David M. Stein, #198256
`dstein@brownrudnick.com
`BROWN RUDNICK LLP
`2211 Michelson Drive, Seventh Floor
`Irvine, CA 92612
`Phone: 949.752.7100
`Fax: 949.252.1514
`Masood Anjom (Pro Hac Vice forthcoming)
`majom@aatriallaw.com
`Amir Alavi (Pro Hac Vice forthcoming)
`aalavi@aatriallaw.com
`Justin Chen (Pro Hac Vice forthcoming)
`jchen@aatriallaw.com
`ALAVI & ANAIPAKOS, PLLC
`3417 Mercer Street, Suite C
`Houston, TX 77027
`Phone: 713.751.2362
`Fax: 713.751.2341
`Attorneys For Plaintiff
`GOTV STREAMING, LLC
`
`IN THE UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION
`
`GOTV STREAMING, LLC,
`Plaintiff,
`
`v.
`NETFLIX, INC.,
`Defendant.
`
`CASE NO. 2:22-CV-7556
`PLAINTIFF’S ORIGINAL COMPLAINT
`FOR PATENT INFRINGEMENT
`
`Netflix v. GoTV
`IPR2023-00758
`Netflix Ex. 1021
`
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`Plaintiff GoTV Streaming, LLC (“GoTV” or “Plaintiff”) hereby submits this Complaint for
`patent infringement against Defendant Netflix, Inc. (“Defendant” or “Netflix”) and states as follows:
`I.
`THE PARTIES
`1.
`GoTV is a limited liability company organized under the laws of California with its
`principal place of business at 3415 S. Sepulveda Blvd., Suite 1100, Los Angeles, California 90034.
`2.
`On information and belief, Netflix is a corporation organized under the laws of
`Delaware, with its headquarters at 100 Winchester Circle, Los Gatos, California 95032 and a regular
`and established place of business at 1375 Vine Street, Hollywood, California 90028.
`II.
`JURISDICTION AND VENUE
`3.
`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a)
`because this action arises under the patent laws of the United States, 35 U.S.C. § 1 et seq., including
`35 U.S.C. § 271.
`4.
`This Court has personal jurisdiction over Netflix at least because Netflix conducts
`business in this Judicial District and in the State of California. For example, Netflix regularly
`transacts business in the State of California and within this District, including by developing and
`offering Netflix’s media streaming platform to customers. Netflix operates a website and various
`advertising campaigns that solicit subscriptions to Netflix’s media streaming platform by consumers
`in this District and in the State of California. Netflix engages in other persistent courses of conduct
`and derives substantial revenue from services provided in this District and in the State of California.
`For example, Netflix has built, maintains and operates regular and established places of business in
`this District and in the State of California, including office locations employing thousands of Netflix
`engineers, executives and other employees. As a result, Netflix has purposefully established
`substantial, systematic and continuous contacts within this District, and Netflix should reasonably
`expect to be sued in this District.
`5.
`This Court also has personal jurisdiction over Netflix at least because Netflix has
`committed acts of patent infringement in this Judicial District and in the State of California. Netflix
`has made, used, sold and offered for sale products that infringe GoTV’s patent rights. On
`information and belief, Netflix’s media streaming platform (defined below and referred to herein as
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`the “Infringing Product”) has been developed, offered for sale, sold and used within the State of
`California and within this Judicial District. Accordingly, Netflix’s conduct and connections with
`the State of California are such that it should reasonably have anticipated being brought into court
`here.
`
`6.
`Venue is proper in this District as to Netflix pursuant to 28 U.S.C. §§ 1391(b),
`7.
`1391(c) and 1400(b) because, among other things, Netflix has a regular and
`established place of business in this District, including but not limited to a regular and established
`place of business at 1375 Vine Street, Hollywood, California 90028. Netflix has committed acts
`within this Judicial District giving rise to this action, and Netflix continues to conduct business in
`this District, including through the development, use, sale, and offer of sale of the Infringing
`Product.
`
`III. BACKGROUND
`8.
`Hands-On Mobile, Inc. was a wireless entertainment company founded in 2001 that
`specialized in developing, publishing and distributing mobile content over wireless networks. In
`2010, Hands-On Mobile sold its U.S. applications business to GoTV Networks, Inc. At the time,
`GoTV Networks, Inc. was a mobile media network and applications developer that similarly
`specialized in delivering media content to mobile users. After acquiring Hands-On Mobile, GoTV
`Networks, Inc. was itself acquired in 2011 by Phunware, Inc., a leading mobile software company
`that produces mobile applications for media delivery, advertising and marketing purposes.
