Free Motion for Preliminary Injunction - District Court of California - California

Case 3:07-cv-02126-BEN-RBB

Document 7-3

Filed 11/15/2007

Page 1 of 44

1 Alan Himmelfarb KAMBEREDELSON LLC 2 2757 Leonis Blvd. Los Angeles, CA 90058 3 (323) 585-8696 [email protected] 4 Jay Edelson 5 Ethan Preston KAMBEREDELSON LLC 6 53 West Jackson Ave., Suite 1530 Chicago, IL 60604 7 312-589-6370 [email protected] 8 [email protected] 9 Counsel for Plaintiffs 10 11 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA No. 07cv2126-JM(NLS) DECLARATION OF ETHAN PRESTON IN SUPPORT OF PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION AND CONDITIONAL CLASS CERTIFICATION Date: January 11, 2008 Time: 1:30 p.m. United States District Court Judge Jeffrey T. Miller 940 Front Street Courtroom 6, 3rd Floor San Diego, CA 92101

JASON DEMAS and JOHN RENNINGER, 12 on their own behalves and on behalf of all others similarly situated, 13 Plaintiffs, 14 v. 15 SONY ELECTRONICS, INC., a Delaware 16 corporation, 17 18 19 20 21 22 23 24 25 26 27 28
Declaration of Ethan Preston in Support of Motion for Preliminary Injunction and Conditional Class Certification

Defendant.

No. 07cv2126 -JM(NLS)

Case 3:07-cv-02126-BEN-RBB

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Page 2 of 44

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Pursuant to 28 U.S.C.§ 1746, I, Ethan Preston, hereby declare and state as follows: 1. I am over the age of eighteen and am fully competent to make this declaration. I make this declaration based upon personal knowledge. 2. On November 13, 2007, I visited the following webpage: http://esupport.sony.com/US/perl/model-documents.pl?mdl=KDSR60XBR1 I downloaded marketing specifications for the KDS R60XBR1 television model from that webpage. A true and correct copy of those specifications are attached to this Declaration as Exhibit A. Exhibit A indicates the KDS R60XBR1 televisions had a "Native Resolution: 1080p" and contained SXRD panels which [met] and exceed[ed] the demands of a High Definition image at its full 1080 line resolution. Digitally transmitted High Definition signals can contain over 2 million individual detail points that need to be displayed accurately and rapidly. SXRD displays those 2 million detail points per SXRD panel accurately since the 3 SXRD panels actually contain enough pixels to fully display a 1080 line picture without interlacing it. (Ex. A 1) (emphasis added). 3. On November 13, 2007, I visited the following webpage: http://esupport.sony.com/US/perl/model-documents.pl?mdl=KDSR50XBR1 I downloaded marketing specifications for the KDS R50XBR1 television model from that webpage. A true and correct copy of those specifications are attached to this Declaration as Exhibit B. Exhibit B indicates the KDS R50XBR1 televisions had a "Native Resolution: 1080p" and contained SXRD panels which [met] and exceed[ed] the demands of a High Definition image at its full 1080 line resolution. Digitally transmitted High Definition signals can contain over 2 million individual detail points that need to be displayed accurately and rapidly. SXRD displays those 2 million detail points per SXRD panel accurately since the 3 SXRD panels actually contain enough pixels to fully display a 1080 line picture without interlacing it. (Ex. B 1) (emphasis added). 4. On November 13, 2007, I visited the following webpage:
2 No. 07cv2126-JM(NLS) Declaration of Ethan Preston in Support of Motion for Preliminary Injunction and Conditional Class Certification

Case 3:07-cv-02126-BEN-RBB

Document 7-3

Filed 11/15/2007

Page 3 of 44

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 7. 6. 5.

