Netflix, Inc. v. Blockbuster, Inc.
Filing
116
Attachment 4
NOTICE by Blockbuster, Inc.(a Delaware corporation), Blockbuster, Inc.(a Delaware corporation), Blockbuster, Inc.
Blockbuster's Amended Preliminary Invalidity Contentions On US Pat. No. 7024381 (Attachments: #
1 Exhibit Exhibit A#
2 Exhibit Exhibit B#
3 Exhibit Exhibit C#
4 Exhibit Exhibit D#
5 Exhibit Exhibit E#
6 Exhibit Exhibit F#
7 Exhibit Exhibit G#
8 Exhibit Exhibit H#
9 Exhibit Exhibit I#
10 Exhibit Exhibit J#
11 Exhibit Exhibit K)(Chen, Tony) (Filed on 12/20/2006)
Case 3:06-cv-02361-WHA
Document 116-5
Filed 12/20/2006
Page 1 of 7
BLOCKBUSTER'S AMENDED PRELIMINARY INVALIDITY CONTENTION
DECEMBER 20, 2006 U.S. PATENT NO. 7,024,381 B1
EXHIBIT D CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1)
Short Name 1.
Yoshida
Classification1
35 U.S.C. § 103
In Combination with
By itself or in combination with any one or more of the references cited herein
Motivation for Combination or Modification2
Adopting electronic hardware and software technologies and functional features of computer implemented video rental kiosk machines to improve item rental business Adopting electronic hardware and software technologies and functional features of computer implemented video rental kiosk machines to improve item rental business
2.
Kuriyama
35 U.S.C. § 103
By itself or in combination with any one or more of the references cited herein
1
A reference classified under 35 U.S.C. § 102 is one which Blockbuster contends to anticipate one or more claims of United States Patent No. 7,024,381 B1; and/or a reference classified under 35 U.S.C. § 103 is one which Blockbuster contends to render one or more claims of said patent obvious. 2 See also the motivations listed in Exhibits E and F.
Dockets.Justia.com
Case 3:06-cv-02361-WHA
Document 116-5
Filed 12/20/2006
Page 2 of 7
BLOCKBUSTER'S AMENDED PRELIMINARY INVALIDITY CONTENTION (U.S. PATENT NO. 7,024,381 B1)
Short Name 3.
Koya
Classification1
35 U.S.C. § 103
In Combination with
By itself or in combination with any one or more of the references cited herein
Motivation for Combination or Modification2
Adopting electronic hardware and software technologies and functional features of computer implemented video rental kiosk machines to improve item rental business Adopting electronic hardware and software technologies and functional features of computer implemented video rental kiosk machines to improve item rental business Adopting electronic hardware and software technologies and functional features of computer implemented video rental kiosk machines to improve item rental business Adopting video content storage, distribution and selection technologies used in TV broadcast systems to improve item rental business Adopting digital electronic telecommunication technologies for conducting e-commerce on the Internet to improve item rental business
4.
Crooks
35 U.S.C. § 103
By itself or in combination with any one or more of the references cited herein
5.
Isobe
35 U.S.C. § 103
By itself or in combination with any one or more of the references cited herein
6.
Bradley
35 U.S.C. § 103
By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein
7.
Morales
35 U.S.C. § 103
EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 2 of 7
Case 3:06-cv-02361-WHA
Document 116-5
Filed 12/20/2006
Page 3 of 7
BLOCKBUSTER'S AMENDED PRELIMINARY INVALIDITY CONTENTION (U.S. PATENT NO. 7,024,381 B1)
Short Name 8.
NCR
Classification1
35 U.S.C. § 103
In Combination with
By itself or in combination with any one or more of the references cited herein
Motivation for Combination or Modification2
Adopting computer implemented method for ordering and downloading resources/contents based on searching their digital profiles/attributes over a telecommunication network to improve item rental business Adopting digital electronic telecommunication technologies for conducting e-commerce on the Internet to improve item rental business Adopting digital electronic telecommunication technologies for conducting e-commerce on the Internet to improve item rental business Adopting computer hardware systems and software program technologies with user friendly features for allowing a user to make and update a list of desired and/or reserved items to improve item rental business Adopting digital electronic telecommunication technologies for conducting e-commerce on the Internet to improve item rental business
9.
Saigh
35 U.S.C. § 103
By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein
10.
Hendricks
35 U.S.C. § 103
11.
Cook
35 U.S.C. § 103
12.
