If you answered “NO” to all claims, please proceed to the final page of the Verdict Form. 

If you answered “YES” to any claim, please proceed to Question 2. 

 

Case 1:20-cv-00655-LY Document 287-3 Filed 08/15/22 Page 5 of 10
QUESTION 2: INVALIDITY

Solely with respect to the claims for which you answered “YES” in Question 1, did 

Facebook prove, by clear and convincing evidence, that the one or more of those claims of the 

below-listed patents are invalid? 

 Check “Yes” or “No” for each claim that corresponds to a “YES” answer in Question 1. 

 “Yes” is a finding for Facebook. “No” is a finding for Voxer 

’270 Patent 

Claim 34 YES ____ NO ____ 

Claim 47 YES ____ NO ____ 

Claim 48 YES ____ NO ____ 

Claim 51 YES ____ NO ____ 

’557 Patent 

Claim 1 YES ____ NO ____ 

Claim 9 YES ____ NO ____ 

If the answer for any claim is “NO”, please proceed to Question 3. Otherwise, please 

proceed to the final page of the Verdict Form. 

Case 1:20-cv-00655-LY Document 287-3 Filed 08/15/22 Page 6 of 10
’270 Patent Facebook Live Instagram Live 

Claim 34 YES NO YES NO 

Claim 47 YES NO YES NO 

Claim 48 YES NO YES NO 

Claim 51 YES NO YES NO 

’557 Patent Facebook Live Instagram Live 

Claim 1 YES NO YES NO 

Claim 9 YES NO YES NO 

Please proceed to the final page of the Verdict Form. 

Case 1:20-cv-00655-LY Document 287-3 Filed 08/15/22 Page 7 of 10
QUESTION 3(a): DAMAGES (IF APPLICABLE)

What sum of money do you find Voxer has proven it is entitled to for Facebook Inc. and 

Instagram LLC’s infringement up through the date of this verdict? 

$ . 

QUESTION 3(b)(IF APPLICABLE)

Does this number represent a running royalty or a one-time lump sum? Please check one 

only. 

 Running Royalty 

OR

 Lump sum 

Please proceed to Question 4.1

 

1

 Should the Court grant Defendants’ pending motion for summary judgement regarding willfulness, this instruction 

will be revised. 

Case 1:20-cv-00655-LY Document 287-3 Filed 08/15/22 Page 8 of 10
QUESTION 4: WILLFULNESS (IF APPLICABLE)2

If you found any patent claim infringed and not invalid under Questions 2, did Voxer 

prove, by a preponderance of the evidence, that Facebook’s infringement of that patent claim 

was willful? 

 Check “Yes” or “No” for each claim. 

 “Yes” is a finding for Voxer. “No” is a finding for Facebook. 

 

2

 Should the Court grant Defendants’ pending motion for summary judgement regarding willfulness, this question 

will be revised. 

Case 1:20-cv-00655-LY Document 287-3 Filed 08/15/22 Page 9 of 10
FINAL PAGE OF THE JURY VERDICT 

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

it accurate reflects your unanimous determinations. The jury foreperson should then sign 

and date the Verdict Form in the spaces below. Once this is done, notify the Court 

Security Officer that you have reached a verdict. The jury foreperson should keep the 

Verdict Form and bring it when the jury is brought back to the court room. 

Signed this day of , 2022. 

 Jury Foreperson 

Case 1:20-cv-00655-LY Document 287-3 Filed 08/15/22 Page 10 of 10