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Netflix’s Infringement of U.S. Patent No. 8,407,609
`HIGHLY-CONFIDENTAL-SOURCE CODE
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`Plaintiff accuses Netflix, Inc. (“Netflix”) of making, using, selling, licensing, offering for sale/license and/or importing products and
`services, including Netflix.com and its subscription-based streaming OTT service and related software, applications (including the
`Netflix App for mobile devices), servers, clients (collectively the “Accused Products”) of directly infringing claims 1, 2 and 3 of U.S.
`Patent No. 8,407,609 (the “’609 Patent”).
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`1
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`NETFLIX, INC. EXHIBIT 1008
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`1. A method for tracking digital
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`The Accused Products track digital media presentations delivered from a first computer system to a user’s
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`media presentations delivered
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`computer via a network. The “digital media presentations are, e. g., televisions programs and movies. The
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`from a first computer system to a
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`“first computer system” is, e. g., a system hosted by Netflix. Digital media programs are delivered to a
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`user's computer via a network
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`user’s computer via, e.g._, the Internet.
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`Who, What, When, Where, HowLong
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`s://www.slideshare.net/Phili FisherO den/netflix—
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`NETFLIX, INC. EXHIBIT 1008
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`NETFLIX, INC. EXHIBIT 1008
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`NETFLIX, INC. EXHIBIT 1008
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`4
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`NETFLIX, INC. EXHIBIT 1008
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`providing a corresponding web
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`page to the user's computer for
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`The Accused Products provide a corresponding web page to the user’s computer for each digital media
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`presentation to be delivered using the first computer system.
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` TV Shows
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`each digital media presentation to
`be delivered using the first w
`computer system;
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`In palticular, a webpage located at https://www.netflix.com/watch!70071613 .
`
`.
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`. con‘esponds to the “No
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`Country for Old Men” movie.
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`NETFLIX, INC. EXHIBIT 1008
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`No Countvy for Old Men
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`In particular, the webpage located at
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`https://Www.netflix.com/watch/70124804?track1d=250312413&tctx=l%2C2%2C32d727fe-4995-4fl32-
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`fa397e02fb04_32179217X19XX1584456878730%2C2da36d64-f20d-42b5-8409-fa397ec2fb04_ROOT
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`con‘esponds to the “Valentine’s Day” movie.
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`associated with the movie “Valentine’s Day”.
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`The webpage located at https://a11d1‘oid.p1‘od.ftl.netflix.com/msl/and1‘oid/7.48/api/PLAY_MANIFEST is
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`NETFLIX, INC. EXHIBIT 1008
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`a Audo a. SUUIUCS
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`iOS Device
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`The webpage located at
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`https://ios.prod.ftl.netflix.com/iosui/user/12.23? ...... path=["videos”,”70124804”,"externa|PlayerArtWor
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`k”]&path=[”videos”,”70124804”,”trickplay|nfo”]&path=[”videos”,”70124804”,”nextEpisode",”summary”
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`]&path=[”videos",”70124804",”contentAdvisory"]&path Format=graph&pixel Density=2.0&progressive=f
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` Von-Ham's Day
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`alse&responseFormat=json is associated with the movie “Valentine’s Day”.
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`NETFLIX, INC. EXHIBIT 1008
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`Valentine's Day
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`providing identifier data to the
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`The Accused Products provide identifier data to the user’s computer using the first computer system.
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`user's computer using the first
`computer system;
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`V i eW i n g D a ta
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`Who, What, When, Where, HowLong
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`htt s:,v'"/"www.slideshare.net/Phili FisherOOdell/"netflix-ViewinO-histor r-eb'uO-2014 at 9.
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`NETFLIX, INC. EXHIBIT 1008
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`wherein each provided webpage
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`Each provided webpage causes corresponding digital media presentation data to be streamed from a
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`causes corresponding digital
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`media presentation data to be
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`second computer system (e. g., the content delivery network, e.g., NOpen Connect) to the user’s computer,
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`distinct from the first computer system and independent of the first computer system (e.g., the Netflix
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`
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`streamed from a second computer website).
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`system distinct from the first
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`computer system directly to the
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`user's computer independent of
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`.
`'
`_
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`.
`_
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`“Netflix NOpen Connect delivers 100% of our Video traffic. currently over 125 million hours of vrewmg
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`per day. This amounts to tens of terabits per second of simultaneous peak traffic. making Netflix Open
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`the first computer system;
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`Connect one of the highest-volrune networks in the world.
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`Globally. close to 90% of our traffic is delivered via direct connections between Open Connect and the
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`residential Internet Service Providers (ISPs) our members use to access the internet. Most of these
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`connections are localized to the regional point of interconnection that’s geographically closest to the
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`member who’s watching. Because connections to the Netflix Open Connect network are always free and
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`our traffic delivery is highly localized. thousands of ISPs arormd the world enthusiastically participate.
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`We also give qualifymg ISPs the same Open Connect Appliances (OCAs) that we use in our internet
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`interconnection locations. After these appliances are installed in an ISP’s data center, ahnost all Netflix
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`content is served from the local OCAs rather than “upstream” from the internet. Many ISPs take
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`advantage of this option. in addition to local network inter‘cormection, because it reduces the arnormt of
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`capacity they need to build to the rest of the internet since Netflix is no longer a significant factor in that
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`NETFLIX, INC. EXHIBIT 1008
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`“ WW
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`wherein the stored data is
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`indicative of an amount of time
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`the digital media presentation
`data is streamed from the second
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`computer system to the user‘s
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`computer; and
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`Netflix experience for their subscribers.
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`We now have Open Connect Appliances in close to 1,000 separate locations around the world. In big
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`cities like New York, Paris, London, Hong Kong, and Tokyo, as well as more remote locations — as far
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`north as Greenland and Tromso, Norway and as far south as Puerto Montt, Chile, and Hobart, Tasmania.
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`ISPs have even placed OCAs in Macapa and Manaus in the Amazon rainforest — on every continent,
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`except Antarctica and on many islands such as Jamaica, Malta, Guam, and Okinawa. This means that
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`most of our members are getting their Netflix audio and video bits from a server that’s either inside of, or
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`directly connected to, their ISP’s network within their local region.”
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`htt s://media.netflix.com/en/com an -blo
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`ow-netflix-works-with-is s-arormd-the- lobe-to—deliver-a-
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` capacity. This has the dual benefit of reducing the ISP’s cost of operation and ensuring the best possible
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`great-Viewing-experience.
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`The stored data is indicative of an amount of time the digital media presentation is streamed from the
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`second computer system to the user’s computer. The stored data indicates the duration and position of the
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`user’s current position, which indicates the amount of time the presentation has been streamed to the
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`user’s computer by the CDN.
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`NETFLIX, INC. EXHIBIT 1008
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