Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 1 of 85
`
`EXHIBIT C
`Preliminary Claim Charts
`
`Index
`
`
`’581 Patent – Claim 1 ................................................................................................................................................................................. 2
`
`’590 Patent – Claim 1 ............................................................................................................................................................................... 14
`
`’560 Patent – Claim 1 ............................................................................................................................................................................... 24
`
`’191 Patent – Claim 1 ............................................................................................................................................................................... 35
`
`’691 Patent – Claim 1 ............................................................................................................................................................................... 52
`
`’154 Patent – Claim 1 ............................................................................................................................................................................... 68
`
`
`
`
`Page 1 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 2 of 85
`
`Claim Element Claim Restriction
`1[preamble]
`A computer implemented method for
`providing a multimedia hardware device
`to generate an authorized reproduction
`of a media content item included in a
`digital media file, comprising:
`
`’581 Patent – Claim 1
`Preliminary Claim Chart
`
`Evidence of Infringement
`“A Roku Account give you access to movies, television shows and other
`audio-visual entertainment in the ‘Roku Channel Store’, a storefront of
`applications provided by Roku via your device’s on-screen menu, as well
`as through ‘The Roku Channel’, Roku’s own streaming video service.”
`https://docs.roku.com/published/usertermsandconditions/en/us
`
`“Roku doesn't store most of its content, but streams it directly,
`eliminating the need for large amounts of internal storage.”
`https://electronics.howstuffworks.com/gadgets/other-gadgets/roku-
`streaming-stick1.htm
`
`“A Roku TV is a standalone smart TV with built-in TV display and a
`simple, intuitive interface that lets you stream content over the internet
`from services such as Netflix, ESPN, and HBO, without needing to
`connect any additional devices. Roku TV also works like a regular TV,
`allowing you to connect an HDTV antenna to watch live television, or
`plug in external devices like a cable set-top box or Blu-ray™ player.”
`https://support.roku.com/article/209403268
`“Roku devices give you access to 500,000+ movies and TV episodes
`from top free and paid channels, so you can stream almost anything….”
`https://www.roku.com/en-gb/how-it-works
`“Stream top free or paid programming from services like Netflix,
`Amazon Prime Video, Hulu, Google Play, HBO, SHOWTIME, PBS, and
`The Roku Channel. Thousands more channels for sports, news,
`international, and kids programming plus broadcast channels like ABC,
`NBC, CBS, and FOX. And major music services like Pandora and Sirius
`XM are available.”
`https://www.roku.com/en-gb/how-it-works
`
`
`1[a]
`
`1[b]
`
`loading a digital media file for
`reproduction, wherein the digital media
`file includes the media content item;
`analyzing the digital media file to
`identify digital media information
`associated with the media content item;
`
`Page 2 of 85
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`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 3 of 85
`
`’581 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`Evidence of Infringement
`
`
`
`
`
`
`
`
`
`Page 3 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 4 of 85
`
`’581 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`Evidence of Infringement
`
`1[c]
`
`1[d]
`
`receiving a license request from a user
`requesting to engage in a license
`transaction to reproduce the media
`content item;
`evaluating the license transaction to
`determine whether the user has acquired
`a license to reproduce the media content
`item;
`
`
`See also
`https://developer.roku.com/docs/features/monetization/billing.md
`
`See also https://developer.roku.com/docs/developer-program/roku-
`pay/implementation/overview.md
`See Evidence of Use for Claim Restriction 1[b]
`
`
`
`See Evidence of Use for Claim Restriction 1[b]
`
`“The ChannelStore node and Roku Pay web services are used together to
`manage the on-device authentication and entitlements in channels. When
`the channel is launched, the channel sends the ChannelStore
`node's getAllPurchases command to retrieve the customer's existing
`subscription purchase (if any). The transaction ID for that subscription is
`
`Page 4 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 5 of 85
`
`’581 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`1[e]
`
`1[f]
`
`accessing a licensing database to
`determine whether the user is licensed to
`reproduce the media content item based
`on the digital media platform;
`reproducing the media content item
`when the user is licensed to reproduce
`the media content item based on the
`digital media information;
`
`Evidence of Infringement
`passed into Roku Pay's validate-transaction API to confirm whether the
`customer is still entitled to it. If the isEntitled flag included in the API
`response is "true", the channel grants the customer access to content; if
`it's "false", the channel prompts the customer to sign up for a subscription
`product (see the next section for how to implement the signup workflow).