http://google.com/products?q=KDS+R60XBR1&btnG=Search+Products A true and correct copy of that webpage is attached to this Declaration as Exhibit C. Exhibit C indicates that many KDS R60XBR1 model televisions remain available from a variety of online retailers. On November 13, 2007, I visited the following webpage: http://google.com/products?q=KDS+R50XBR1&btnG=Search+Products A true and correct copy of that webpage is attached as Exhibit D to this Declaration. Exhibit D indicates that many KDS R50XBR1 model televisions remain available from a variety of online retailers. On November 13, 2007, I visited the following webpage: http://www.sonystyle.com/webapp/wcs/stores/servlet/ProductDisplay? catalogId=10551&storeId=10151&langId=-1&XID=O:kds-r50xbr1:dg_ggldf& kw=kds-r50xbr1&lp=8198552921665087995&productId= 8198552921665087995 A true and correct copy of that webpage is attached to this Declaration as Exhibit E. Exhibit E indicates that Sony Electronics, Inc. continues to sell refurbished KDS R50XBR1 model televisions. Exhibit E includes the following representation: SXRD technology is a new display technology developed by the legendary television engineers at Sony® to meet and exceed the demands of a High Definition image at its full 1080 line resolution. Digitally transmitted High Definition signals can contain over 2 million individual detail points that need to be displayed accurately and rapidly. SXRD displays those 2 million detail points per SXRD panel accurately since the 3 SXRD panels actually contain enough pixels to fully display a 1080 line picture without interlacing it. (Ex. E 2.) On November 13, 2007, I visited the following webpage: http://www.amazon.com/SONY-KDS-R60XBR1-Inch-Grand-Wega/dp/ B000BN7BDA/ref=sr_1_1?ie=UTF8&s=electronics&qid=1194993756&sr=8-1 A true and correct copy of that webpage is attached to this Declaration as
Declaration of Ethan Preston in Support of Motion for Preliminary Injunction and Conditional Class Certification 3 No. 07cv2126-JM(NLS)

Case 3:07-cv-02126-BEN-RBB

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Case 3:07-cv-02126-BEN-RBB

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No. 07cv2126-JM(NLS)

EXHIBIT A

Case 3:07-cv-02126-BEN-RBB

Document 7-3

Filed 11/15/2007

Page 6 of 44

KDS-R60XBR1
Grand WEGATM SXRDTM Rear Projection Television
Key Features SXRDTM Technology WEGA EngineTM HD System Cinema Black Pro ATSC Integrated Tuner with CableCARDTM Slot HDMITM (High Definition Multimedia Interface) PC Input (D-Sub 15pin)

Key Technologies SXRDTM Panels SXRD technology is a new display technology developed by the legendary television engineers at
Sony to meet and exceed the demands of a High Definition image at its full 1080 line resolution. Digitally transmitted High Definition signals can contain over 2 million individual detail points that need to be displayed accurately and rapidly. SXRD displays those 2 million detail points per SXRD panel accurately since the 3 SXRD panels actually contain enough pixels to fully display a 1080 line picture without interlacing it. SXRD has the speed to create a smooth, film like image. The SXRD panels have a blistering 2.5ms response time (total rise and fall time), which exceeds the demands of even the most rapidly moving High Definition images. And SXRD creates highly accurate, natural colors because the 3-panel design displays all the colors, all the time.

Cinema Black Pro Cinema Black Pro is an exclusive Sony function designed to improve contrast expression
especially in darker scenes. The Cinema Black Pro function is enabled by using either one or both of two features Iris Control and Advanced Iris. The Iris Control function sets the maximum size of the iris opening and sets the overall level of brightness. There are six settings that allow the user to adjust the iris opening to best match the room lighting conditions. The Advanced Iris function is a dynamic adjustment that automatically opens and closes the iris according to the gamma level of the picture on the screen. There are four different adjustments. The " High" setting is ideal for movies and music video content. And the " Off" setting works great for sports and news content.

WEGA EngineTM HD Because of the special demands HDTV places on signal quality a new generation of Sony's
exclusive WEGA EngineTM advanced picture quality system has evolved into WEGA EngineTM HD. Two innovative digital imaging processes have been added to improve overall picture quality. A High Contrast Image processor dynamically detects the histogram of each frame and instantly applies the ideal contrast level for crisper images. And the Natural High Density Picture image processor reduces noise elements by intelligently separating the noise from the video signal for a purer more detailed picture. Enjoy a stunning display of realistic images, amazing detail and sharpness, reduced noise and enhanced clarity with improved depth and contrast.

