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`
`Subj:
`Date:
`From:
`To:
`
`RE: Provisional Patent Application Draft
`6/9/2004 5:08:20 PM Hawaiian Standard Time
`mdiaz@bbitv.com
`LKMChong@aol.com
`
`Leighton —
`
`I am working in this with the hope of finishing this week. As I have worked on this off and on over the last weeks,
`I realize that I have a possible semantics issue that is tripping me up:
`
`This draft extensively uses the term "VOD" in referring to platform and content critical to our application and
`patent. Taking a step back, our application is and "interactive television" application that uses specific iTV
`capabilities to deliver and present certain types of content (the interactive pages for example) and integrates
`traditional VOD content into the presentations — a user can access VOD content from an interactive page.
`
`In your use of the term "VOD", are you looking at it in a more generalized way than the industry typically uses it?
`When the cable industry refers to "VOD" it specifically means short or long-form continuous motion video content
`that is stream on an on-demand basis to a user SIB. It does not typically include static assets such as interactive
`television pages, banners, etc., The draft appears to use the term "VOD" in a more encompassing way — where
`VOD means any video asset that may be accessed on an on-demand basis, not just continuous-motion video.
`Am I reading things correctly? My instinct as I read the draft has been to edit it to distinguish between "iTV" and
`"VOD" platform and content, but also realize that this broader use of the term "VOD" may be the most appropriate
`for a patent. Sorry to ramble, I am very interested in your perspective
`
`Thanks,
`
`mdp
`
` Original Message
`From: LKMChong@aol.com [mailto:LKMChong@aol.corn]
`Sent: Wednesday, March 31, 2004 3:15 PM
`To: clifkagawa@hawaii.rr.com; milton_diaz@yahoo.com
`Subject: Provisional Patent Application Draft
`
`Hi Clif & Milton --
`
`Attached is my draft of the provisional patent application. Pls review and let me know if
`there are any corrections. Milton, can you quickly generate anddeliver to me the 3
`drawing figures noted in the draft? If there is not enough time, can you fax me the
`sketches you prepared during our discussion? With your comments and the drawings
`received back by no later than 4:30 pm, I can file the provisional by Express Mail
`deposit by 5 pm.
`
`Leighton
`
`Thursday, June 10, 2004 America Online: LI(MChong
`
`RESTRICTED -ATTORNEYS' EYES ONLY
`
`BBITV184371
`
`BBiTV EX2104
`DISH v. BBiTV
`IPR2020-01267
`
`PROTECTIVE ORDER MATERIAL
`
`

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