Netflix’s Infringement of U.S. Patent No. 8,407,609
`HIGHLY-CONFIDENTAL-SOURCE CODE
`
`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”).
`
`1
`
`NETFLIX, INC. EXHIBIT 1008
`
`
`HIGHLY-CONFIDENTAL-SOURCE CODE
`
`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”).
`
`1
`
`NETFLIX, INC. EXHIBIT 1008
`
`
`
`The Accused Products track digital media presentations delivered from a first computer system to a user’s
`1. A method fortracking digital
`computervia a network. The“digital media presentationsare, e.g., televisions programs and movies. The
`media presentations delivered
`from a first computer system toa|“first computer system”is, e.g., a system hosted by Netflix. Digital media programsare deliveredto a
`user's computervia a network
`user’s computervia, e.g., the Internet.
`
`comprising: Viewing Data
`
`.
`
`|
` THEes
`
`“city"PLEASANTON",
`"region_code”-"CA",
`
`Duration
`
`«Latest
`Position
`
`
`
`Who, What, When, Where, How Long
`
`Netflix viewing data architecture evolution. See h
`viewing-history-ebjug-2014 at 9.
`
`2
`NETFLIX, INC. EXHIBIT 1008
`
`NETFLIX, INC. EXHIBIT 1008
`
`
`
`Conceptual Data Model
`
`
`
`ViewingHistory
`
`
`
`LatestPositions
`
`CustomerID
`
`loved tate!
`Position
`
`CustomeriD
`
`Movie
`
`Latest Position
`
`Web Browser
`
`The three screens below showstracking because under “Continue Watching”they show programs the
`viewerpreviously viewed.
`
`Netflix viewing data architecture evolution. See https://www.slideshare.net/PhilipFisherO gden/netflix-
`viewing-history-ebjug-2014 at 30.
`
`3
`NETFLIX, INC. EXHIBIT 1008
`
`NETFLIX, INC. EXHIBIT 1008
`
`
`
`
`
`m Netflix
`
`Ce
`
`O &@ hittps://www.'
`
`— 2
`ee
`
`¢
`
`Continue Watching for
`
`Android Device
`
`tae 10) TV Shows
`
`THE CIRCLE
`‘9
`;
`K
`attii
`“J
`=
`at pee: Cee ©) py fe
`ree renes
`
`t=
`
`|
`|
`
`Bites
`PaAY, ER
`
`,
`y
`BACK%EXe
`
`4
`NETFLIX, INC. EXHIBIT 1008
`
`NETFLIX, INC. EXHIBIT 1008
`
`
`
`
`
`Aut
`
`A ee)
`
`+ Ey ©
`
`Previews 10S Device
`
`5
`NETFLIX, INC. EXHIBIT 1008
`
`NETFLIX, INC. EXHIBIT 1008
`
`
`
`
`
`providing a corresponding web
`page to the user's computerfor
`eachdigital media presentation to
`be delivered using the first
`computer system;
`
`TV Shows
`
`Tea
`
`Veale
`
`Sia |
`
`ela)
`
`4
`
`Tees
`THRO Co
`
`_
`THE CIRCLE
`
`VIRGI0
`RIVEI
`
`Continue Watching for
`
` 1:53 PM
`
`The Accused Products provide a corresponding web pageto the user’s computerfor each digital media
`presentation to be delivered using the first computer system.
`
`Web Browser
`
`In particular, a webpage located at https://www.netflix.com/watch/70071613 .
`Country for Old Men” movie.
`
`.
`
`. corresponds to the “No
`
`6
`NETFLIX, INC. EXHIBIT 1008
`
`NETFLIX, INC. EXHIBIT 1008
`
`
`
`
`
` =a
`
`In particular, the webpage located at
`https://www.netflix.com/watch/70124804?trackId=2503 12413 &tetx=1%2C2%2C32d727fe-4995-4fb2-
`bf39-72d78f254a25-78 1304360%2C2da36d64-f20d-42b5-8409-
`fa397ec2fb04_32179217X19XX1584456878730%2C2da36d64-f20d-42b5-8409-fa397ec2fb04_ROOT
`correspondsto the “Valentine’s Day” movie.
`
`7
`
`a PP
`
`_
`
`a
`
`rw)
`
`oo}
`
`Yb]
`
`No Country for Old Men
`
`@)
`
`aon)
`
`a
`
`7
`NETFLIX, INC. EXHIBIT 1008
`
`NETFLIX, INC. EXHIBIT 1008
`
`
`
`em
`
`Netflix
`
`Ss
`
`|
`
`Rw) @ ) ele or]
`
`ox www.netflix.com/wat
`
`
`The webpagelocatedat https://android.prod.ftl.netflix.com/msl/android/7.48/api/PLAY_MANIFESTis
`associated with the movie “Valentine’s Day”.