Case 3:07-cv-02126-BEN-RBB

Document 7-3

Filed 11/15/2007

Page 7 of 44

KDS-R60XBR1
Grand WEGATM SXRDTM Rear Projection Television
Features
General
Auto SAP: Yes Channel Fix: Yes ID1 Detection: Yes Video Label: Yes Program Guide Access: Yes Auto Channel Programming: Yes Menu Color: Yes Multiple Language Display: English, Español, Français Parental Control (V-Chip): Yes Info Banner: Yes Programmable Timer: 2 Event Sleep Timer: 15, 30, 45, 60, 90, Off Timer Events: Timer 1, Timer 2 Caption Vision: On, Off, Program Clock: Yes Power Save Mode: Standard, Reduced, Picture Off Built-In AC Adaptor: Yes Twin-ViewTM Technology: Yes Picture Freeze: Yes Power Consumption (in Standby): Less then 0.5W Power Requirements: AC 120V, 60Hz Power Management: Yes Power Consumption (CableCARDTM Function in Standby): Less than 30W (Also applies to i.LINK port.)

Video
Tuner: 8 VSB, ATSC, NTSC, Clear QAM, CableCARDTM QAM Video Processing: Yes Auto White Balance: Yes Color Temperature: Cool, Neutral, Warm Color Correction: High, Low, Off Noise Reduction: Yes Black Corrector: High, Medium, Low, Off Clear White: On, Off Gamma Compensation: High, Medium, Low, Off CineMotion® Reverse 3:2 Pulldown Technology: Yes Digital Texture Enhancer: High, Medium, Low, Off Direct Digital II Circuitry: Yes Advanced Iris: Yes Slide Show Mode: Slide Show transitions Display Mode for PC Input: Video, Text Comb Filter: 3D Digital Comb Filter DRC® MultiFunction Circuitry: Yes (DRC MF V1) DRC® Mode: Mode 1, Mode 2, CineMotion® Technology DRC® Palette Presets: Custom 1, Custom 2, Custom 3 Direct Mode: On, Off Game Mode: On/Off Game Picture: Yes Auto Adjustment (PC): Yes Phase (PC Only): Yes Pitch (PC Only): Yes Advanced Video Menu: Yes Picture Modes: Vivid, Standard, Pro Color System: ATSC, NTSC BN Smoother: Yes Wide Mode: Yes Display Technology: SXRDTM Technology

Regulation and Standard Compliance
Energy Star® Compliant: Yes

Service and Warranty Information
Limited Warranty: 1 Year Parts / 1 Year Labor

Dimensions
Weight: 112lbs 7oz (51Kg) Measurements: 65 10/11 x 39 8/11 x 20 3/13" (1674 x 1009 x 514mm)

Supplied Accessories
Remote Control (RM-Y914) Operating Instructions Quick Start Guide Batteries (AAA x2) Warranty Product Registration Card

Specifications
General
Aspect Ratio: 16:9 Screen Size: 60"1

Video
Native Resolution: 1080p Horizontal Scan (KHz) for PC: 15 different frequencies Display Resolution: 1920 x 1080 Overscan: Normal, +1, +2 Viewing Angle: Right/Left: 130° Up/Down: 60° , Display Response Time: 2.5ms Vertical Size: Yes Vertical Center: +10 to -10 Horizontal Center: +63 to -64 Vertical Frequency (Hz): 6 different frequencies

Optional Accessories
SU-GW12 (AV Stand) XL-5100 (120W Replacement Lamp) UPC Code: 027242681118
Confidential Sony Information. For Internal Use Only. 1. Screen Size measured diagonally 2. For additional information on viewing angles please consult the Owner's Manual. ©2005 Sony Electronics Inc. All rights reserved. Sony, Qualia, Grand WEGA, S-Master, Steady Sound, WEGA GATE, WEGA Engine, Speed Surf, Memory Stick, SXRD, i.LINK, CineMotion and DRC are trademarks of Sony. CableCARD is a trademark of Cable Television Laboratories, Inc. SRS and the SRS symbol, and TruSurround are trademarks of SRS Labs, Inc. This TV incorporates High-Definition Multimedia Interface (HDMITM ) technology. HDMI, the HDMI logo and High-Definition Multimedia Interface are trademarks or registered trademarks of HDMI Licensing LLC. All other trademarks are property of their respective owners. Features and specifications are subject to change without notice. Nonmetric weights and measures are approximate.

