UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`SONY MOBILE COMMUNICATIONS (USA) INC.
`Petitioner
`
`
`
`Patent No. 6,771,290
`Issue Date: Aug. 3, 2004
`Title: COMPUTER INTERFACE METHOD AND APPARATUS WITH
`PORTABLE NETWORK ORGANIZATION SYSTEM AND TARGETED
`ADVERTISING
`__________________________________________________________________
`
`EXHIBIT
`EXCERPT FROM B.E. TECHNOLOGY, L.L.C.’S
`INITIAL INFRINGEMENT CONTENTIONS
`TO SONY MOBILE COMMUNICATIONS (USA) INC.
`
`No. IPR2014-00029
`__________________________________________________________________
`
`On the following pages is the cover pleading to B.E. Technology, L.L.C.’s
`
`
`
`Initial Infringement Contentions to Sony Mobile Communications (USA) Inc. In
`
`addition, attached as Appendix A, are excerpts from the 3980 pages of infringement
`
`contention claim charts. The excerpts have been abridged for the Board’s
`
`convenience and, where appropriate, page numbers have been relabeled pursuant to
`
`37 C.F.R. § 42.63(d)(2)(i).
`
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`SONY MOBILE COMMUNICATIONS (USA) INC.
`Petitioner
`
`
`
`Patent No. 6,771,290
`Issue Date: Aug. 3, 2004
`Title: COMPUTER INTERFACE METHOD AND APPARATUS WITH
`PORTABLE NETWORK ORGANIZATION SYSTEM AND TARGETED
`ADVERTISING
`__________________________________________________________________
`
`EXHIBIT
`EXCERPT FROM B.E. TECHNOLOGY, L.L.C.’S
`INITIAL INFRINGEMENT CONTENTIONS
`TO SONY MOBILE COMMUNICATIONS (USA) INC.
`
`No. IPR2014-00029
`__________________________________________________________________
`
`On the following pages is the cover pleading to B.E. Technology, L.L.C.’s
`
`
`
`Initial Infringement Contentions to Sony Mobile Communications (USA) Inc. In
`
`addition, attached as Appendix A, are excerpts from the 3980 pages of infringement
`
`contention claim charts. The excerpts have been abridged for the Board’s
`
`convenience and, where appropriate, page numbers have been relabeled pursuant to
`
`37 C.F.R. § 42.63(d)(2)(i).
`
`
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
`
`B.E. TECHNOLOGY, L.L.C.,
`
`Plaintiff,
`
`v.
`
`SONY MOBILE COMMUNICATIONS
`(USA) INC.,
`
`Defendant.
`
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Case No. 2:12-CV-2827 JPM tmp
`
`JURY DEMAND
`
`INITIAL INFRINGEMENT CONTENTIONS AND DOCUMENT PRODUCTION
`ACCOMPANYING INITIAL INFRINGEMENT CONTENTIONS
`
`Plaintiff B.E. Technology, L.L.C. (“Plaintiff” or “B.E.”) hereby submits to Defendant
`
`Sony Mobile Communications (USA) Inc. (“Defendant” or “Sony Mobile”) its Initial
`
`Infringement Contentions and Document Production Accompanying Initial Infringement
`
`Contentions pursuant to Local Patent Rules 3.1 and 3.2.
`
`Plaintiff makes these contentions based upon information reasonably available to it as of
`
`this date. Plaintiff has not completed its preparation of this matter for trial and discovery has not
`
`yet begun. Because Plaintiff’s investigations are ongoing and discovery is not yet complete,
`
`Plaintiff reserves the right to amend, modify, supplement, or narrow any portion of its asserted
`
`claims and infringement contentions, including, but not limited to, the identification of the claims
`
`infringed by Defendant and of the products and/or services accused of infringement. In
`
`particular, B.E. reserves the right to supplement its contentions as necessary and in accordance
`
`with this Court’s Local Rules in light of Defendant’s future document production, interrogatory
`
`answers, admissions, disclosures, fact witness testimony expert witness evidence, additional
`
`1
`
`
`
`discovery, future rulings from the Court, any amendments to the pleadings, any additional items
`
`of evidence, and/or for any other reason authorized by statute, rule, or applicable case law. B.E.
`
`similarly reserves the right to supplement its Initial Infringement Contentions to assert
`
`infringement of claims currently not addressed. B.E. further reserves the right to supplement its
`
`Initial Infringement Contentions and the associated infringement claim charts after Defendant
`
`identifies which claim elements it contends are not present in Defendant’s products and/or
`
`services, and the bases for any such contentions.
