$VRNG $GOOG - Jury Must Disregard Google's Confusing Claptrap to Fool Jurors

Here's the actual doc:
Case 2:11-cv-00512-RAJ-TEM Document 740-1 Filed 10/24/12 Page 1 of 2 PageID# 16089
UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF VIRGINIA 
NORFOLK DIVISION 
__________________________________________ 
) 
I/P ENGINE, INC., ) 
) 
Plaintiff, ) 
v. ) Civ. Action No. 2:11-cv-512 
) 
AOL, INC. et al., ) 
) 
Defendants. ) 
__________________________________________) 
PLAINTIFF’S PROPOSED CURATIVE INSTRUCTIONS 
1. Instruction Regarding The Disney-Google Agreement 
Members of the jury, yesterday you heard counsel for Defendants ask Dr. Becker a 
number of questions during cross-examination regarding a patent license agreement between 
Disney and Google. Defendants were trying to establish that the technology of the DisneyGoogle Agreement is comparable to the technology of the patents-in-suit that I/P Engine is 
asserting against Google and the other defendants. The Court has ruled that the technology of 
the Disney-Google Agreement is not comparable to the technology of the patents-in-suit. As a 
result, the Court instructed you to disregard all testimony regarding the Disney-Google 
Agreement. You may not consider that agreement, or the amount of that agreement, for any 
purpose, including trying to determine what the appropriate royalty should be in this case. 
I want to emphasize that my instruction to you on this matter is in no way a reflection that 
Dr. Becker did anything improper. During his direct examination, Dr. Becker testified that he 
was not relying on the Disney-Google agreement because there is no evidence that the Disney 
technology is relevant to any issue in this case the questions of Defense counsel regarding the 
Case 2:11-cv-00512-RAJ-TEM Document 740-1 Filed 10/24/12 Page 1 of 2 PageID# 160891 
Disney-Google agreement were improper. The Court has therefore ruled that any evidence 
regarding the Disney technology is improper and irrelevant. 
2. Instruction Regarding Discovery of Google’s Financial Information 
You also heard counsel for Defendants ask Dr. Becker questions regarding whether he 
had asked counsel for I/P Engine for further documents or information to support his opinions 
regarding his apportionment, or whether there was a final version of PX 64, the Revenue Force 
document. After reviewing the record on this matter, the Court has found that counsel for I/P 
Engine had requested those documents and information from Google, but that Google did not 
produce to I/P Engine a final version of the Revenue Force document, PX 64, or any documents 
providing the numerical support for the slides on page 38 of that document. I instruct you that 
you may conclude, based upon the cross-examination questions asked of Dr. Becker by 
Defendants’ counsel, that Google had additional documents and information that, had they been 
produced, would have provided further support to Dr. Becker’s opinions regarding his 
apportionment.