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TiVo vs. Echostar: Judge grants TiVo motion to disallow patent invalidity defense


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#51 OFFLINE   Greg Bimson

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Posted 07 February 2009 - 03:52 PM

In the latest stipulation TiVo admitted they knew the design around since 2006, they never said they only knew the design around was for just the "new" DVRs, because E* had always told them the design around was for all the 8 named DVRs.

To eliminate any need for further discovery relating to such topics, TiVo stipulates that TiVo became aware of EchoStar’s design-around efforts on or about the date the first EchoStar Statement was made, specifically August 9, 2006; and TiVo became aware of other EchoStar Statements on or about the dates they were made, specifically November 7, 2006, March 1, 2007, May 10, 2007, August 9, 2007, November 9, 2007, February 26, 2008 and May 12, 2008.

August 9, 2006
November 7, 2006
March 1, 2007
May 10, 2007
August 9, 2007
November 9, 2007
February 26, 2008
May 12, 2008

From the 9 November 2007 quarterly 10-Q filing:
During April 2006, a Texas jury concluded that certain of our digital video recorders, or DVRs, infringed a patent held by Tivo. The Texas court subsequently issued an injunction prohibiting us from offering DVR functionality. A Court of Appeals has stayed that injunction during the pendency of our appeal.

In accordance with Statement of Financial Accounting Standards No. 5, “Accounting for Contingencies” (“SFAS 5”), we recorded a total reserve of $94 million in “Litigation expense” on our Condensed Consolidated Statement of Operations to reflect the jury verdict, supplemental damages and pre-judgment interest awarded by the Texas court through September 8, 2006. Based on our current analysis of the case, including the appellate record and other factors, we believe it is more likely than not that we will prevail on appeal. Consequently, we are not recording additional amounts for supplemental damages or interest subsequent to the September 8, 2006 judgment date. If the verdict is upheld on appeal, the $94 million amount would increase by approximately $35 million through the end of 2007.

If the verdict is upheld on appeal and we are not able to successfully implement alternative technology (including the successful defense of any challenge that such technology infringes Tivo’s patent), we will owe substantial additional damages and/or license fees and we could also be prohibited from distributing DVRs, or be required to modify or eliminate certain user-friendly DVR features that we currently offer to consumers. In that event we would be at a significant disadvantage to our competitors who could offer this functionality and, while we would attempt to provide that functionality through other manufacturers, the adverse affect on our business could be material.

On July 30, 2007, the Patent and Trademark Office (“PTO”) issued a “final office action” rejecting as invalid all of the hardware claims that Tivo asserted against us at trial and which the jury found we had infringed. The PTO did not reject the two software claims that Tivo asserted against us at trial and which the jury found we had infringed. Tivo can appeal the final office action. We believe that we do not infringe any of the claims asserted against us.

From the 26 February 2008 yearly 10-K filing:
On January 31, 2008, the U.S. Court of Appeals for the Federal Circuit affirmed in part and reversed in part the April 2006 jury verdict concluding that certain of our digital video recorders, or DVRs, infringed a patent held by Tivo. In its decision, the Federal Circuit affirmed the jury’s verdict of infringement on Tivo’s “software claims,” upheld the award of damages from the district court, and ordered that the stay of the district court’s injunction against us, which was issued pending appeal, will dissolve when the appeal becomes final. The Federal Circuit, however, found that we did not literally infringe Tivo’s “hardware claims,” and remanded such claims back to the district court for further proceedings. We are appealing the Federal Circuit’s ruling.

In addition, we have developed and deployed ‘next-generation’ DVR software to our customers’ DVRs. This improved software is fully operational and has been automatically downloaded to current customers (the “Design-Around”). We have formal legal opinions from outside counsel that conclude that our Design-Around does not infringe, literally or under the doctrine of equivalents, either the hardware or software claims of Tivo’s patent.


In accordance with Statement of Financial Accounting Standards No. 5, “Accounting for Contingencies” (“SFAS 5”), we recorded a total reserve of $128 million in “Litigation expense” on our Consolidated Balance Sheets to reflect the jury verdict, supplemental damages and pre-judgment interest awarded by the Texas court. This amount also includes the estimated cost of any software infringement prior to the Design-Around, plus interest subsequent to the jury verdict.