`
`I.
`
`L.P.R 3.1: INITIAL INFRINGEMENT CONTENTIONS.
`A.
`
`Identification Of Asserted Claims.
`
`Based on the information presently known and reasonably available to Plaintiff, Plaintiff
`
`identifies Claims 2-3 of U.S. Pat. No. 6,771,290 (“the ’290 Patent”) to be the Asserted Claims.
`
`These contentions of Asserted Claims are, at this stage in the proceedings, necessarily limited in
`
`the sense that Plaintiff has had limited access to information concerning the structure and
`
`function of Defendant’s products and/or services. Plaintiff therefore reserves the right to
`
`supplement these contentions as it obtains additional information concerning Defendant’s
`
`products and/or services over the course of discovery.
`
`The applicable statutory subsections of 35 U.S.C. § 271 for each of the Asserted Claims
`
`are as follows:
`
`Claims 2-3 of the ’290 Patent: 35 U.S.C. §§ 271(a).
`
`Plaintiff reserves the right to amend, modify, supplement, or narrow these contentions
`
`pursuant to Local Patent Rule 3.11 as discovery in this case proceeds.
`
`B.
`
`Identification Of Accused Instrumentalities.
`
`Based on the information presently known to B.E., without the benefit of complete
`
`discovery from Defendant, B.E. presently accuses at least (but not limited to) the following of
`
`- 2 -
`
`2
`
`
`
`Defendant’s products and/or services of infringing the Asserted Claims of the ’290 Patent: Sony
`
`Android Walkman Z MP3 Player, Sony F Series Walkman Video MP3, Sony Mix Walkman
`
`Phone, Sony Xperia J, Sony 3D Blu-ray Disc Player (BDP-S590), Sony 3D Blu-ray Disc Player
`
`(BDP-S790), Sony 3D Blu-ray Home Theater System (BDV-E390), Sony 3D Blu-ray Home
`
`Theater System (BDV-N790W), Sony 3D Blu-ray Home Theater System (BDV-N890W/Z),
`
`Sony Blu-ray Disc Player (BDP-S185), Sony Blu-ray Disc Player (BDP-S390), Sony NSX-
`
`46GT1 Google TV, Sony NSZ-GS7 Google TV, Sony NSZ-GT1 Google TV, Sony Live with
`
`Walkman, Sony PlayStation 3, Sony PlayStation Portable (including without limitation PSP-
`
`1000, PSP-2000, PSP-3000, and PSP Go (PSP-N1000)), Sony PlayStation Vita Wi-Fi, Sony
`
`PlayStation Vita 3G/Wi-Fi, Sony Reader (PRST2HBC), Sony Reader (PRST2RC), Sony Reader
`
`Pocket Edition, Sony Reader Touch Edition, Sony Reader Wi-Fi (PRS-T1BC), Sony Smart
`
`Streaming Player (SMP-N100), Sony Smart Streaming Player (SMP-N200), Sony Smart TV
`
`EX640 40”, Sony Smart TV EX640 54.6”, Sony Smart TV EX645 46”, Sony Smart TV EX645
`
`50”, Sony Smart TV EX645 60”, Sony Smart TV HX750 46”, Sony Smart TV HX750 54.6”,
`
`Sony Smart TV HX850 46”, Sony Smart TV HX850 54.6”, Sony Smart TV XBR HX950 54.6”,
`
`Sony Smart TV XBR HX950 64.5”, Sony Smart TV XBR X900 84”, Sony Tablet P, Sony Tablet
`
`S, Sony VAIO Duo 11 Ultrabooks (including without limitation SVD11213CXB and
`
`SVD11215CXB), Sony VAIO E Series Laptops (including without limitation SVE14A290X
`
`Premium, SVE14A290X Premium Plus, SVE141290X Standard, SVE141290X Enhanced,
`
`SVE151290X Standard, SVE151290X Enhanced, SVE151290X Performance, SVE171290X
`
`Standard, SVE11125CXW, SVE14125CX, SVE14A25CXS, SVE15122CX, SVE15126CXS,
`
`SVE1512KCXS), Sony VAIO L Series Desktops (including without limitation SVL241290X
`
`Standard, SVL241290X Enhanced, SVL24125CXW, SVL24127CXB), Sony VAIO S Series
`
`- 3 -
`
`3
`
`
`
`Laptops (including without limitation SVS151290X Performance, SVS151290X Enhanced,
`
`SVS151290X Standard, SVS131290X Standard, SVS13A290X Premium, SVS13A290X
`
`Premium Plus, SVS15125CXW, SVS1512EPXB, SVS1512DCXB, SVS1512GPXB,
`
`SVS13122CX, SVS13127PXB, SVS13A2APXS), Sony VAIO T Series Ultrabooks (including
`
`without limitation SVT131290X Standard, SVT131290X Enhanced, SVT141190X Standard,
