Interval Licensing LLC v. AOL, Inc. et al

Filing 201

DECLARATION of Edgar Sargent filed by Plaintiff Interval Licensing LLC re #192 MOTION to Sever or Dismiss for Misjoinder Pursuant to Fed R. Civ. P. 20 & 21, #193 MOTION to Sever (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5)(Sargent, Edgar)

Interval Licensing LLC v. eBay, Inc. et al

Doc. 201 Att. 2

EXHIBIT 2

Dockets.Justia.com

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Defendant: Netflix Product: Netflix Website ­ Item Page
Claim Cl i 63
A computer readable medium encoded with one or more computer programs for enabling acquisition and review of a body of information, y wherein the body of information includes a plurality of segments, each segment representing a defined set of information in the body of information, comprising:

Patent: 6 263 507 6,263,507

In the operation of its websites, Netflix makes and uses a computer readable medium encoded with one or more computer programs for enabling acquisition and review of a body of information, wherein the body of information includes a plurality of segments, each segment representing a defined set of information in the body of information.

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Defendant: Netflix Product: Netflix Website ­ Item Page
Claim Cl i 63
instructions for acquiring data representing the body of information; instructions for storing the acquired data;

Patent: 6 263 507 6,263,507

Netflix's website acquires and displays information representing the body of information. Accordingly, it is apparent that the computer readable medium comprises the recited instructions.

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13

Defendant: Netflix Product: Netflix Website ­ Item Page
Claim Cl i 63
instructions for generating a display of a first segment of the body of information from data that is part of the stored data;

Patent: 6 263 507 6,263,507

When a user visits, e.g., a movie or television program item page, Netflix generates a display of a first segment of the body of information from data that is part of the stored data, as demonstrated by the following exemplary screenshot. Accordingly, it is apparent that the computer readable medium comprises the recited instructions.

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14

Defendant: Netflix Product: Netflix Website ­ Item Page
Claim Cl i 63
instructions for comparing data representing a segment of the body of information to data representing a different segment of the body of , g information to determine whether, according to one or more predetermined criteria, the compared segments are related; and

Patent: 6 263 507 6,263,507

Netflix compares data representing a segment of the body of information (e.g., data relating to the movie or television program item being viewed) to data representing a different segment of the body of information (e.g., data related to other movie or television program items), according to one or more predetermined criteria, to determine whether the segments are related. It appears that the computer readable medium comprises the recited instructions. However, Plaintiff requires access to source code to precisely identify the comparison instructions.

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15

Defendant: Netflix Product: Netflix Website ­ Item Page
Claim Cl i 63
instructions for generating a display of a portion of, or a representation of, a second segment of the body of information from data that is part of , p y the stored data, wherein the display of the portion or representation of the second segment is generated in response to the display of a first segment to which the second segment is related.

Patent: 6 263 507 6,263,507

Netflix generates a display of a portion of, or a representation of, a second segment of th b d t ti f d t f the body of information in response to the display of a first segment of information to which the second segment is related. It appears that the computer readable medium comprises the recited instructions. However, Plaintiff requires access to source code to precisely identify the instructions that cause the display of a portion of, or representation of, a second segment to be generated in response to the display of a first segment.

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