The only way to win this jury is to point out that the Chinese government has already deemed IDCC's patents to be valid and essential and is trying to assess penalties in an attempt to extort lower royalties for the benefit of Chinese manufacturers. Now ZTE is trying to back door the US courts saying IDCC's patents are not essential and/or not valid. As M3S argued, you can't have it both ways.
Since the Chinese decisions are in the public domain, can it be presented at the trial in Delaware? If so, the Chinese courts have already established that IDCC's patents make a perfect Chocolate Sundae.