`
`SVT141190X Enhanced, SVT13125CXS, SVT13128CXS, SVT14117CXS), Sony VAIO Tap
`
`20 Mobile Desktops (including without limitation SVJ202190X Standard, SVJ202190X
`
`Enhanced, SVJ20215CXW, SVJ20217CXW), Sony Xperia Active, Sony Xperia Advance, Sony
`
`Xperia Arc S, Sony Xperia Arc, Sony Xperia Go, Sony Xperia ion, Sony Xperia Mini Pro, Sony
`
`Xperia Mini, Sony Xperia miro, Sony Xperia Neo V, Sony Xperia Neo, Sony Xperia P, Sony
`
`Xperia PLAY, Sony Xperia PLAY 4G, Sony Xperia PLAY Verizon, Sony Xperia Pro, Sony
`
`Xperia Ray, Sony Xperia S, Sony Xperia SL, Sony Xperia Sola, Sony Xperia Tablet S, Sony
`
`Xperia tipo dual, Sony Xperia tipo, Sony Xperia TL, Sony Xperia U, Sony Xperia X8, Sony
`
`Xperia X10US, any other products and/or services identified in the attached Appendix A, and all
`
`reasonably similar products and/or services (“Accused Instrumentalities”). In addition, B.E.
`
`presently accuses all of Defendant’s products and/or services with the following features,
`
`software, firmware, or applications of infringing the Asserted Claims of the ’290 patent: Android
`
`Market, Google Play (including Play Store, Play Music, Play Books, Play Magazines, and Play
`
`Movies & TV), YouTube, Sony Entertainment Network (e.g., Music Unlimited and Video
`
`Unlimited), PlayStation Store, Netflix, Hulu Plus, Amazon (Prime) Instant Video, Kindle Store,
`
`Sony Reader Store, Windows Store, Xbox Video, Xbox Music, Xbox Games, and Sony Media
`
`Go (also, “Accused Instrumentalities”).
`
`- 4 -
`
`4
`
`
`
`Based on the information presently known to B.E., B.E. contends that the Asserted
`
`Claims of the ’290 Patent are infringed by the Accused Instrumentalities. B.E. believes that
`
`discovery will reveal additional Accused Instrumentalities, products, and/or services that infringe
`
`the’290 Patent, and B.E. explicitly reserves the right to amend, modify, supplement, or narrow its
`
`contentions to identify additional Accused Instrumentalities, products, and/or services pursuant
`
`to Local Patent Rule 3.11.
`
`C.
`
`Claim Chart Identifying Claim Elements Present In Accused
`Instrumentalities.
`
`Based on the information presently known to B.E., without the benefit of complete
`
`discovery from Defendant, B.E. provides the attached Appendix A (which explains how the
`
`Accused Instrumentalities and other products/services infringe each of the Asserted Claims of
`
`the ’290 Patent). B.E.’s attached Appendices are incorporated by reference as if fully set forth
`
`herein. The infringement contention charts appended hereto are exemplary and not limiting, and
`
`address the Asserted Claims without the benefit of full discovery. Any citations included in the
`
`infringement contention charts are exemplary only, and should not be construed to be limiting.
`
`In the attached Appendices containing B.E.’s infringement contention charts, B.E. has
`
`subdivided each Asserted Claim to better explain where each claim element may be found with
`
`the respective Accused Instrumentalities and other products/services. The subdivisions in the
`
`appended infringement contention charts should not be taken as an indication of the boundaries
`
`of claim elements with respect to doctrine of equivalents, or any other issue. Additionally, the
`
`Accused Instrumentalities and Defendant’s other products/services may infringe the Asserted
`
`Claims in multiple ways. B.E. reserves the right to provide an alternative claim mapping or
`
`infringement contention.
`
`- 5 -
`
`5
`
`
`
`B.E. reserves the right to amend, modify, supplement, or narrow these contentions
`
`pursuant to Local Patent Rule 3.11 as discovery in this case proceeds.