`The result is a seamless, authentication workflow that requires no user
`interaction.”
`https://developer.roku.com/docs/developer-program/roku-
`pay/implementation/overview.md
`
`See also
`https://developer.roku.com/docs/features/monetization/billing.md
`See Evidence of Use for Claim Restrictions 1[b] amd 1[d]
`
`See Evidence of Use for Claim Restriction 1[b]
`
`
`Page 5 of 85
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`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 6 of 85
`
`’581 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`Evidence of Infringement
`
`1[g]
`
`after the evaluation of the license
`transaction, extracting from the license
`transaction user data that is specific to
`the user that is attempting to reproduce
`the media content item when the user
`acquires the license and when the user
`declines the license, wherein the user
`data includes demographic data
`associated with the user that enables a
`copyright owner of the media content
`item to gauge a demographic that
`acquired the license for the media
`content item of the copyright owner and
`a demographic that declined the license
`for is the media content item of the
`copyright owner;
`
`
`
`
`“We receive information about your interactions with the Roku Services,
`such as your … interactions with content and advertisements.”
`https://docs.roku.com/published/userprivacypolicy/en/us
`
`“We receive information about your activities within Roku’s Channels
`and Roku Direct Publisher Channels …, like the videos and other content
`you select and view within these channels. If you use the Roku Media
`Player channel to view your video or photo files or listen to your music
`files, Roku will collect data about the files viewed within the Roku
`Media Player, such as codecs, and other metadata of the local files your
`play through the Roku Media Player.”
`https://docs.roku.com/published/userprivacypolicy/en/us
`
`“Roku collects information about your online activities, including videos
`you search for and view, when you use Roku’s mobile app, in order to
`show you advertisements that we think may interest you on Roku’s and
`
`Page 6 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 7 of 85
`
`’581 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`1[h]
`
`aggregating the user data into a statistics
`record for the license request when the
`user acquires the license and when the
`user declines the license, wherein the
`statistics record summarizes the user
`data associated with the license request;
`
`Evidence of Infringement
`third parties’ online services, and for the other online advertising
`purposes.”
`https://docs.roku.com/published/mobileoptout/en/us
`
`See Hooman Mohajeri Moghaddam, et al., Watching You Watch: The
`Tracking Ecosystem of Over-the-Top TV Streaming Devices (2019),
`https://dl.acm.org/doi/pdf/10.1145/3319535.3354198.
`
`“When you choose to use your voice to control your Player, you agree
`that Roku and third parties who fulfill your requests and/or provide
`services for us have your consent to record, process and store your voice
`inputs (e.g., a recording and the interpretation of what was said), and use
`such voice inputs with other information about your Player (e.g., device
`identifier) to provide services to you, to improve the accuracy and quality
`of the service, and as described in Roku’s Privacy Policy.”
`https://docs.roku.com/published/deviceplayereula/en/us
`
`See also https://docs.roku.com/published/mobileapptermsofuse/en/us
`“Viewership Details table
`The Viewership Details table shows the number of visits, streams,
`streaming hours and rebuffers per streaming hour by Roku device. The
`hardware is identified by the Roku codename. The Roku model number
`is provided next to the hardware name, see Roku Models and Features for
`the list of hardware and model numbers.
`
`Click a column header to sort by that column. Click on the "more" icon
`(three dots) on the far right side of the name bar on this table to download
`it. The download includes additional product details along with the table.
`
`Visits and Streams visualization
`This visualization shows the number of times a channel has been
`launched and the number of times content has been streamed within that
`
`Page 7 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 8 of 85
`
`Evidence of Infringement
`channel. When someone launches a channel, that counts as one visit (this
`is sometimes called a session, as in web analytics). Duration does not
`factor into visit counts. Starting a channel and immediately exiting would
`still count as one visit.
`
` A
`
` stream is counted every time a stream is opened (i.e. a user presses
`play). If a user stops and starts a title multiple times, that will be counted
`as multiple streams. Multiple streams can be associated with the same
`title but multiple title cannot be associated with the same stream.
`
`The number of streams can be expected to be higher in channels with
`shorter form content, such as 1-5 minute user-generated videos, than in
`channels with longer form content, such as feature length films.