Audio
Speaker Type: Round Cone Speakers (Total): 4 Full Range Speaker Size: 3 1/4" Audio Power Output: 30W Total (15W x 2)

Inputs and Outputs
Analog Audio Input(s): 6 (1 Front/5 Rear) Audio Out (Variable/Fixed): 1 (Rear) CableCARDTM Slot: 1 (Rear) Component Video (Y/Pb/Pr ) Input(s): 2 (Rear) Composite Video Input(s): 3 (1 Front/2 Rear) Control-S Input(s): 1 (Rear) Control-S Output(s): 1 (Rear) i.LINK® Connection: 3 (1 Front/ 2 Rear) Memory Stick® Media Slot: 1 (Front) - Memory Stick DuoTM , Memory Stick PRO DuoTM , Memory Stick PROTM Media Compatibility RF Connection Input(s): 2 (Rear) S-Video Input(s): 3 (1 Front/2 Rear) PC Audio Input(s): 1 (Rear) PC Video Input(s): 1 (Rear) Optical Audio Digital Output(s): 1 (Rear) Dolby® Digital

Audio
Tone Control(s): Treble, Bass Sound Mode: Dynamic, Clear Voice, Natural MTS Stereo Decoder: Yes Digital Amplifier: Yes (S-Master® Digital Amplifier) Audio Mute: Yes Speaker On/Off: Yes Simulated Surround: Yes SRS® TruSurround® Audio Effect: Yes Dolby® Digital: Yes

Convenience
Channel Label: Yes Channel Skip/Add: Yes Channel Jump: Yes Favorite Channel: Yes Speed SurfTM Channel Selection: Yes

Power
Internal Power Supply: Yes Power Consumption (in Operation): 240W
Please visit the Dealer Network for current information at www.sony.com/dn

Sony Electronics Inc. · 16530 Via Esprillo Drive · San Diego, CA 92127 · 1-800-222-7669 · www.sony.com

Last Updated: 08/31/2006

Case 3:07-cv-02126-BEN-RBB

Document 7-3

Filed 11/15/2007

Page 8 of 44

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
No. 07cv2126-JM(NLS)

EXHIBIT B

Case 3:07-cv-02126-BEN-RBB

Document 7-3

Filed 11/15/2007

Page 9 of 44

KDS-R50XBR1
Grand WEGATM SXRDTM Rear Projection Television
Key Features SXRDTM Technology WEGA EngineTM HD System Cinema Black Pro ATSC Integrated Tuner with CableCARDTM Slot HDMITM (High Definition Multimedia Interface) PC Input (D-Sub 15pin)

Key Technologies SXRDTM Panels SXRD technology is a new display technology developed by the legendary television engineers at
Sony® to meet and exceed the demands of a High Definition image at its full 1080 line resolution. Digitally transmitted High Definition signals can contain over 2 million individual detail points that need to be displayed accurately and rapidly. SXRD displays those 2 million detail points per SXRD panel accurately since the 3 SXRD panels actually contain enough pixels to fully display a 1080 line picture without interlacing it. SXRD has the speed to create a smooth, film like image. The SXRD panels have a blistering 2.5ms response time (total rise and fall time), which exceeds the demands of even the most rapidly moving High Definition images. And SXRD creates highly accurate, natural colors because the 3-panel design displays all the colors, all the time.