`9.
`On January 24, 2012, the United States Patent and Trademark Office (“USPTO”)
`duly and legally issued United States Patent No. 8,103,865 (“the ’865 Patent”), titled “Server
`Method and System for Rendering Content on a Wireless Device.” The ’865 Patent claims patent-
`eligible subject matter and is valid and enforceable.
`10.
`On July 2, 2013, the USPTO duly and legally issued United States Patent No.
`8,478,245 (“the ’245 Patent”), titled “Method and System for Rendering Content on a Wireless
`Device.” The ’245 Patent claims patent-eligible subject matter and is valid and enforceable.
`/ / /
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`11.
`On March 24, 2015, the USPTO duly and legally issued United States Patent No.
`8,989,715 (“the ’715 Patent”), titled “Method and System for Rendering Content on a Wireless
`Device.” The ’715 Patent claims patent-eligible subject matter and is valid and enforceable.
`12.
`GoTV is the sole and exclusive owner of all rights, title, and interest in the ’865
`Patent, the ’245 Patent, and the ’715 Patent (collectively, the “GoTV Patents”), including the sole
`and exclusive right to prosecute this action, to enforce the GoTV Patents against infringers, to collect
`damages for past, present and future infringement of the GoTV Patents and to seek injunctive relief
`as appropriate under the law. Accordingly, Netflix’s infringement, as described below, has injured,
`and continues to injure GoTV.
`13.
`As described in the GoTV Patents, the increase in popularity of wireless devices has
`led to an increase in the number of wireless device types used by media consumers, such as cellular
`phones, personal digital assistants, laptops, tablets, etc. This has led to an increase in demand for
`various applications to run on the various wireless devices. Since each wireless device is unique,
`each application must be tailored in accordance with the device’s attributes to fully utilize its
`capabilities. The corresponding increase in the types of wireless devices, the number of
`applications, and the need to tailor each application to a given device has increased the cost of
`developing mobile applications.
`14.
`Collectively, the GoTV Patents disclose novel embodiments of methods and systems
`that address this problem. As described generally in the GoTV Patents, embodiments of the present
`inventions relieve software vendors from tailoring their applications based on each wireless device
`type because the server tailors the output of a generic application based on the wireless device
`capability.
`15.
`For example, the ’865 Patent is directed generally to a server-implemented method
`for processing data for a wireless device. As discussed in one embodiment, in response to a user
`request, the server executes an application program for generating content for rendering on the
`wireless device where the content is wireless device generic. An engine or reader on the device
`interprets commands of a generic syntax that are device specific in their parameters.
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`16.
`Similarly, the ’245 Patent is directed generally to a method for rendering content on
`a wireless device. For example, as discussed in one embodiment, a reader on a device is operable
`to communicate with a server and receive a series of low-level basic commands that layout content,
`position, etc. for rendering application content on a wireless device. The reader of the wireless
`device receives the basic commands that are tailored and are specific to the wireless device based
`on the device’s attributes and capabilities.
`17.
`The ’715 Patent is similarly directed to a method for rendering content on a wireless
`device. For example, as discussed in one embodiment, a graphical user interface includes a plurality
`of rendering blocks. A custom configuration may be used to customize the appearance of content
`generated by a requested application rendered on the rendering blocks. The graphical user interface
`is operable for rendering basic commands received from the reader and for customizing the
`operation and appearance of the requested application based on the custom configuration.
`18.
`As a result, using the novel methods and systems claimed in the GoTV Patents,
`software vendors can develop a generic application where the output of the generic application is
`tailored based on each wireless device type using the server, thus, among other things, promoting
`ease and efficiency in mobile application development, use, and maintenance.
`IV. COUNT I: INFRINGEMENT OF THE ’865 PATENT
`19.
`GoTV incorporates each of the allegations of paragraphs 1–18 above.
`20.
`Netflix has directly infringed and continues to directly infringe the ’865 Patent by,
`for example, making, using, offering to sell, selling, and/or importing into the United States, without
`authority, products or methods that practice one or more claims of the ’865 Patent.
`21.
`Defendant is not licensed or otherwise authorized to make, use, offer for sale, sell or
`import any products or methods that embody the inventions of the ’865 Patent in the United States.
`22.
`Defendant has and continues to directly infringe one or more claims of the ’865
`Patent, including, for example, claim 1 of the ’865 Patent, either literally or under the doctrine of
`equivalents, by making, using, offering to sell, selling, and/or importing into the United States the
`Infringing Product without authority and in violation of 35 U.S.C. § 271.