If the Federal Circuit’s decision is upheld and Tivo decides to challenge the Design-Around, we will mount a vigorous defense. If we are unsuccessful in subsequent appeals or in defending against claims that the Design-Around infringes Tivo’s patent, we could be prohibited from distributing DVRs, or be required to modify or eliminate certain user-friendly DVR features that we currently offer to consumers. In that event we would be at a significant disadvantage to our competitors who could offer this functionality and, while we would attempt to provide that functionality through other manufacturers, the adverse affect on our business could be material. We could also have to pay substantial additional damages.

What a difference three months makes. On the 9 November 2007 report, there was no mention of a design around, yet it was already completed to the adjudged receivers. On the 26 February 2008 report, DISH/SATS finally mentions that the design around is in place on all DVR's, almost 10 months after the last of the adjudged DVR's received a design around.

It was because the Court of Appeals upheld the verdict in late January 2008 that DISH/SATS finally admitted the design around was implemented on all DVR's.

Does anyone think TiVo will use DISH/SATS SEC filings as the basis for their knowledge of the design around, and then use all those filings to prove DISH/SATS was not forthcoming about the design around?

Please stop trying to revise history.

In fact the current judge's order is based on TiVo's proposed modifications to the judge's initial bench order. And again TiVo never proposed to separate the DVRs placed in use before the injunction from the ones placed after the injunction.

That is wholly incorrect.

From the filing before the 4 September 2008 status hearing, TiVo mentions that those sold with new software can also be found in contempt, which means there was a dividing line between those that had old software and those that had new software. In the lead-up to the 30 May 2008 status hearing, TiVo had also mentioned they were going after the install base which had the offending software, of course separating that from versions being sold now. And in the motion for damages, there are three distinct classes of each model which TiVo has requested compensation: those adjudged as infringing before 8 September 2006 which contained the old software, those which received the old software after 8 September 2006 and those which only ever received the new software.

Judge Folsom's order is to determine the status of colorable difference and continuing infringement of eight models of DVR's. There obviously is a dividing line as that means DVR's sold with the new software were never adjudged, yet these are being evaluated as well.

Again, please stop trying to revise history.

Edited by Greg Bimson, 07 February 2009 - 04:09 PM.


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#52 OFFLINE   nobody99

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Posted 07 February 2009 - 03:53 PM

In fact the current judge's order is based on TiVo's proposed modifications to the judge's initial bench order. And again TiVo never proposed to separate the DVRs placed in use before the injunction from the ones placed after the injunction.


Hmm. They are seeking contempt for not following the injunction. There are two parts to that injunction that are of interest.

IT IS FURTHER ORDERED THAT
Defendant...[is] hereby restrained and enjoined...from making, using, offering to sell, selling,...the Infringing Products...that are only colorably different therefrom in the context of the Infringed Claims


I've added some emphasis in the hopes that it will make it clear to you that this portion of the injunction is to prevent DISH from continuing to sell the eight-named DVRs unless they are modified to be more than colorably different.

Defendants are hereby FURTHER ORDERED to, within thirty (30) days of the issuance of this order, disable the DVR functionality...in all but 192,708 units of the Infringing Products that have been placed with an end user or subscriber.


I hope that makes it a little more understandable for you. I am not sure where you come up with the idea that TiVo "never proposed to seperate" because we don't know what they are doing. I am assuming that they will demand contempt in the first section for new DVRs that were placed in service after the decision. These will be subject to the more than colorably different test, and that's what the hearing is for.

They will then undoubtedly demand contempt for the second section because the DVR functionality was not turned off for the already-installed DVRs. I do not believe it matters if the receivers are colorably different or not; these are devices that have already been adjudicated.

Please, if you have some more information that hasn't been posted here that shows that TiVo does not intend to take this approach, please share it with the rest of us.

#53 OFFLINE   nobody99

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Posted 07 February 2009 - 04:13 PM

Maybe this will help illustrate that TiVo does intend to treat the separately. Here, Mr. Chu is explaining how KSM applies.

We have the Thermal-Lock products that were the expressed subject of the consent decree in the settlement. So they stopped selling Thermal-Lock. That wasn’t the subject of the contempt. Instead, there were new products called the Ultra-Lok I and later the Ultra-Lok II products. There was no adjudication by a court on those products. They were not included in the consent decree. There wasn’t language saying, and we are going to stop you from using or you have to disable the operation as an example of the Ultra-Lok products at all.