`
`D.
`
`Identification Of Direct Infringement Underlying Allegations Of Indirect
`Infringement.
`
`B.E. contends that the Asserted Claims of the ’290 Patent are directly infringed by
`
`Defendant. Defendant, without B.E.’s authority, directly infringes the Asserted Claims of the
`
`’290 Patent under 35 U.S.C. § 271(a) by making, using, offering to sell, or sell its Accused
`
`Instrumentalities and other products/services within the United States, or imports into the United
`
`States its Accused Instrumentalities and other products/services.
`
`B.E. reserves the right to amend, modify, supplement, or narrow these contentions
`
`pursuant to Local Patent Rule 3.11 as discovery in this case proceeds.
`
`E.
`
`Identification Of Elements Present Literally And Present Under The
`Doctrine Of Equivalents.
`
`Based on the information presently available to B.E., B.E. contends that each Asserted
`
`Claim is literally met in the Accused Instrumentalities and/or other Defendant products/services.
`
`At present, B.E. knows of no elements of the Asserted Claims where the doctrine of equivalents
`
`would change the infringement analysis set forth in the attached infringement claim charts.
`
`Without the benefit of the Court’s claim construction, B.E. presently believes that Defendant’s
`
`Accused Instrumentalities and other products/services literally infringe the Asserted Claims of
`
`the ’290 Patent.
`
`Regardless, B.E. also contends that each Asserted Claim is met in the Accused
`
`Instrumentalities and/or other Defendant products/services under the doctrine of equivalents.
`
`Specifically, to the extent a claim element is not met literally, it is met under the doctrine of
`
`equivalents because they perform substantially the same function, in substantially the same way,
`
`to achieve substantially the same result. To the extent that any differences are alleged to exist
`
`- 6 -
`
`6
`
`
`
`between the Asserted Claims and Defendant’s Accused Instrumentalities, products and/or
`
`services, such differences are insubstantial.
`
`Information regarding the formulations of the Accused Instrumentalities and Defendant’s
`
`products/services, and the processing conditions used to manufacture the Accused
`
`Instrumentalities and Defendant’s products/services, is either confidential or is not publically
`
`available. Following discovery regarding Defendant’s products/services, Accused
`
`Instrumentalities, and technical information relating to the Accused Instrumentalities and
`
`Defendant’s products/services, B.E. reserves the right to amend, modify, supplement, or narrow
`
`these contentions pursuant to Local Patent Rule 3.11 as discovery in this case proceeds.
`
`Moreover, because discovery has not yet commenced, B.E. reserves the right to further apply the
`
`doctrine of equivalents to each and every Asserted Claim element after full discovery from
`
`Defendant, or as appropriate in response to the Court’s legal determination of issues, including,
`
`without limitation, the construction of the Asserted Claims.
`
`Should Defendant contend that any element or limitation of the Asserted Claims are
`
`absent in an Accused Instrumentality and/or Defendant’s products/services, B.E. reserves the
`
`right to demonstrate that the allegedly missing element or limitation is present in the Accused
`
`Instrumentality and/or Defendant’s products/services under the doctrine of equivalents.
`
`F.
`
`Identification Of Priority Date.
`
`The ’290 patent was filed on July 16, 1999, claiming priority from Continuation-in-Part
`
`of U.S. Patent Application No. 09/118,351, filed July 17, 1998, now U.S. Patent No. 6,141,010.
`
`Thus, the ’290 Patent and each asserted claim are entitled to a priority date of at least as early as
`
`July 17, 1998. B.E. reserves the right to present evidence that the ’290 Patent is entitled to an
`
`earlier priority date based on an earlier conception of the claimed inventions and an earlier
`
`diligent reduction to practice.
`
`- 7 -
`
`7
`
`
`
`G. Willful Infringement.
`
`Based on the information presently known to B.E., without the benefit of complete
`
`discovery from Defendant, B.E. contends that Defendant willfully infringed the ’290 Patent
`
`beginning no later than September 2012 when B.E. filed its Complaint for Patent Infringement
`
`against Defendant. Plaintiff believes that discovery will reveal that Defendant was aware of the
`
`’290 Patent long before September 2012, but Defendant nevertheless proceeded with its
`
`infringing conduct. At all times when Defendant was aware of the ’290 Patent, Defendant
`
`undertook no efforts to design its products/services around the ’290 Patent to avoid infringement
`
`despite Defendant’s knowledge and understanding that its products/services infringe these
`
`patents.