`/ / /
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`23.
`For example, the Netflix streaming media platform infringes representative Claim 1
`of the ’865 Patent.
`24.
`Claim 1 of the ’865 Patent claims a server implemented method for processing data
`for a wireless device, comprising: receiving from the wireless device a request for an application
`program, said request including an indication of a type of the wireless device; executing, in response
`to receiving said request, said application program to generate a wireless device generic template
`including a plurality of content items; sending a custom configuration to the wireless device, said
`custom configuration being specific to said application program; generating a page description
`based on said wireless device generic template and a capability of the wireless device, said page
`description having at least one discrete low level rendering command that is within said rendering
`capability of said wireless device but that is of a syntax that is wireless device generic; and sending
`said page description to the wireless device such that the wireless device is capable of presenting at
`least one content item from said plurality of content items using both said page description and said
`custom configuration.
`25.
`The Netflix streaming media platform practices the server implemented method of
`Claim 1 of the ’865 Patent.
`26.
`The Netflix streaming media platform practices a server implemented method for
`processing data for a wireless device. The Netflix system includes servers that process data for a
`wireless device, such as a mobile client device, including for example, smartphones, tablets and
`streaming media players.
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`27.
`The practiced method comprises: receiving from the wireless device a request for an
`application program, said request including an indication of a type of the wireless device. For
`example, Netflix engineers have described that “from Netflix's perspective, your TV on which the
`Netflix app is installed has a unique identity, which we call as the ESN or the Electronic Serial
`Number. Along with your credentials, this ESN is also passed in the login request. That request then
`gets routed to one of our origin servers, that is the API, which then calls one of the mid-tier services,
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`not surprisingly called auth service to validate your credentials.”1 Netflix’s engineers have further
`described that this identity information is passed downstream in the form of the Netflix Passport:
`“Going back to this current architecture diagram, the next logical question would be, in what form
`did we send the identity information downstream? For this, we created a new identity structure
`called Passport. What is Passport? It is an identity structure created at the edge for each request and
`services consumed in the scope of same request. It contains user and device identity information.” 2
`28.
`As described by Netflix’s engineers, Passport “has two buckets of information, User
`Info, and Device Info. As the name suggests, User Info stores user or the customer identity
`information, mainly the customer ID and the account owner ID. Device Info stores the device
`identity information, mainly the ESN and the device type.”3 This operation of Netflix’s backend
`can be illustrated through the following diagram: 4
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`1 https://www.infoq.com/presentations/netflix-user-identity/
`2 https://www.infoq.com/presentations/netflix-user-identity/
`3 https://www.infoq.com/presentations/netflix-user-identity/
`4 https://netflixtechblog.com/edge-authentication-and-token-agnostic-identity-propagation-
`514e47e0b602
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`https://uxdesign.cc/netflix-system-design-ef5802426ad4
`29.
`The practiced method comprises: executing, in response to receiving said request,
`said application program to generate a wireless device generic template including a plurality of
`content items. Upon receiving a request, the Netflix system generates a wireless device generic
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`template including a plurality of content items, including for example, an order of thumbnails,
`content categories, episode information, previews, interface elements, and the like.5
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`30.
`As described by Netflix’s engineers, “a key management service provides storage
`and access control for cryptographic keys. The server takes this key, cracks open the cookie, and if
`the cookie is valid and is not expired, it’ll send the customer ID and ESN information downstream,
`eventually generating a Netflix homepage, which is personalized for that customer ID.”6 Thus, upon
`receiving a request, the Netflix system generates a wireless device generic template including a
`plurality of content items to create a personalized homepage for the user.
`31.
`The practiced method comprises: sending a custom configuration to the wireless
`device, said custom configuration being specific to said application program. For example, this
`information can include text fonts, text colors, background colors, background images, border
`thickness, border colors, frame colors of menus, style of menus (such as whether a menu bar is
`horizontal or vertical), styles of check boxes, images of non-selected icons, images of selected icons,
`colors of the bar/animation representing the progress when downloading/streaming and an
`animation to use when download/streaming is in progress, and/or the like. It can also include
`information about the existence and appearance of a preview section or display cutout.
`
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`6 https://www.infoq.com/presentations/netflix-user-identity/
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`32.