So, it’s a typical circumstance, your honor, where there is an injunction and says thou shall not sell Product A, or similar products, or infringing products. Now, Product B comes along and then the question is, what’s the procedure and is contempt appropriate? That’s what ksm addresses. It does not address the situation where we have an adjudication, a jury verdict, post trial motions, affirmed on appeal of exactly the products that they failed to disable. That is a critical difference.



#54 OFFLINE   nobody99

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Posted 07 February 2009 - 04:43 PM

More from the September hearing. Three classifications, only the third is affected by contempt.

Your Honor, there are three categories of damages, and on this first category, yes, I would say that this category would be unaffected by any ruling on the contempt issue. The same would be true of the second category of damages. And if I could have the next slide I will put up that amount. That’s the dollar amount that includes the first and second categories.

And that second category is just these same adjudicated DVRs but that had this software download downloaded to them afterwards through the satellite. And the reason I would say that those damages would still be appropriate is just a very simple but-for analysis. But for the stay, these DVRs wouldn’t have been out there in the field. They wouldn’t have been functioning. New ones wouldn’t have been placed, and so there would be nothing for this download to download to. So if you take a simple but-for analysis, but for the stay, none of these DVRs would be functioning. There would be nothing there for redesign software and therefore, yes, on these units we would say regardless of the court’s ruling on the contempt, these damages would still be appropriate.

there is a third category of damages and that’s what brings us up to the total of $220 million. The third category of damages would be affected by your Honor’s ruling. This category is the –- these would be adjudicated receivers where this alleged redesign was in the receivers when they were placed with the customer. So when the customer opened the box, put it in the tv, started working, they already had the redesign. That’s the category of damages that would be affected by a contempt ruling.



#55 OFFLINE   Curtis52

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Posted 07 February 2009 - 04:50 PM

Yep. TiVo admits they've known about a design around. TiVo has not admitted they knew DISH/SATS would apply that design around to receivers adjudged infringing, where Judge Folsom ordered the modification to disable the DVR functionality on those receivers.

So TiVo in practicality has admitted absolutely nothing.

I'm pretty sure that none of the Dish statements mentioned any success with a design around until after the Supreme Court turned them down and then TiVo promptly complained to the court. So, TiVo could have only known about a viable design around fairly recently.

#56 OFFLINE   jacmyoung

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Posted 07 February 2009 - 05:38 PM

I'm pretty sure that none of the Dish statements mentioned any success with a design around until after the Supreme Court turned them down and then TiVo promptly complained to the court. So, TiVo could have only known about a viable design around fairly recently.


E* had given TiVo the new software code before the 5/30/08 status meeting, and Rogers said their engineers looked at the code and had concluded the design around did not happen, or was impossible. That was way before the Supreme Court decision.

E* in turn in their recent request sought the answers as how the above Rogers' conclusions were reached, by seeking the engineers' communication details, presumably how they examined and tested the new software to make the conclusion that either nothing new was in there, or it was impossible.

Keep in mind the new software code did not change, it was a legit question to ask how TiVo reached such conclusion after they had the chance to look at the new code.

TiVo's response was we would not answer such questions because it was our trade secret and protected under the court Protective Order.

For one thing, the Protective Order does not prevent parties from disclosing sensitive information to each other and to the court, rather to provide specific means to prevent the leak of the information or the parties from using such information for anything else other than the sole purpose of the court proceedings.

For another, even if the information may be trade secret, since TiVo needs to prove by clear and convincing evidence that the new software still infringes, you would think TiVo would be willing to sacrifice a little and provide the evidence why based on their engineers' analysis of the new code, that it was no good, impossible, or no real design around at all.

The fact TiVo mostly recently refused to provide the proof is a good indication the new design worked, and TiVo and Rogers were simply throwing BS around about the new software.

I am not going to respond to any of the other posts because they were again old arguments.

Edited by jacmyoung, 07 February 2009 - 05:44 PM.


#57 OFFLINE   Greg Bimson

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Posted 07 February 2009 - 05:46 PM

The decision from the Court of Appeals, upholding most but remanding some of Judge Folsom's verdict, released 31 January 2008.