`
`As such, Defendant proceeded with the infringing conduct with knowledge of the ’290
`
`Patent. Moreover, Defendant proceeded in the face of an unjustifiably high risk that it was
`
`infringing the claims of valid and enforceable ’290 Patent.
`
`Moreover, Defendant cannot formulate a credible defense based on non-infringement.
`
`Because Defendant is very familiar with the formulations of the Accused Instrumentalities and
`
`its other products/services, as well as the method of manufacturing the Accused Instrumentalities
`
`and Defendant’s other products/services, Defendant is aware that each and every element of each
`
`Asserted Claim of the ’290 Patent is present in the Accused Instrumentalities and Defendant’s
`
`other products/services. Defendant cannot articulate a convincing non-infringement argument.
`
`Given the facts and circumstances available prior to and during Defendant’s infringing
`
`actions, a reasonable person in Defendant’s position would have appreciated a high likelihood
`
`that acting in Defendant’s manner would infringe the ’290 Patent. Furthermore, Defendant knew
`
`or should have known of the unjustifiably high risk that it was infringing the ’290 Patent, which
`
`is valid and enforceable.
`
`- 8 -
`
`8
`
`
`
`II.
`
`L.P.R. 3.2: DOCUMENT PRODUCTION ACCOMPANYING INITIAL
`INFRINGEMENT CONTENTIONS.
`A.
`
`Disclosure, Transfer, Sale, Offers To Sell Claimed Invention.
`
`Based on the information presently known to B.E., B.E. is not aware of any responsive,
`
`relevant, non-privileged, non-immune documents that correspond to this category. B.E. reserves
`
`the right to supplement this disclosure if, and as, warranted.
`
`B.
`
`Conception And Reduction To Practice.
`
`Based on the information presently known to B.E., B.E. refers Defendant to the
`
`documents produced in conjunction with the service of this disclosure and identified by Bates
`
`production numbers BE00000001-BE00002165, BE00002779-BE00002870.
`
`C.
`
`File Histories.
`
`Based on the information presently known to B.E., B.E. refers Defendant to the file
`
`histories produced in conjunction with the service of this disclosure and identified by Bates
`
`production numbers BE00002166-BE00002778.
`
`D.
`
`Ownership.
`
`Based on the information presently known to B.E., B.E. refers Defendant to the
`
`assignment records produced in conjunction with the service of this disclosure and identified by
`
`Bates production numbers BE00002871-BE00002873.
`
`Dated: January 7, 2013
`
`
`
`
`Respectfully submitted,
`
`
`
`
`s/Craig R. Kaufman
`Robert E. Freitas (CA Bar No. 80948)
`Craig R. Kaufman (CA Bar No. 159458)
`James Lin (CA Bar No. 241472)
`Qudus B. Olaniran (CA Bar No. 267838)
`FREITAS TSENG & KAUFMAN LLP
`100 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`Telephone: (650) 593-6300
`Facsimile: (650) 593-6301
`
`- 9 -
`
`9
`
`
`
`rfreitas@ftklaw.com
`ckaufman@ftklaw.com
`jlin@ftklaw.com
`qolaniran@ftklaw.com
`
`
`Richard M. Carter (TN B.P.R. #7285)
`Adam C. Simpson (TN B.P.R. #24705)
`MARTIN, TATE, MORROW & MARSTON, P.C.
`6410 Poplar Avenue, Suite 1000
`Memphis, TN 38119-4839
`Telephone: (901) 522-9000
`Facsimile: (901) 527-3746
`rcarter@martintate.com
`asimpson@martintate.com
`
`Attorneys for Plaintiff B.E. Technology, L.L.C.
`
`
`
`
`
`- 10 -
`
`10
`
`
`
`CERTIFICATE OF SERVICE
`I hereby certify that on this 7th day of January, 2013, a copy of the foregoing was
`served upon the following counsel by email:
`
`Glen G. Reid, Jr.
`Mark Vorder-Bruegge, Jr.
`WYATT, TARRANT & COMBS, LLP
`1715 Aaron Brenner Drive, Suite 800
`Memphis, TN 38120-4367
`Phone: 901.537.1000
`Facsimile: 901.537.1010
`greid@wyattfirm.com
`mvorder-bruegge@wyattfirm.com
`
`Counsel for Defendant SONY MOBILE COMMUNICATIONS (USA) INC.