`
`Android Device
`
`8
`NETFLIX, INC. EXHIBIT 1008
`
`NETFLIX, INC. EXHIBIT 1008
`
`
`
`
`
`Valentine's Day a= BPoS iTetary
`
`The webpagelocated at
`https://ios.prod.ftl.netflix.com/iosui/user/12.23?......path=[“videos”,” 70124804”,”externalPlayerArtWor
`k”]&path=[“videos”,” 70124804”,”trickplayInfo”]&path=[“videos”,”70124804”,”nextEpisode”,”summary”
`]&path=[“videos”,”70124804”,”contentAdvisory”]&pathFormat=graph&pixelDensity=2.0&progressive=f
`alse&responseFormat=jsonis associated with the movie “Valentine’s Day”.
`
`10S Device
`
`9
`NETFLIX, INC. EXHIBIT 1008
`
`NETFLIX, INC. EXHIBIT 1008
`
`
`
`Maeeead
`
`The Accused Products provide identifier data to the user’s computerusing the first computer system.
`
`@ Pear”
`
`providing identifier data to the
`user's computerusing thefirst
`computer system;
`
`V CW n g Data
`
`Who,]} What, When, Where, How Long
`
`10
`NETFLIX, INC. EXHIBIT 1008
`
`NETFLIX, INC. EXHIBIT 1008
`
`
`
`
`
`
`wherein each provided webpage|Each provided webpagecauses corresponding digital media presentation data to be streamed froma
`
`second computer system (e.g., the content delivery network, e.g., NOpen Connect) to the user’s computer,
`causes corresponding digital
`media presentation data to be
`distinct fromthe first computer system and independentofthe first computer system (e.g., the Netflix
`
`streamed from a second computer|website).
`systemdistinct from thefirst
`;
`;
`;
`_
`.
`
`“Netflix NOpen Connect delivers 100% of our video traffic, currently over 125 million hours of viewing
`computer system directly to the
`per day. This amounts to tens of terabits per second of simultaneous peaktraffic, making Netflix Open
`user's computer independent of
`Connect one of the highest-volume networksin the world.
`the first computer system;
`
`
`
`Globally, close to 90% ofourtraffic is delivered via direct connections between Open Connect and the
`residential Internet Service Providers (ISPs) our members useto access the internet. Most of these
`connectionsare localized to the regional point of interconnection that’s geographically closest to the
`memberwho’s watching. Because connections to the Netflix Open Connect network are always free and
`ourtraffic delivery is highly localized, thousands of ISPs around the world enthusiastically participate.
`
`Wealso give qualifying ISPs the same Open Connect Appliances (OCAs) that we use in ourinternet
`interconnection locations. After these appliancesare installed in an ISP’s data center, almost all Netflix
`content is served from the local OCAsrather than “upstream” from the internet. Many ISPs take
`advantage ofthis option, in addition to local network interconnection, because it reduces the amount of
`capacity they need to build to the rest of the internet since Netflix is no longer a significant factor in that
`
`44
`NETFLIX, INC. EXHIBIT 1008
`
`NETFLIX, INC. EXHIBIT 1008
`
`
`
`capacity. This has the dual benefit of reducing the ISP’s cost of operation and ensuring the best possible
`Netflix experience for their subscribers.
`
`Accused Products
`
`great-viewing-experience.
`
`
`We now have Open Connect Appliancesin close to 1,000 separate locations around the world. In big
`cities like New York, Paris, London, Hong Kong, and Tokyo,as well as more remote locations — as far
`north as Greenland and Tromso, Norwayandas far south as Puerto Montt, Chile, and Hobart, Tasmania.
`ISPs have even placed OCAsin Macapa and Manausin the Amazon rainforest — on every continent,
`except Antarctica and on manyislands such as Jamaica, Malta, Guam, and Okinawa. This meansthat
`most of our membersare getting their Netflix audio and videobits from a serverthat’s either inside of, or
`directly connected to, their ISP’s network within their local region.”
`
`wherein the stored data is
`The stored data is indicative of an amountof time the digital media presentation is streamed from the
`
`indicative of an amount of time
`second computer system to the user’s computer. The stored data indicates the duration andposition ofthe
`
`the digital media presentation
`user’s current position, which indicates the amountof time the presentation has been streamedto the
`data is streamed from the second|user’s computer by the CDN.
`
`
`computer system to the user's
`
`computer; and
`
`45
`NETFLIX, INC. EXHIBIT 1008
`
`NETFLIX, INC. EXHIBIT 1008
`
`
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