Cinema Black Pro Cinema Black Pro is an exclusive Sony function designed to improve contrast expression
especially in darker scenes. The Cinema Black Pro function is enabled by using either one or both of two features Iris Control and Advanced Iris. The Iris Control function sets the maximum size of the iris opening and sets the overall level of brightness. There are six settings that allow the user to adjust the iris opening to best match the room lighting conditions. The Advanced Iris function is a dynamic adjustment that automatically opens and closes the iris according to the gamma level of the picture on the screen. There are four different adjustments. The " High" setting is ideal for movies and music video content. And the " Off" setting works great for sports and news content.

WEGA EngineTM HD Because of the special demands HDTV places on signal quality a new generation of Sony's
exclusive WEGA EngineTM advanced picture quality system has evolved into WEGA EngineTM HD. Two innovative digital imaging processes have been added to improve overall picture quality. A High Contrast Image processor dynamically detects the histogram of each frame and instantly applies the ideal contrast level for crisper images. And the Natural High Density Picture image processor reduces noise elements by intelligently separating the noise from the video signal for a purer more detailed picture. Enjoy a stunning display of realistic images, amazing detail and sharpness, reduced noise and enhanced clarity with improved depth and contrast.

Case 3:07-cv-02126-BEN-RBB

Document 7-3

Filed 11/15/2007

Page 10 of 44

KDS-R50XBR1
Grand WEGATM SXRDTM Rear Projection Television
Features
General
Auto SAP: Yes Channel Fix: Yes ID1 Detection: Yes Video Label: Yes Speed SurfTM Channel Selection: Yes Program Guide Access: Yes Auto Channel Programming: Yes Menu Color: Yes Multiple Language Display: English, Español, Français Parental Control (V-Chip): Yes Info Banner: Yes Programmable Timer: 2 Event Sleep Timer: 15, 30, 45, 60, 90, Off Timer Events: Timer 1, Timer 2 Caption Vision: On, Off, Program Clock: Yes Power Save Mode: Standard, Reduced, Picture Off Built-In AC Adaptor: Yes Twin-ViewTM Technology: Yes Picture Freeze: Yes

Power
Internal Power Supply: Yes Power Consumption (in Operation): 240W Power Consumption (in Standby): 0.5W Power Requirements: AC 120V, 60Hz Power Management: Yes Power Consumption (CableCARDTM Function in Standby): Less than 30W (Also applies to i.LINK port.)

Video
Tuner: 8 VSB, ATSC, NTSC, Clear QAM, CableCARDTM QAM Video Processing: Yes Auto White Balance: Yes Color Temperature: Cool, Neutral, Warm Color Correction: High, Low, Off Noise Reduction: Yes Black Corrector: High, Medium, Low, Off Clear White: On, Off Gamma Compensation: High, Medium, Low, Off CineMotion® Reverse 3:2 Pulldown Technology: Yes Digital Texture Enhancer: High, Medium, Low, Off Direct Digital II Circuitry: Yes Advanced Iris: Yes Slide Show Mode: Slide Show transitions Display Mode for PC Input: Video, Text Comb Filter: 3D Digital Comb Filter DRC® MultiFunction Circuitry: Yes (DRC MF V2) DRC® Mode: Mode 1, Mode 2, CineMotion® Technology DRC® Palette Presets: Custom 1, Custom 2, Custom 3 Direct Mode: On, Off Game Mode: On/Off Game Picture: Yes Auto Adjustment (PC): Yes Phase (PC Only): Yes Pitch (PC Only): Yes Advanced Video Menu: Yes Picture Modes: Vivid, Standard, Pro Color System: ATSC, NTSC BN Smoother: Yes Wide Mode: Yes Display Technology: SXRDTM Technology

Regulation and Standard Compliance
Energy Star® Compliant: Yes

Service and Warranty Information
Limited Warranty: 1 Year Parts / 1 Year Labor

Dimensions
Weight: 94lbs 13oz (43Kg) Measurements: 57 1/4" x 34" x 18 7/8" (1453 x 863 x 478 mm)

Specifications
General
Aspect Ratio: 16:9 Screen Size: 50"1

Supplied Accessories
Remote Control (RM-Y914) Operating Instructions Quick Start Guide Batteries (AAA x2) Warranty Product Registration Card

