Netflix, Inc. v. Blockbuster, Inc.

Filing 178

Attachment 4
NOTICE by Blockbuster, Inc. Final Invalidity Contentions for U.S. Patent No. 6,584,450 (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L# 13 Exhibit M# 14 Exhibit N)(Chen, Tony) (Filed on 4/11/2007)

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N etflix, Inc. v. Blockbuster, Inc. BLOCKBUSTER'S FINAL INVALIDITY CONTENTION APRIL 11, 2007 U.S. PATENT NO. 6,584,450 B1 EXHIBIT D CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Short Name 1. Yoshida Classification1 35 U.S.C. § 102/ 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 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. 6,584,450 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. 1 Dockets.Justia.com Doc. 178 Att. 4 925457_2.DOC BLOCKBUSTER'S FINAL INVALIDITY CONTENTION (U.S. PATENT NO. 6,584,450 B1) Short Name 3. Koya Classification1 35 U.S.C. § 102/ 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. § 102/ 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. § 102/ 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 11 925457_2.DOC BLOCKBUSTER'S FINAL INVALIDITY CONTENTION (U.S. PATENT NO. 6,584,450 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. § 102/ 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 11 925457_2.DOC BLOCKBUSTER'S FINAL INVALIDITY CONTENTION (U.S. PATENT NO. 6,584,450 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 practices with computer 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 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. § 102/ 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. § 102/ 35 U.S.C. § 103 17. Maxcess 35 U.S.C. § 102/ 35 U.S.C. § 103 18. Sirsi 35 U.S.C. § 102/ 35 U.S.C. § 103 EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 4 of 11 925457_2.DOC BLOCKBUSTER'S FINAL INVALIDITY CONTENTION (U.S. PATENT NO. 6,584,450 B1) Short Name 19. Auto Librarian Classification1 35 U.S.C. § 102/ 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 with subscription based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business 20. Multi-Video Article 35 U.S.C. § 102/ 35 U.S.C. § 103 21. Multi-Video Services 35 U.S.C. § 102/ 35 U.S.C. § 103 22. Multi-Video 35 U.S.C. § 103 23. Pop*Card Publications 35 U.S.C. § 102/ 35 U.S.C. § 103 24. Pop*Card Services 35 U.S.C. § 102/ 35 U.S.C. § 103 EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 5 of 11 925457_2.DOC BLOCKBUSTER'S FINAL INVALIDITY CONTENTION (U.S. PATENT NO. 6,584,450 B1) Short Name 25. Pop*Card 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 brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business 26. Video Hit Article 35 U.S.C. § 102/ 35 U.S.C. § 103 27. Video Hit Services 35 U.S.C. § 102/ 35 U.S.C. § 103 28. Video Hit 35 U.S.C. § 103 29. Cine Club Publications 35 U.S.C. § 102/ 35 U.S.C. § 103 30. Cine Club Services 35 U.S.C. § 102/ 35 U.S.C. § 103 EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 6 of 11 925457_2.DOC BLOCKBUSTER'S FINAL INVALIDITY CONTENTION (U.S. PATENT NO. 6,584,450 B1) Short Name 31. Cine Club 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 brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business Adopting brick and mortar video store rental practice with subscription based no late fee charge programs to improve item rental business Adopting subscription based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscription based no late fee practices utilized in audio book and tape rental business to improve item rental business 32. Campus Video Article 35 U.S.C. § 102/ 35 U.S.C. § 103 33. Campus Video Services 35 U.S.C. § 102/ 35 U.S.C. § 103 34. Campus Video 35 U.S.C. § 103 35. AudioQueue Publications 35 U.S.C. § 102/ 35 U.S.C. § 103 36. AudioQueue Services 35 U.S.C. § 102/ 35 U.S.C. § 103 EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 7 of 11 925457_2.DOC BLOCKBUSTER'S FINAL INVALIDITY CONTENTION (U.S. PATENT NO. 6,584,450 B1) Short Name 37. 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 subscription based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscription based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscription based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscription based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscription based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscription based no late fee practices utilized in audio and video program rental business to improve item rental business 38. BTCC 35 U.S.C. § 102/ 35 U.S.C. § 103 39. Business Training Library Web Pages 35 U.S.C. § 102/ 35 U.S.C. § 103 40. Business Training Library Services 35 U.S.C. § 102/ 35 U.S.C. § 103 41. BTL 35 U.S.C. § 103 42. BVS publications 35 U.S.C. § 102/ 35 U.S.C. § 103 EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 8 of 11 925457_2.DOC BLOCKBUSTER'S FINAL INVALIDITY CONTENTION (U.S. PATENT NO. 6,584,450 B1) Short Name 43. BVS Services Classification1 35 U.S.C. § 102/ 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 subscription based no late fee practices utilized in audio and video program rental business to improve item rental business Adopting subscription based no late fee practices utilized in audio and video program rental business to improve item rental business Adopting subscription based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscription based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscription based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscription based no late fee practices utilized in audio book and tape rental business to improve item rental business 44. BVS 35 U.S.C. § 103 45. Talking Book World Article 35 U.S.C. § 102/ 35 U.S.C. § 103 46. Talking Book World Services 35 U.S.C. § 102/ 35 U.S.C. § 103 47. TBW 35 U.S.C. § 102/ 35 U.S.C. § 103 48. Books On Tape publications 35 U.S.C. § 102/ 35 U.S.C. § 103 EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 9 of 11 925457_2.DOC BLOCKBUSTER'S FINAL INVALIDITY CONTENTION (U.S. PATENT NO. 6,584,450 B1) Short Name 49. Books On Tape services Classification1 35 U.S.C. § 102/ 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 Motivation for Combination or Modification2 Adopting subscription based no late fee practices utilized in audio book and tape rental business to improve item rental business Adopting subscription 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 50. BOT 35 U.S.C. § 102/ 35 U.S.C. § 103 51. Video Vendor 35 U.S.C. § 103 52. 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 53. TiVo 35 U.S.C. § 103 54. Netflix 35 U.S.C. § 103 EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 10 of 11 925457_2.DOC BLOCKBUSTER'S FINAL INVALIDITY CONTENTION (U.S. PATENT NO. 6,584,450 B1) Short Name 55. Any combination of references cited above Classification1 35 U.S.C. § 103 In Combination with Any combination of references cited above Motivation for Combination or Modification2 Improving item rental business EXHIBIT D: CLASSIFICATIONS, COMBINATIONS AND MOTIVATIONS (Part 1) Page 11 of 11 925457_2.DOC

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