From DISH Network, released 31 January 2008:
"We are pleased the Federal Circuit found for us on Tivo’s hardware claims, but are disappointed in the Federal Circuit’s decision on the software claims. The decision, however, will have no effect on our current or future customers because EchoStar’s engineers have developed and deployed ‘next-generation’ DVR software to our customers’ DVRs. This improved software is fully operational, has been automatically downloaded to current customers, and does not infringe the Tivo patent at issue in the Federal Circuit’s ruling.

That was the very first admission of a design around, downloaded to the adjudged receivers.

#58 OFFLINE   nobody99

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Posted 07 February 2009 - 05:52 PM

E* had given TiVo the new software code before the 5/30/08 status meeting, and Rogers said their engineers looked at the code and had concluded the design around did not happen, or was impossible. That was way before the Supreme Court decision.

E* in turn in their recent request sought the answers as how the above Rogers' conclusions were reached, by seeking the engineers' communication details, presumably how they examined and tested the new software to make the conclusion that either nothing new was in there, or it was impossible.

Keep in mind the new software code did not change, it was a legit question to ask how TiVo reached such conclusion after they had the chance to look at the new code.

TiVo's response was we would not answer such questions because it was our trade secret and protected under the court Protective Order.

For one thing, the Protective Order does not prevent parties from disclosing sensitive information to each other and to the court, rather to provide specific means to prevent the leak of the information or the parties from using such information for anything else other than the sole purpose of the court proceedings.

For another, even if the information may be trade secret, since TiVo needs to prove by clear and convincing evidence that the new software still infringes, you would think TiVo would be willing to sacrifice a little and provide the evidence why based on their engineers' analysis of the new code, that it was no good, impossible, or no real design around at all.

The fact TiVo mostly recently refused to provide the proof is a good indication the new design worked, and TiVo and Rogers were simply throwing BS around about the new software.

I am not going to respond to any of the other posts because they were again old arguments.


I'd love to reply to yours, but I honestly have no idea what point you are trying to make with this post.

#59 OFFLINE   Curtis52

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Posted 07 February 2009 - 05:59 PM

According to Dish, the software and the Fish and Richardson opinion letter were provided to TiVo on April 18, 2008, the day the case was remanded back to the district court.

Edited by Curtis52, 07 February 2009 - 06:05 PM.


#60 OFFLINE   jacmyoung

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Posted 07 February 2009 - 07:54 PM

According to Dish, the software and the Fish and Richardson opinion letter were provided to TiVo on April 18, 2008, the day the case was remanded back to the district court.


Pretty much what I said.

The E*'s 16 questions (as Greg put it) pretty much evolved around TiVo's public comments right after they received the above information and Rogers said his engineers told him the new software was impossible and could not have been true. Later in the court filing though TiVo said it still infringed, but "to be sure" TiVo asked for a disclosure of more design around details.

That disclosure request was denied by the judge after the 5/30/08 meeting.

Now TiVo said we would not answer those 16 questions in part because we are protected under the court Protective Order to not disclose any trade secret.

Really? What can be so secretive in their engineers' communication to Rogers that the new software was impossible or did not make it? Any patentee would have been more than happy to tell the infringer and the court exactly why they, after examining the code, said that the infringer's design around was just impossible or did/did not make it, no reason to avoid answering those questions head on.

Unless of course if TiVo was just blowing smoke.

#61 OFFLINE   Greg Bimson

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Posted 07 February 2009 - 08:20 PM

Now TiVo said we would not answer those 16 questions in part because we are protected under the court Protective Order to not disclose any trade secret.

Really? What can be so secretive in their engineers' communication to Rogers that the new software was impossible or did not make it?

...uhh, before we start even getting into that, I don't want any of this to go off topic...

DISH/SATS provided code, and code only, to TiVo. DISH/SATS would not provide the test engine upon which the code was implemented. Therefore, let's not even talk about what sections are secretive...

#62 OFFLINE   nobody99

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Posted 07 February 2009 - 10:59 PM

jacmyoung, I am wondering why you are so focused on Tom Rogers comments to Bear Stearns about it being "highly, highly unlikely" that DISH has a valid workaround.

What difference does it make? What he says to an investor group, or to his drinking buddies, or to his softball team really doesn't seem to matter as far as the trial goes. If he said "I hate Charlie Ergen, he's a jackass" would that matter to this case? Why do you dwell on this, with multiple posts about a comment someone made?

I'm surprised you're not more focused on the actual issues in front of the court.

