Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1:04-cv-01532-KAJ Document 151 Filed 10/O2/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
INGENIO, FILIALE DE )
LOTO··Q`UEBEC, INC., )
}
)
Plaintiff, ) Civil Action N0. 044532 (KAJ)
v· )
)
GAMELOGIC, INC. )
)
)
Defendant. )
1’LAINTlFF’S |I’ROPOSEDl VOIR DIRE
Good morning, ladies and gentlemen. I am Judge J ordan, and I will be presiding over the
trial for which ajury is about to be drawn in the case The parties are Ingenio Filiaie de Loto—
Quebec, Inc., and Ga1neLogic, inc, Briefly stated, this is a case involving allegations of patent
infringement. The defendant denies patent inhringement. The trial may last up to l0 days I
time my trials, so the attorneys will have to complete their presentations within these limits.
While it appears unlikely at this point, jury deliberations may require you to be present longer
than that number ofdays.
I am going to ask you a series of "yes or no" questions, the purpose of which is to: (E)
enable the court to determine whether or not any prospective juror should be excused for cause;
and (2) enable counsel for the parties to exercise their individualjudgment in helping to
determine the final composition of the jury. lf any of you have a "yes" answer to any of my
questions, please keep track of that in your own mind. When I have concluded asking all the
questions I will ask all those who had a "yes" to answer to any of my questions to raise their
637065%

Case 1:04-cv-01532-KAJ Document 151 Filed 10/O2/2006 Page 2 of 4
hands. Then we will call you to the bench individually to speak with you about your affirmative
response or responsesr
1, As Inientioned, this case is expected to take it} or less business days to tryr Is
there any member of the panel would be unable to sit as a juror in the case for that period of
time?
2. Do you know anything about this case'?
3h Plaintiff, Ingenio, is represented by Edmond "Ted" Johnson of the Bayarcl Firm
and Rodger Tate, Brian Buroker, and Daniel Vivareili ofthe Hunton & Williams law firm. D0
you know, or are you a client of Ted Johnson, Rodger Tate, Brian Buroker, Daniel Vivarelli, or
their law firms, The Bayard Firm and Hunton & Williams?
4,. Defendant, Gamelaogic, is represented by Richard Horwitz and David Moore of
the law firm Potter Anderson & Corroon and Gary Hnath, Goutnam Patnaik, and Timothy
Moiino of the Bingham MoCutchen law firm. Do you know, or are you a client of Richard
Horwitz, David Moore, Gary Hnath, Goutnam Patnaik, or Timothy Moline or their law firms
Potter Anderson & Corroon and Bingham McCutohen‘?
5. is any member ofthe panel related to or personally acquainted with any ofthe
parties, either the Plaintiffs, Ingenio Filiale de Loto—Quebee, or the Defendant, GameLogic?
6. Are you or any of your family members present or former employee of Ingenio or
GameLogic’?
7. Do you know any ofthe witnesses who will appear in this trial? They are:
• Jack D. Grimes
• William K, Bertram
• Nathalie Rajotte

Case 1:04-ev-01532-KAJ Document 151 Filed 10/O2/2006 Page 3 of 4
• Perry Kaye
• Dow K. Hardy
• Steven Kane
• Edward Russavage
• Christopher Brandin
• Mark Herrmann
• Martin Korn
• Jennifr Westbury
• Carla Schaefer
S. Do you have specialized training in lottery systems or Internebbased systems?
9. Do you have any knowledge about, or familiarity with lottery systems or Internet—
based systems?
10. Do any of your immediate family members work in the lottery or gaming
industry?
ll. Do you have any feelings or beliefs about patent eases in general or damages
awards that would influence your decision in a ease like this one'?
12. Would you be unable to render a fair and impartial verdict based solely upon the
evidence presented in court and under the law as presented to you?
13. Have you ever been a party in a lawsuit?
14. Have you or any member of your family ever made a claim or had a claim made
against you for patent iniringement?
I5. Have you or any member of your family ever suffered any gaming or gambling-
related issues?

Case 1:04-cv-01532-KAJ Document 151 Filed 10/O2/2006 Page 4 of 4
16. Do you lcnow of any other matter which would believe should be called to the
Court’s attention as having some bearing upon your qualifications or ability to sit as ajuror, or
which you think may prevent you from rendering a fair and impartial verdict based solely upon
the evidence and my instructions as to the law?
ADDITIONAL QUESTEONS PROPOSED BY INGENIO
l?. Have you, a member of your family, or a close friend had a problem with
gambling?
18. Do you or a member of your immediate family play the lottery more than l0
times per month?
l9r Do you or a member of your immediate family spend more than $50 per month
playing the lottery?
20. Do you hold the opinion that the government should not sponsor lotteries?
21. Is playing the lottery against your personal beliefs?
22. Have you or or any rnemlyer of your immediate family, ever invented anything?
23. Have you or or any rnember of your immediate family, ever been awarded a
United States Patent for an invention?
24, Have you ever played a lottery game where the results of the lottery were revealed
through a computer game?