`
`s/ Elizabeth Kim
`Elizabeth Kim
`
`
`
`
`
`
`
`
`
`
`
`- 11 -
`
`11
`
`
`
`APPENDIX A
`
`APPENDIX A
`
`12
`
`
`
`1
`
`
`
`
`
`movies, apps, games) in the user’s library in the server.
`that provide links to one or more files (e.g., music files, books, magazines, TV shows,
`WiFi or Ethernet. The user’s user profile in the server contains one or more user links
`his or her user profile stored in a server accessible via a network using, for example,
`Google Account, Amazon (Prime) Instant Video Account, or Netflix Account to access
`user may use his or her Sony Entertainment Network Account, Hulu Plus Account,
`Google Account, Amazon (Prime) Instant Video Account, and Netflix Account. The
`Sony Entertainment Network (formerly known as Qriocity) Account, Hulu Plus Account,
`For example, a user of a Sony Smart Streaming Player (SMP-N100) is provided with a
`
`of the files in the user library.
`more files and the user profile containing at least one user link that provides a link to one
`library for each of a number of different users, with the user library containing one or
`accessible by the accused device via a network, the server storing a user profile and user
`readable memory for use by the accused device in conjunction with a server that is
`The accused device is a client computer. The accused device includes a computer-
`Sony Smart Streaming Player (SMP-N100)
`
`
`
`readable memory comprising:
`files in the user library, the computer
`user link that provides a link to one of the
`the user profile containing at least one
`library containing one or more files and
`number of different users, with the user
`a user profile and user library for each of a
`computer via a network, the server storing
`server that is accessible by the client
`by a client computer in conjunction with a
`2. A computer-readable memory for use
`Claim
`
`Sony Smart Streaming Player (SMP-N100)
`
`-vs.-
`
`U.S. Patent No. US 6,771,290 B1 (Hoyle)
`
`13
`
`
`
`2
`
`
`
`
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`14
`
`
`
`3
`
`
`
`http://www.sonyentertainmentnetwork.com/video-unlimited/
`
`
`
`
`
`
`
`http://www.sonyentertainmentnetwork.com/music-unlimited/why-music-unlimited/
`
`
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`15
`
`
`
`4
`
`
`
`61253#overview
`1&searchType=search&storeId=10151&catalogId=10551&productId=81985529216662
`http://store.sony.com/webapp/wcs/stores/servlet/ProductDisplay?langId=-
`
`
`
`
`
`
`
`
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`16
`
`
`
`5
`
`
`
`because they perform substantially the same function, in substantially the same way, to
`To the extent this element is not met literally, it is met under the doctrine of equivalents
`
`
`
`61253#overview
`1&searchType=search&storeId=10151&catalogId=10551&productId=81985529216662
`http://store.sony.com/webapp/wcs/stores/servlet/ProductDisplay?langId=-
`
`
`
`
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`17
`
`
`
`6
`
`
`
`
`
`device.
`The Sony Smart Streaming Player (SMP-N100) includes a non-volatile data storage
`
`a) a non-volatile data storage device;
`
`
`
`and/or services, such differences are insubstantial.
`exist between the claim element and Defendant’s Accused Instrumentalities, products
`achieve substantially the same result. To the extent that any differences are alleged to
`Sony Smart Streaming Player (SMP-N100)
`
`
`
`Claim
`
`18
`
`
`
`7
`
`
`
`computer-readable format.
`(Prime) Instant Video, or Netflix, stored on said non-volatile data storage device in a
`Network (e.g., Music Unlimited and Video Unlimited), Hulu Plus, YouTube, Amazon
`The Sony Smart Streaming Player (SMP-N100) includes a program, Sony Entertainment
`
`b) a program stored on said non-volatile
`
`readable format;
`data storage device in a computer-
`
`
`
`and/or services, such differences are insubstantial.