`
`Streams can generally be expected to exceed visits. If visits exceeds
`streams, that would indicate account holders are starting your channel,
`then exiting without ever streaming any
`content.https://developer.roku.com/docs/features/analytics/viewership-
`summary.md#
`
`“Audience Insights report
`The Audience Insights report tells publishers about the demographics of
`their channel audiences using first-party data.
`
`The interests and preferences revealed in the Audience Insights
`dashboard can help channel owners with content management and
`product planning. For example, if a content manager sees growing
`activity within their channel among college-educated individuals aged
`between 30 and 44 years who also spend a large amount of their time
`streaming in news and comedy channels, she may choose to start
`programming her channel with more political satire.
`
`
`Page 8 of 85
`
`’581 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 9 of 85
`
`Evidence of Infringement
`For channels that monetize with video advertisements, the Audience
`Insights report can also be used as an ad sales enablement tool. Consider
`an ad sales manager who sees that 40% of the viewers of his channel are
`young men aged between 25 and 34 years with an average income
`between $175-250,000 a year who also spend time streaming in sports
`and fitness channels. He would be wise to sell ad placements in his
`channel to high-end sports apparel brands.
`
` A
`
` channel audience is defined as all of the active users for given channel,
`and an active user is any account that has streamed content for greater
`than zero seconds in the past 30 days in that channel.”
`https://developer.roku.com/docs/features/analytics/audience-insights.md
`
`“Information collected by Roku is used for the following purposes: … 2.
`Improvement of Products and Services: to understand and analyze our
`user base and how you use the Roku Services, and to improve and
`enhance the Roku Services, and to develop new products, services,
`features and functionality; … 4. Advertising: to show you advertising,
`including personalized advertising, on the Roku Services, Third-Party
`Channels, and on third-party websites, mobile apps, platforms and
`devices, and to measure and understand the reach, viewership, and
`effectiveness of such advertising; 5. Marketing and Promotions: for
`marketing purposes, including sending you emails and text messages
`about products, events, promotions and offers from Roku or its partners
`or advertisers, and understanding the effectiveness of our marketing; 6.
`Analytics and Performance: to measure performance and analyze key
`metrics relevant to our business….”
`http://docs.roku.com/published/userprivacypolicy/en/us
`
`“Advertising Partners - We work with advertising partners to show you
`advertisements that we think may interest you on Roku Services and on
`other companies’ websites, apps, and devices. These advertising partners
`
`Page 9 of 85
`
`’581 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 10 of 85
`
`’581 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`1[i]
`
`storing in the license database the
`statistics record so that the user data is
`accessible to the copyright owner of the
`media content item;
`
`Evidence of Infringement
`may set and access their own cookies, pixel tags and similar technologies
`on the Roku Services and they may otherwise collect or have access to
`information about you which they collect over time and across different
`online services and devices.”
`http://docs.roku.com/published/userprivacypolicy/en/us
`“We use industry-standard methods of securing electronic databases of
`personal information.”
`http://docs.roku.com/published/userprivacypolicy/en/us
`
`“Channel Engagement report
`The Channel Engagement report is the default that displays when you
`choose View Analytics. Use this report to grow your audience by
`analyzing data about streaming activity and the size of your install base.
`...
`
`Summary statistics
`The band of metrics below FILTERS shows the summary statistics based
`on the time period you select in FILTERS:
`
`New Installs - total count of new unique accounts during the selected
`Time Period.
`Uninstalls - total count of accounts uninstalled during the selected Time
`Period.
`Cumulative Installs To-Date - count of unique accounts that that have
`installed your channel to-date; roughly equivalent to the size of your
`install base. When users uninstall and re-install a channel, this is credited
`as one net new installation and will increase the Cumulative Installs To-
`Date.
`Average Daily Viewers - average number of daily views similar to DAU
`"daily active users." Changing Time Grain will not effect this
`measurement.
`Average Minutes Per Viewer - average number of minutes streamed per
`
`Page 10 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 11 of 85
`
`’581 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`Evidence of Infringement
`unique streaming accounts.
`Total Hours Streamed - total hours streamed during the selected Time
`Period.”
`https://developer.roku.com/docs/features/analytics/channel-
`engagement.md
`
`“However Roku doesn’t sell most of the ads that run on its platform;
`most of it is sold by the publishers on the platform, said Roku gm of
`platform Scott Rosenberg on the earnings call.
