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)

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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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