`exist between the claim element and Defendant’s Accused Instrumentalities, products
`achieve substantially the same result. To the extent that any differences are alleged to
`because they perform substantially the same function, in substantially the same way, to
`To the extent this element is not met literally, it is met under the doctrine of equivalents
`
`
`
`
`
`61253#overview
`1&searchType=search&storeId=10151&catalogId=10551&productId=81985529216662
`http://store.sony.com/webapp/wcs/stores/servlet/ProductDisplay?langId=-
`
`
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`19
`
`
`
`8
`
`
`
`
`
`
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`20
`
`
`
`13
`
`
`
`execution and in response to selection by a user of one of said items to access the
`Hulu Plus, YouTube, Amazon (Prime) Instant Video, and/or Netflix is operable upon
`wherein the Sony Entertainment Network (e.g., Music Unlimited and Video Unlimited),
`associated with it a link to an information resource accessible via the network and
`a number of user-selectable items displayed therein, wherein each of said items has
`execution to display a graphical user interface comprising an application window having
`Plus, YouTube, Amazon (Prime) Instant Video, and/or Netflix is operable upon
`The Sony Entertainment Network (e.g., Music Unlimited and Video Unlimited), Hulu
`
`information resource accessible via the
`associated with it a link to an
`wherein each of said items has
`selectable items displayed therein,
`window having a number of user-
`interface comprising an application
`execution to display a graphical user
`
`c) said program being operable upon
`
`and/or services, such differences are insubstantial.
`exist between the claim element and Defendant’s Accused Instrumentalities, products
`achieve substantially the same result. To the extent that any differences are alleged to
`because they perform substantially the same function, in substantially the same way, to
`To the extent this element is not met literally, it is met under the doctrine of equivalents
`
`
`
`
`
`
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`21
`
`
`
`14
`
`
`
`
`
`
`
`
`
`associated information resource over the network.
`Sony Smart Streaming Player (SMP-N100)
`
`information resource over the network;
`of said items to access the associated
`response to selection by a user of one
`operable upon execution and in
`network and wherein said program is
`
`Claim
`
`22
`
`
`
`15
`
`
`
`
`
`
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`23
`
`
`
`28
`
`
`
`61253#specifications
`1&searchType=search&storeId=10151&catalogId=10551&productId=81985529216662
`http://store.sony.com/webapp/wcs/stores/servlet/ProductDisplay?langId=-
`
`
`
`
`
`
`
`
`
`The Sony Smart Streaming Player (SMP-N100) is network accessible.
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`24
`
`
`
`29
`
`
`
`61253#overview
`1&searchType=search&storeId=10151&catalogId=10551&productId=81985529216662
`http://store.sony.com/webapp/wcs/stores/servlet/ProductDisplay?langId=-
`
`
`
`
`
`
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`25
`
`
`
`
`
`30
`
`
`
`
`
`within the user profile.
`Instant Video profile) and to display a user-selectable item for user links contained
`Network profile, Netflix profile, Hulu Plus profile, Google profile, Amazon (Prime)
`execution to receive from server one of the user profiles (e.g., Sony Entertainment
`Plus, YouTube, Amazon (Prime) Instant Video, and/or Netflix is operable upon
`The Sony Entertainment Network (e.g., Music Unlimited and Video Unlimited), Hulu
`
`and/or services, such differences are insubstantial.
`exist between the claim element and Defendant’s Accused Instrumentalities, products
`achieve substantially the same result. To the extent that any differences are alleged to
`because they perform substantially the same function, in substantially the same way, to
`To the extent this element is not met literally, it is met under the doctrine of equivalents
`Sony Smart Streaming Player (SMP-N100)
`
`
`
`user profile.
`library associated with the received
`the selected user link from the user
`links to access the file associated with
`selection by a user of one of the user
`further being operable in response to
`within the user profile, said program
`selectable item for user links contained
`the user profiles and to display a user-
`execution to receive from server one of
`
`d) said program being operable upon
`
`Claim
`
`26
`
`
`
`31
`
`
`
`
`
`
`
`
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`27
`
`
`
`48
`
`
`
`
`
`link from the user library associated with the received user profile.
`magazines, music files, TV shows, movies, games, etc.) associated with the selected user
`selection by a user of one of the user links to access the file (e.g., apps, books,
`Plus, YouTube, Amazon (Prime) Instant Video, and/or Netflix is operable in response to
`The Sony Entertainment Network (e.g., Music Unlimited and Video Unlimited), Hulu
`
`
`
`
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`28
`
`
`
`49
`
`
`
`
`
`
`
`
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`29
`
`
`
`62
`
`
`
`achieve substantially the same result. To the extent that any differences are alleged to
`because they perform substantially the same function, in substantially the same way, to
`To the extent this element is not met literally, it is met under the doctrine of equivalents
`
`
`
`over the network using a browser.
`to selection by a user of one of said items to access the associated information resource
`The infringing programs as set forth above are operable upon execution and in response
`
`and/or services, such differences are insubstantial.