#63 OFFLINE   jacmyoung

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Posted 08 February 2009 - 09:16 AM

...uhh, before we start even getting into that, I don't want any of this to go off topic...

DISH/SATS provided code, and code only, to TiVo. DISH/SATS would not provide the test engine upon which the code was implemented. Therefore, let's not even talk about what sections are secretive...


Please show us where is TiVo currently saying that E* refused to provide the test product. If this is the case, yes it is a big deal.

I also want to point out that let's not try to dig up things on or prior to the 9/4/08 hearing, rather what parties are saying now. Not only because the moderators had reminded us not to do so, but also anything on or before 9/4/08 are past sentences.

This is a new hearing, and in this new hearing, two new issues will be addressed, and only the two new issues. You cannot bring back some old third issue, if you do, E* can easily appeal and have that issue thrown out, because if you want the third issue continue be a part of the next hearing, it has to be first proposed, then allowed by the judge, and then the other party given the chance to object to it, or argue against it.

TiVo of course can still bring up that third issue (separation of the DVRs pre and post the injunction), and the judge can even buy into it and rule on that, but since E* will have no chance to argue against it and defend themselves on that issue, it will be tossed out on appeal becasue E*'s due process right will have been violated.

Now to answer the question then why the Rogers' comments are relevant here? After all they were made some time ago. Well they should not matter. The only reason I brought this issue up was because some of you brought them up by discussing the new joint stipulation, and trying to make a big deal out of it.

I was only responding to the issues brought up by you folks. If you think it should be dropped, I am more than happy to comply.

In front of us are two things to be addressed in the next hearing, first whether the new software is only colorably different than the old software. And based on the reading of all the case law, if the answer is more than colorable, there cannot be a contempt, the proceeding should end. E* is arguing that since the two very pieces of evidence (the index table and the multiple buffers for auto flow control), you know the two things TiVo said were the "core of the invention" that proved the old DVRs infringed, they are now removed, gone, evidence no more. Therefore the differences are certainly more than colorable.

Keep in mind the above colorable difference arugment has nothing to do with the patent claim limitations at all, the specific terms such as "parse", "temporary store", "extract"... are not discussed here.

The second issue is whether the 8 named DVRs still infringe on the Claims 31 and 61, literally or by equivalents. In the second issue the claims limitations will be addressed. And of course I will not repeat them.

Edited by jacmyoung, 08 February 2009 - 09:44 AM.


#64 OFFLINE   nobody99

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Posted 08 February 2009 - 10:19 AM

In front of us are two things to be addressed in the next hearing, first whether the new software is only colorably different than the old software. And based on the reading of all the case law, if the answer is more than colorable, there cannot be a contempt, the proceeding should end.


Perhaps it is time once again for James & Jason to close the thread as we are, once again, back to the same tired old stubborness.

You state, as fact, that "there cannot be contempt" if there is more than a colorable difference based on your interpretation of case law. I will wholeheartedly agree with you that contempt won't be found for sales of new DVRS if the difference is more than colorable. However, KSM offers absolutely no precedence for the actual devices that are already adjudicated to infringe. The Jedi Mindtrick of new software = new receiver doesn't work for some of us.

TiVo's lawyers intepret things differently than you. And since they are are actual lawyers, as opposed to people playing a lawyer on message boards, I tend to give their opinions a bit more credence.

So, it’s a typical circumstance, your honor, where there is an injunction and says thou shall not sell Product A, or similar products, or infringing products. Now, Product B comes along and then the question is, what’s the procedure and is contempt appropriate? That’s what ksm addresses. It does not address the situation where we have an adjudication, a jury verdict, post trial motions, affirmed on appeal of exactly the products that they failed to disable. That is a critical difference.


DISH is resting their entire case on the idea that KSM allows an already-adjudicated device to escape scrutiny. TiVo disagrees. For that reason, this isn't simply a case of "more than colorable = no contempt"

So let's suppose for the sake of argument a best-case scenario for DISH that the court finds the software to be more than colorable. That means new sales of the eight-named DVRs escape contempt.

But it does not address what happens to the already-adjudicated DVRS, the 4+ million already in the homes of customers at the time of the verdict.

This is where the precedence will be set in either case. It does not matter what his decision is, it will be the new standard by patent cases for field-modifiable devices are judged.

I suspect that Judge Folsom will require a somewhat higher level of court involvement for these devices. In other words, DISH will need to get court approval for changes to them. Once they get court approval and apply the changes, they are out of "contempt jail."