`
`Enabling publishers to control ad sales on their channels has helped Roku
`to win favor with media companies, especially as more launch their own
`OTT apps. In June the company debuted Roku Audience Marketplace, a
`program for publishers to sell ads in their Roku channels that can be
`targeted using Roku’s first-party data and ad tech. And Roku has played
`a supporting role by selling ads for smaller publishers’ channels and
`splitting that revenue and striking deals with larger publishers to sell
`some of their inventory or to fill their unsold inventory.”
`https://digiday.com/future-of-tv/rokus-advertising-business-outpacing-
`hardware-business/
`
`
`Page 11 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 12 of 85
`
`’581 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`Evidence of Infringement
`
`1[j]
`
`analyzing a plurality of statistics records
`aggregated from each license request for
`the media content item owned by the
`copyright owner to provide the
`copyright owner with the aggregated
`user data from each license request of
`the media content item when the license
`is acquired by the user and when the
`license is declined by the user;
`
`
`https://developer.roku.com/docs/direct-publisher/tutorial/analytics.md
`“Information collected by Roku is used for the following purposes: … 2.
`Improvement of Products and Services: to understand and analyze our
`user base and how you use the Roku Services, and to improve and
`enhance the Roku Services, and to develop new products, services,
`features and functionality; … 4. Advertising: to show you advertising,
`including personalized advertising, on the Roku Services, Third-Party
`Channels, and on third-party websites, mobile apps, platforms and
`devices, and to measure and understand the reach, viewership, and
`effectiveness of such advertising; 5. Marketing and Promotions: for
`marketing purposes, including sending you emails and text messages
`about products, events, promotions and offers from Roku or its partners
`or advertisers, and understanding the effectiveness of our marketing; 6.
`Analytics and Performance: to measure performance and analyze key
`metrics relevant to our business….”
`http://docs.roku.com/published/userprivacypolicy/en/us
`
`
`Page 12 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 13 of 85
`
`’581 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`
`
`Evidence of Infringement
`“Channels have access to web-based channel analytics through Roku's
`Developer Dashboard. This allows you to analyze your channel's health,
`viewership trends, and metrics for specific titles and devices.
`
`As a service to our partners, Roku provides some basic analytics for all
`channels on the platform in the form of standardized dashboards with
`metrics on channel health, viewership and engagement, and so forth.
`Dashboards are read-only - meaning users cannot modify the dashboards
`themselves (apart from applying filters), create new dashboards, or
`change any of the underlying data. Also, the channel data displayed are
`restricted to channel owners. You will never see data pertaining to
`channels other than your own, and Roku will never share your channel
`data with other channel owners. Roku evaluates making changes to the
`available dashboards on an ongoing basis, based on feedback from our
`channel partners. Access to some dashboards may be restricted based on
`the size of the business relationship.”
`https://developer.roku.com/docs/features/analytics/analytics-reports.md
`
`Page 13 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 14 of 85
`
`Claim Element Claim Restriction
`1[preamble]
`A computer implemented method for
`providing a multimedia hardware device
`to generate an authorized reproduction
`of a media content item included in a
`digital media file, comprising:
`
`’590 Patent – Claim 1
`Preliminary Claim Chart
`
`Evidence of Infringement
`“A Roku Account give you access to movies, television shows and other
`audio-visual entertainment in the ‘Roku Channel Store’, a storefront of
`applications provided by Roku via your device’s on-screen menu, as well
`as through ‘The Roku Channel’, Roku’s own streaming video service.”
`https://docs.roku.com/published/usertermsandconditions/en/us
`
`“Roku doesn't store most of its content, but streams it directly,
`eliminating the need for large amounts of internal storage.”
`https://electronics.howstuffworks.com/gadgets/other-gadgets/roku-
`streaming-stick1.htm
`
`“A Roku TV is a standalone smart TV with built-in TV display and a
`simple, intuitive interface that lets you stream content over the internet
`from services such as Netflix, ESPN, and HBO, without needing to
`connect any additional devices. Roku TV also works like a regular TV,
`allowing you to connect an HDTV antenna to watch live television, or
`plug in external devices like a cable set-top box or Blu-ray™ player.”
`https://support.roku.com/article/209403268
`“Roku devices give you access to 500,000+ movies and TV episodes
`from top free and paid channels, so you can stream almost anything….”