`The practiced method comprises: generating a page description based on said
`wireless device generic template and a capability of the wireless device, said page description having
`at least one discrete low level rendering command that is within said rendering capability of said
`wireless device but that is of a syntax that is wireless device generic. The ’865 Patent describes that
`“[i]n one example, a page description contains basic commands that may include the description of
`the scrolling area (e.g., starting and ending vertical positions), the horizontal and vertical
`coordinates, the width, the height, the type of component to be displayed (e.g., text, image, video,
`audio and the like), the unique identification of the rendering block to be used to render the
`component, related parameters for the rendering block and for display components (e.g., version
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`number of the image) and the like.”7 For example, Netflix generates a description of the homepage,
`which can include information associated with the thumbnails and categories on the homepage. The
`description is based on the wireless device generic template and the capabilities of the wireless
`device. The description contains basic commands relating to the position and size of thumbnails,
`content categories, episode information, previews, interface elements, and the like based on device
`type, screen size, or resolution.
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`33. Moreover, the description is based on a capability of the wireless device because
`certain categories, such as UltraHD 4K, are included only for devices with the capability to display
`the videos in those categories.
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`7 The ’865 Patent at 13:26-34.
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`34.
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`The Netflix client is responsible for at least some rendering.8
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`8 https://towardsdatascience.com/deep-dive-into-netflixs-recommender-system-341806ae3b48
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`https://netflixtechblog.com/growth-engineering-at-netflix-automated-imagery-generation-
`5a105fd51569
`35.
`The practiced method comprises: sending said page description to the wireless device
`such that the wireless device is capable of presenting at least one content item from said plurality of
`content items using both said page description and said custom configuration. For example, Netflix
`sends the page description such that the wireless device is capable of presenting a homepage
`including thumbnails and categories using the page description and custom configuration.
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`36.
`Accordingly, Netflix directly infringes the ’865 Patent.
`37.
`On information and belief, Netflix directs and controls its cloud computing providers
`by contractual agreement to operate, or to provide Netflix with the means to operate (e.g., servers),
`or otherwise distribute the Infringing Product in a manner that infringes the ’865 Patent. Netflix
`further conditions receipt of the benefit of the Infringing Product upon use of the patented features,
`such as performing steps of the methods claimed in the ’865 Patent.
`V.
`COUNT II: INFRINGEMENT OF THE ’245 PATENT
`38.
`GoTV incorporates each of the allegations of paragraphs 1–37 above.
`39.
`Netflix has directly infringed and continues to directly infringe the ’245 Patent by,
`for example, making, using, offering to sell, selling, and/or importing into the United States, without
`authority, products or methods that practice one or more claims of the ’245 Patent.
`40.
`Defendant is not licensed or otherwise authorized to make, use, offer for sale, sell or
`import any products or methods that embody the inventions of the ’245 Patent in the United States.
`41.
`Defendant has and continues to directly infringe one or more claims of the ’245
`Patent, including, for example, claim 1 of the ’245 Patent, either literally or under the doctrine of
`equivalents, by making, using, offering to sell, selling, and/or importing into the United States the
`Infringing Product without authority and in violation of 35 U.S.C. § 271.
`20
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`42.
`For example, the Netflix streaming media platform infringes representative Claim 1
`of the ’245 Patent.
`43.
`Claim 1 of the ’245 Patent claims a method of rendering content on a wireless device,
`said method comprising: receiving an identification of a custom configuration of a plurality of
`rendering blocks of said wireless device, wherein said custom configuration is associated with an
`application and configures said plurality of rendering blocks to render content in a manner
`customized to said application; receiving compiled content generated in part from execution of said
`application wherein said compiled content comprises render commands expressed in a syntax that
`is generic to said wireless device; using a graphical user interface comprising said plurality of
`rendering blocks to generate renderable content based on said compiled content and said custom
`configuration; and rendering said renderable content on said wireless device, wherein said receiving
`compiled content comprises: receiving first compiled content specific to a first page of said
`application; and receiving second compiled content specific to a second page of said application,
`wherein said custom configuration is applicable to both said first and second compiled content.
`44.
`The Netflix streaming media platform practices the method of Claim 1 of the ’245
`Patent.
`45.
`The Netflix streaming media platform practices a method of rendering content on a
`wireless device. The Netflix system includes client software that renders content received from
`Netflix’s back-end and content delivery network on a wireless device, including for example,
`smartphones, tablets and streaming media players.
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`46.
`The practiced method comprises: receiving an identification of a custom
`configuration of a plurality of rendering blocks of said wireless device, wherein said custom
`configuration is associated with an application and configures said plurality of rendering blocks to
`render content in a manner customized to said application. For example, Netflix receives an
`identification of a custom configuration of a plurality of rendering blocks of said wireless device.