Ginter
35 U.S.C. § 103
By itself or in combination with any one or more of the references cited herein
EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 3 of 7
Case 3:06-cv-02361-WHA
Document 116-5
Filed 12/20/2006
Page 4 of 7
BLOCKBUSTER'S AMENDED PRELIMINARY INVALIDITY CONTENTION (U.S. PATENT NO. 7,024,381 B1)
Short Name 13.
Fein
Classification1
35 U.S.C. § 103
In Combination with
By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein
Motivation for Combination or Modification2
Adopting video content storage, distribution and selection technologies used in TV broadcast systems to improve item rental business Adopting computer hardware systems and software program technologies with user friendly features for allowing a user to make and update a list of desired and/or reserved items to improve item rental business Adopting library practices with computer implemented subscription based no late fee book-lending programs to improve item rental business Adopting library pract ices with computer implemented subscription based no late fee book-lending programs to improve item rental business Adopting library practices with co mputer implemented subscription based no late fee book-lending programs to improve item rental business Adopting library practices with computer implemented subscription based no late fee book-lending programs to improve item rental business
14.
Leason
35 U.S.C. § 103
15.
Reference Guide
35 U.S.C. § 103
By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein
16.
Functional Requirements
35 U.S.C. § 103
17.
Maxcess
35 U.S.C. § 103
18.
Sirsi
35 U.S.C. § 103
EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 4 of 7
Case 3:06-cv-02361-WHA
Document 116-5
Filed 12/20/2006
Page 5 of 7
BLOCKBUSTER'S AMENDED PRELIMINARY INVALIDITY CONTENTION (U.S. PATENT NO. 7,024,381 B1)
Short Name 19.
Auto Librarian
Classification1
35 U.S.C. § 103
In Combination with
By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein
Motivation for Combination or Modification2
Adopting library practices with computer implemented subscription based no late fee book-lending programs to improve item rental business Adopting brick and mortar video store rental practice wit h subscript ion based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscript ion based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscript ion based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscript ion based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscript ion based no late fee charge programs to improve item rental business
20.
Multi-Video
35 U.S.C. § 103
21.
Pop*Card
35 U.S.C. § 103
22.
Video Hit
35 U.S.C. § 103
23.
Cine Club
35 U.S.C. § 103
24.
Campus Video
35 U.S.C. § 103
EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 5 of 7
Case 3:06-cv-02361-WHA
Document 116-5
Filed 12/20/2006
Page 6 of 7
BLOCKBUSTER'S AMENDED PRELIMINARY INVALIDITY CONTENTION (U.S. PATENT NO. 7,024,381 B1)
Short Name 25.
AudioQueue
Classification1
35 U.S.C. § 103
In Combination with
By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein
Motivation for Combination or Modification2
Adopting subscript ion based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscript ion based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscript ion based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscript ion based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscript ion based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscript ion based no late fee practices utilized in audio book and tape rental business to improve item rental business
26.
BTCC
35 U.S.C. § 102/ 35 U.S.C. § 103
27.
BTL Web Pages
35 U.S.C. § 102/ 35 U.S.C. § 103
28.
BTL Services
35 U.S.C. § 102/ 35 U.S.C. § 103
29.
BTL
35 U.S.C. § 103
30.
TBW
35 U.S.C. § 103
EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 6 of 7
Case 3:06-cv-02361-WHA
Document 116-5
Filed 12/20/2006
Page 7 of 7
BLOCKBUSTER'S AMENDED PRELIMINARY INVALIDITY CONTENTION (U.S. PATENT NO. 7,024,381 B1)
Short Name 31.
BOT
Classification1
35 U.S.C. § 103
In Combination with
By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein
Motivation for Combination or Modification2
Adopting subscript ion based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting computer hardware systems and software program technologies with user friendly features for allowing a user to make and update a list of desired and/or reserved items to improve item rental business Adopting telecommunication systems and computer software technologies for conducing online car rental business to improve item rental business Adopting video content storage, distribution and selection technologies used in TV broadcast systems to improve item rental business Adopting Netflix prior per-item online DVD rental business to improve item rental business Improving item rental business
32.
Video Vendor
35 U.S.C. § 103
33.
Avis
35 U.S.C. § 103
By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein By itself or in combination with any one or more of the references cited herein Any combination of references cited above
34.
TiVo
35 U.S.C. § 103
35.
Netflix
35 U.S.C. § 103
36.
Any combination of references cited above
35 U.S.C. § 103
EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 7 of 7
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