`https://www.roku.com/en-gb/how-it-works
`
`1[a]
`
`1[b]
`
`receiving a license request from a user
`requesting to engage in a license
`transaction to reproduce a media content
`item;
`evaluating the license transaction to
`determine whether the user has acquired
`a license to reproduce the media content
`item;
`
`“Stream top free or paid programming from services like Netflix,
`Amazon Prime Video, Hulu, Google Play, HBO, SHOWTIME, PBS, and
`The Roku Channel. Thousands more channels for sports, news,
`international, and kids programming plus broadcast channels like ABC,
`NBC, CBS, and FOX. And major music services like Pandora and Sirius
`XM are available.”
`https://www.roku.com/en-gb/how-it-works
`
`Page 14 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 15 of 85
`
`’590 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`Evidence of Infringement
`
`
`
`
`
`
`
`
`Page 15 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 16 of 85
`
`’590 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`Evidence of Infringement
`
`
`1[c]
`
`after the evaluation of the license
`transaction, extracting from the license
`transaction user data that is specific to
`the user that is attempting to reproduce
`the media content item when the user
`acquires the license and when the user
`declines the license, wherein the user
`data includes demographic data
`associated with the user that enables a
`copyright owner of the media content
`item to gauge a demographic that
`acquired the license for the media
`content item of the copyright owner and
`a demographic that declined the license
`for the media content item of the
`copyright owner;
`
`
`“We receive information about your interactions with the Roku Services,
`such as your … interactions with content and advertisements.”
`https://docs.roku.com/published/userprivacypolicy/en/us
`
`“We receive information about your activities within Roku’s Channels
`and Roku Direct Publisher Channels …, like the videos and other content
`you select and view within these channels. If you use the Roku Media
`Player channel to view your video or photo files or listen to your music
`files, Roku will collect data about the files viewed within the Roku
`Media Player, such as codecs, and other metadata of the local files your
`play through the Roku Media Player.”
`https://docs.roku.com/published/userprivacypolicy/en/us
`
`“Roku collects information about your online activities, including videos
`you search for and view, when you use Roku’s mobile app, in order to
`show you advertisements that we think may interest you on Roku’s and
`
`Page 16 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 17 of 85
`
`’590 Patent – Claim 1
`Preliminary Claim Chart
`
`Claim Element Claim Restriction
`
`1[d]
`
`aggregating the user data into a statistics
`record for the license request when the
`user acquires the license and when the
`user declines the license, wherein the
`statistics record summarizes the user
`data associated with the license request;
`
`Evidence of Infringement
`third parties’ online services, and for the other online advertising
`purposes.” (emphasis added).
`https://docs.roku.com/published/mobileoptout/en/us
`
`See Hooman Mohajeri Moghaddam, et al., Watching You Watch: The
`Tracking Ecosystem of Over-the-Top TV Streaming Devices (2019),
`https://dl.acm.org/doi/pdf/10.1145/3319535.3354198.
`
`“When you choose to use your voice to control your Player, you agree
`that Roku and third parties who fulfill your requests and/or provide
`services for us have your consent to record, process and store your voice
`inputs (e.g., a recording and the interpretation of what was said), and use
`such voice inputs with other information about your Player (e.g., device
`identifier) to provide services to you, to improve the accuracy and quality
`of the service, and as described in Roku’s Privacy Policy.”
`https://docs.roku.com/published/deviceplayereula/en/us
`
`See also https://docs.roku.com/published/mobileapptermsofuse/en/us
`“Viewership Details table
`The Viewership Details table shows the number of visits, streams,
`streaming hours and rebuffers per streaming hour by Roku device. The
`hardware is identified by the Roku codename. The Roku model number
`is provided next to the hardware name, see Roku Models and Features for
`the list of hardware and model numbers.
`
`Click a column header to sort by that column. Click on the "more" icon
`(three dots) on the far right side of the name bar on this table to download
`it. The download includes additional product details along with the table.
`
`Visits and Streams visualization
`This visualization shows the number of times a channel has been
`launched and the number of times content has been streamed within that
`
`Page 17 of 85
`
`

`

`Case 1:21-cv-00027-LY Document 1-3 Filed 01/08/21 Page 18 of 85
`
`Evidence of Infringement
`channel. When someone launches a channel, that counts as one visit (this
`is sometimes called a session, as in web analytics). Duration does not
`factor into visit counts. Starting a channel and immediately exiting would
`still count as one visit.