`For example, Netflix receives an identification of information regarding the user interface style,
`including edit boxes, static texts, images, pop-up menus, drop-down menu lists, tabbed menus,
`sounds, videos, visual control panels, check boxes/radio buttons, rating controls, scroll bars,
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`progress bars, tables, interface elements and the like. The information can include text fonts, text
`colors, background colors, background images, border thickness, border colors, frame colors of
`menus, and styles of menus, check boxes, icons, status bars, and the like.
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`47.
`As shown in the examples below, Netflix receives an identification of information
`regarding the user interface style.
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`48.
`The custom configuration is associated with the Netflix application and configures
`the edit boxes, static texts, images, pop-up menus, drop-down menu lists, tabbed menus, sounds,
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`videos, visual control panels, check boxes/radio buttons, rating controls, scroll bars, progress bars,
`and/or tables and/or associated user interface elements to render content in a manner customized to
`the Netflix application.
`49.
`The practiced method comprises: receiving compiled content generated in part from
`execution of said application wherein said compiled content comprises render commands expressed
`in a syntax that is generic to said wireless device. Netflix receives compiled content generated in
`part from execution of said application, including for example information associated with
`thumbnails and image resolution.
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`http://highscalability.com/blog/2017/12/11/netflix-what-happens-when-you-press-play.html
`50.
`Netflix receives other commands used to layout content and position of the
`application that include descriptions of the scrolling area, the horizontal and vertical coordinates,
`the width, the height, the type of component to be displayed (e.g., text, image, video, audio and the
`like), the unique identification of the rendering block to be used to render the component, and related
`parameters for the rendering block and for display components (e.g., version number of the image).
`The commands can also include information associated with a progress bar or display cutout. For
`example, Netflix receives JavaScript and JSON elements that are generated in part from execution
`of the Netflix application.
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`51.
`For example, Netflix receives a custom JSON data structure that is generated in part
`from execution of the Netflix application. The custom JSON data structure comprises render
`commands expressed in a syntax that is generic to said wireless device. As stated on the Netflix
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`Tech Blog: “If you recall in our previous blog post, Growth Engineering owns a service called the
`Orchestration Service. It is a mid-tier service that emits a custom JSON data structure that contains
`fields that are consumed by the UI. The UI can then use these fields to control the presentation in
`the UI
`layer.”
` https://netflixtechblog.com/growth-engineering-at-netflix-automated-imagery-
`generation-5a105fd51569.
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`52.
`The practiced method comprises: using a graphical user interface comprising said
`plurality of rendering blocks to generate renderable content based on said compiled content and said
`custom configuration. Netflix uses a graphical user interface comprising said plurality of rendering
`blocks to generate renderable content based on said compiled content and said custom configuration.
`The rendering blocks discussed above are part of the Netflix graphical user interface. The graphical
`user interface generates renderable content based on the compiled content and custom configuration
`discussed above.
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`53.
`The practiced method comprises: rendering said renderable content on said wireless
`device. Renderable content is rendered by Netflix on the wireless device.
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`54.
`The practiced method comprises: wherein said receiving compiled content comprises
`receiving first compiled content specific to a first page of said application and receiving second
`compiled content specific to a second page of said application, wherein said custom configuration
`is applicable to both said first and second compiled content. For example, Netflix receives compiled
`content specific to a page that can be selected from a menu bar. On iOS, exemplary pages could be
`the “Home” page, “New & Hot” page, “Fast Laughs” page, or “Downloads” page.
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`55.
`As another example, Netflix receives compiled content specific to a page for a
`particular video.
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`Netflix practices the method at least when conducting testing of the Infringing
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`56.
`Product.
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`https://netflixtechblog.com/testing-netflix-on-android-78e5f71b89ab; see also
`https://netflixtechblog.com/automated-testing-on-devices-fc5a39f47e24
`57.
`Accordingly, Netflix directly infringes the ’245 Patent.
`58.
`On information and belief, Netflix directs and controls the operation of devices
`executing the Infringing Product by programming the software which, when executed by a customer
`or end user, performs the claimed method of at least claim 1 of the ’245 Patent. Netflix further
`conditions receipt of the benefit of the Infringing Product upon use of the patented features, such as
`performing steps of the methods claimed in the ’245 Patent.
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`VI. COUNT III: INFRINGEMENT OF THE ’715 PATENT
`59.
`GoTV incorporates each of the allegations of paragraphs 1–58 above.
`60.
`Netflix has directly