`exist between the claim element and Defendant’s Accused Instrumentalities, products
`achieve substantially the same result. To the extent that any differences are alleged to
`because they perform substantially the same function, in substantially the same way, to
`To the extent this element is not met literally, it is met under the doctrine of equivalents
`
`
`
`
`
`
`
`using a browser.
`information resource over the network
`said items to access the associated
`response to selection by a user of one of
`is operable upon execution and in
`defined in claim 2, wherein said program
`3. A computer-readable memory as
`
`Sony Smart Streaming Player (SMP-N100)
`
`Claim
`
`30
`
`
`
`63
`
`
`
`
`
`and/or services, such differences are insubstantial.
`exist between the claim element and Defendant’s Accused Instrumentalities, products
`Sony Smart Streaming Player (SMP-N100)
`
`
`
`Claim
`
`31
`
`
`
`
`
`shows, movies, apps, games) in the user’s library in the server.
`links that provide links to one or more files (e.g., music files, books, magazines, TV
`GSM, HSPA, or LTE. The user’s user profile in the server contains one or more user
`profile stored in a server accessible via a network using, for example, WiFi, CDMA,
`Sony Entertainment Network Account, or PlayStation Account to access his or her user
`PlayStation Account. The user may use his or her Google Account, Kindle Account,
`a Google Account, Kindle Account, Sony Entertainment Network Account, or
`For example, a user of a Sony Xperia Active Android-based smartphone is provided with
`
`of the files in the user library.
`more files and the user profile containing at least one user link that provides a link to one
`library for each of a number of different users, with the user library containing one or
`accessible by the accused device via a network, the server storing a user profile and user
`readable memory for use by the accused device in conjunction with a server that is
`The accused device is a client computer. The accused device includes a computer-
`Sony Xperia Active Smartphones
`
`
`
`readable memory comprising:
`files in the user library, the computer
`user link that provides a link to one of the
`the user profile containing at least one
`library containing one or more files and
`number of different users, with the user
`a user profile and user library for each of a
`computer via a network, the server storing
`server that is accessible by the client
`by a client computer in conjunction with a
`2. A computer-readable memory for use
`Claim
`
`Sony Xperia Active Smartphones
`
`-vs.-
`
`U.S. Patent No. US 6,771,290 B1 (Hoyle)
`
`32
`
`
`
`Id=10151&langId=-1&productId=8198552921666472564
`http://store.sony.com/webapp/wcs/stores/servlet/ProductDisplay?catalogId=10551&store
`
`
`
`
`
`
`
`
`
`Id=10151&langId=-1&productId=8198552921666472564
`http://store.sony.com/webapp/wcs/stores/servlet/ProductDisplay?catalogId=10551&store
`
`
`
`
`
`Sony Xperia Active Smartphones
`
`Claim
`
`33
`
`
`
`Id=10151&langId=-1&productId=8198552921666472564
`http://store.sony.com/webapp/wcs/stores/servlet/ProductDisplay?catalogId=10551&store
`
`
`
`
`
`
`
`Sony Xperia Active Smartphones
`
`Claim
`
`34
`
`
`
`
`
`
`
`
`
`
`
`http://www.google.com/mobile/play/#promo-1
`
`
`
`Sony Xperia Active Smartphones
`
`Claim
`
`35
`
`
`
`
`
`The Sony Xperia Active smartphone includes a non-volatile data storage device.
`
`a) a non-volatile data storage device;
`
`
`
`and/or services, such differences are insubstantial.
`exist between the claim element and Defendant’s Accused Instrumentalities, products
`achieve substantially the same result. To the extent that any differences are alleged to
`because they perform substantially the same function, in substantially the same way, to
`To the extent this element is not met literally, it is met under the doctrine of equivalents
`
`
`
`
`
`
`
`http://www.google.com/mobile/play/#promo-1
`
`http://www.google.com/mobile/play/#promo-1
`Sony Xperia Active Smartphones
`
`
`
`Claim
`
`36
`
`
`
`device in a computer-readable format.
`Unlimited), Kindle Store or PlayStation Store, stored on said non-volatile data storage
`Android Market, Sony Entertainment Network (e.g., Music Unlimited and Video
`The Sony Xperia Active smartphone includes a program, Google Play, YouTube,
`
`b) a program stored on said non-volatile
`
`readable format;
`data storage device in a computer-
`
`
`
`and/or services, such differences are insubstantial.
`e
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