As a result, I believe that these devices will be held in contempt through, at the very least, the date of the hearing.

Of course, none of this matters if the software is merely colorable or there is still infrigement by DOE. In that event, all devices - new sales included - will be subject to contempt.

Edited by nobody99, 08 February 2009 - 10:22 AM.
Fix underline tag, typos


#65 OFFLINE   Curtis52

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Posted 08 February 2009 - 11:31 AM

TiVo hereby moves for an Order that EchoStar be held in contempt of court and that it be ordered to comply immediately with the Order “to disable the DVR functionality,” finally allowing the injunctive relief intended to protect TiVo to take effect.


Newly sold named DVRs are not the subject of TiVo's contempt motion. The already installed DVRs will be looked at for colorable difference at the hearing. Apparently, it matters. If it didn't matter, he would have already ruled on it.

#66 OFFLINE   nobody99

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Posted 08 February 2009 - 11:57 AM


TiVo hereby moves for an Order that EchoStar be held in contempt of court and that it be ordered to comply immediately with the Order “to disable the DVR functionality,” finally allowing the injunctive relief intended to protect TiVo to take effect.


Newly sold named DVRs are not the subject of TiVo's contempt motion. The already installed DVRs will be looked at for colorable difference at the hearing. Apparently, it matters. If it didn't matter, he would have already ruled on it.


Where does it say anything about not being newly-sold? There are three classes of DVRS that are currently installed in users homes:

1) Those present at the time of the verdict
2) Those that were installed after the verdict with the old software
3) Those that were installed after the verdict with the new software

So yes, some installed DVRs will be looked at for colorable difference (#3). But the quote you provided reveals nothing with relation to those DVRs that were installed at the time of the verdict (aka, the "convicted DVRs").

The text is already posted, on this page in fact, that TiVo believes there are three classes of DVRs in this motion (at least as far as damages go). I'm also curious how you stretch your citation ("to disable the DVR functionality") into a meaning that they must already be installed? It says nothing of the sort. It is basically saying that the eight-named models should no longer have DVR functionality. That's it.

#67 OFFLINE   jacmyoung

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Posted 08 February 2009 - 01:24 PM

The problem is you again continue to quote the 9/4/08 hearing. That one was over.

What you need to look at is the current order, in which there is absolutely no three classes, no distinction between those DVRs, but any and all 8 named DVRs. And the judge's ruling will be on all those DVRs.

TiVo no longer tries to separate those DVRs, TiVo's own proposed order did not try to separate them, and the judge's order does not separate them.

As I said, this is a new hearing, don't keep quoting the old ones.

#68 OFFLINE   jacmyoung

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Posted 08 February 2009 - 01:25 PM

Newly sold named DVRs are not the subject of TiVo's contempt motion. The already installed DVRs will be looked at for colorable difference at the hearing. Apparently, it matters. If it didn't matter, he would have already ruled on it.


I belive the newly sold 8 named DVRs are included too, simply because the order does not separate them, just that those DVRs that bear the 8 model numbers.

#69 OFFLINE   Greg Bimson

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Posted 08 February 2009 - 02:46 PM

I also want to point out that let's not try to dig up things on or prior to the 9/4/08 hearing, rather what parties are saying now. Not only because the moderators had reminded us not to do so, but also anything on or before 9/4/08 are past sentences.

The E*'s 16 questions (as Greg put it) pretty much evolved around TiVo's public comments right after they received the above information and Rogers said his engineers told him the new software was impossible and could not have been true. Later in the court filing though TiVo said it still infringed, but "to be sure" TiVo asked for a disclosure of more design around details.

That disclosure request was denied by the judge after the 5/30/08 meeting.

If that which happened before this order for an evidentiary hearing on 17 February didn't matter, why is DISH/SATS spending so much of their time trying to discern what TiVo knew regarding the design around and CEO Rogers comments that the design around more than likely still infringed upon the Time Warp patent?

At this point, surprisingly enough, I will also ask for this thread to be closed. I am getting tired of arguments using the ping-pong theory: throw 1,000 ping-pong balls up in the air and paddle all them before they hit the ground. Sure, some will be missed, but some of these ping-pong ball arguments don't even matter.

#70 OFFLINE   Chris Blount

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Posted 08 February 2009 - 03:16 PM

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