`
` A
`
` stream is counted every time a stream is opened (i.e. a user presses
`play). If a user stops and starts a title multiple times, that will be counted
`as multiple streams. Multiple streams can be associated with the same
`title but multiple title cannot be associated with the same stream.
`
`The number of streams can be expected to be higher in channels with
`shorter form content, such as 1-5 minute user-generated videos, than in
`channels with longer form content, such as feature length films.
`
`Streams can generally be expected to exceed visits. If visits exceeds
`streams, that would indicate account holders are starting your channel,
`then exiting without ever streaming any
`content.https://developer.roku.com/docs/features/analytics/viewership-
`summary.md#
`
`“Audience Insights report
`The Audience Insights report tells publishers about the demographics of
`their channel audiences using first-party data.
`
`The interests and preferences revealed in the Audience Insights
`dashboard can help channel owners with content management and
`product planning. For example, if a content manager sees growing
`activity within their channel among college-educated individuals aged
`between 30 and 44 years who also spend a large amount of their time
`streaming in news and comedy channels, she may choose to start
`programming her channel with more political satire.
`
`
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`Evidence of Infringement
`For channels that monetize with video advertisements, the Audience
`Insights report can also be used as an ad sales enablement tool. Consider
`an ad sales manager who sees that 40% of the viewers of his channel are
`young men aged between 25 and 34 years with an average income
`between $175-250,000 a year who also spend time streaming in sports
`and fitness channels. He would be wise to sell ad placements in his
`channel to high-end sports apparel brands.
`
` A
`
` channel audience is defined as all of the active users for given channel,
`and an active user is any account that has streamed content for greater
`than zero seconds in the past 30 days in that channel.”
`https://developer.roku.com/docs/features/analytics/audience-insights.md
`
`“Information collected by Roku is used for the following purposes: … 2.
`Improvement of Products and Services: to understand and analyze our
`user base and how you use the Roku Services, and to improve and
`enhance the Roku Services, and to develop new products, services,
`features and functionality; … 4. Advertising: to show you advertising,
`including personalized advertising, on the Roku Services, Third-Party
`Channels, and on third-party websites, mobile apps, platforms and
`devices, and to measure and understand the reach, viewership, and
`effectiveness of such advertising; 5. Marketing and Promotions: for
`marketing purposes, including sending you emails and text messages
`about products, events, promotions and offers from Roku or its partners
`or advertisers, and understanding the effectiveness of our marketing; 6.
`Analytics and Performance: to measure performance and analyze key
`metrics relevant to our business….”
`http://docs.roku.com/published/userprivacypolicy/en/us
`
`“Advertising Partners - We work with advertising partners to show you
`advertisements that we think may interest you on Roku Services and on
`other companies’ websites, apps, and devices. These advertising partners
`
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`storing in a license database the
`statistics record so that the user data is
`accessible to the copyright owner of the
`media content item;
`
`Evidence of Infringement
`may set and access their own cookies, pixel tags and similar technologies
`on the Roku Services and they may otherwise collect or have access to
`information about you which they collect over time and across different
`online services and devices.”
`http://docs.roku.com/published/userprivacypolicy/en/us
`“We use industry-standard methods of securing electronic databases of
`personal information.”
`http://docs.roku.com/published/userprivacypolicy/en/us
`
`“Channel Engagement report
`The Channel Engagement report is the default that displays when you
`choose View Analytics. Use this report to grow your audience by
`analyzing data about streaming activity and the size of your install base.
`...
`
`Summary statistics
`The band of metrics below FILTERS shows the summary statistics based
`on the time period you select in FILTERS:
`
`New Installs - total count of new unique accounts during the selected
`Time Period.
`Uninstalls - total count of accounts uninstalled during the selected Time
`Period.
`Cumulative Installs To-Date - count of unique accounts that that have
`installed your channel to-date; roughly equivalent to the size of your
`install base. When users uninstall and re-install a channel, this is credited
`as one net new installation and will increase the Cumulative Installs To-
`Date.
`Average Daily Viewers - average number of daily views similar to DAU
`"daily active users." Changing Time Grain will not effect this
`measurement.
`Average Minutes Per Viewer - average number of minutes streamed per
`
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`unique streaming accounts.
`Total Hours Streamed - total hours streamed during the selected Time
`Period.”
`https://developer.roku.com/docs/features/analytic