Video
Native Resolution: 1080p Horizontal Scan (KHz) for PC: 15 different frequencies Display Resolution: 1920 x 1080 Overscan: Normal, +1, +2 Viewing Angle: Right/Left: 130° Up/Down: 60° , Display Response Time: 2.5ms Vertical Size: Yes Vertical Center: +63 to -64 Horizontal Center: +63 to -64 Vertical Frequency (Hz): 6 different frequencies

Optional Accessories
SU-GW12 (AV Stand) XL-5100 (120W Replacement Lamp) UPC Code: 027242681101
Confidential Sony Information. For Internal Use Only. 1. Screen Size measured diagonally 2. For additional viewing angle information please consult the Owner's Manual. ©2005 Sony Electronics Inc. All rights reserved. Sony, Qualia, Grand WEGA, S-Master, Steady Sound, WEGA Engine, Speed Surf, Memory Stick, SXRD, i.LINK, CineMotion and DRC are trademarks of Sony. CableCARD is a trademark of Cable Television Laboratories, Inc. SRS and the SRS symbol, and TruSurround are trademarks of SRS Labs, Inc. This TV incorporates High-Definition Multimedia Interface (HDMITM ) technology. HDMI, the HDMI logo and High-Definition Multimedia Interface are trademarks or registered trademarks of HDMI Licensing LLC. All other trademarks are property of their respective owners. Features and specifications are subject to change without notice. Nonmetric weights and measures are approximate.

Audio
Speaker Type: Round Cone Speakers (Total): 4 Full Range Speaker Size: 3 1/4" Audio Power Output: 30W Total (15W x 2)

Inputs and Outputs
Analog Audio Input(s): 6 (1 Front/5 Rear) Audio Out (Variable/Fixed): 1 (Rear) CableCARDTM Slot: 1 (Rear) Component Video (Y/Pb/Pr ) Input(s): 2 (Rear) Composite Video Input(s): 3 (1 Front/2 Rear) Control-S Input(s): 1 (Rear) Control-S Output(s): 1 (Rear) i.LINK® Connection: 3 (1 Front/2 Rear) Memory Stick® Media Slot: 1 (Front) - Memory Stick DuoTM , Memory Stick PRO DuoTM , Memory Stick PROTM Media Compatibility RF Connection Input(s): 2 (Rear) S-Video Input(s): 3 (1 Front/2 Rear) PC Audio Input(s): 1 (Rear) PC Video Input(s): 1 (Rear) HDMITM Connection(s): 2 (Rear) - 1 rear input included L/R audio inputs Optical Audio Digital Output(s): 1 (Rear) Dolby® Digital

Audio
Tone Control(s): Treble, Bass Sound Mode: Dynamic, Clear Voice, Natural MTS Stereo Decoder: Yes Digital Amplifier: Yes (S-Master® Digital Amplifier) Audio Mute: Yes Speaker On/Off: Yes Simulated Surround: Yes SRS® TruSurround® Audio Effect: Yes Dolby® Digital: Yes

Convenience
Channel Label: Yes Channel Skip/Add: Yes Channel Jump: Yes Favorite Channel: Yes

Please visit the Dealer Network for current information at www.sony.com/dn

Sony Electronics Inc. · 16530 Via Esprillo Drive · San Diego, CA 92127 · 1-800-222-7669 · www.sony.com

Last Updated: 08/31/2006

Case 3:07-cv-02126-BEN-RBB

Document 7-3

Filed 11/15/2007

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No. 07cv2126-JM(NLS)

EXHIBIT C

KDS R60XBR13:07-cv-02126-BEN-RBB Case - Google Product Search Web Images Video News Maps

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Sony KDS-R60XBR1 60" SXRD TV

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Sony KDS-R60XBR1 Grand WEGA SXRD Rear Projection 60" HDTV, Native ...

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No. 07cv2126-JM(NLS)

EXHIBIT D

KDS R50XBR13:07-cv-02126-BEN-RBB Case - Google Product Search Web Images Video News Maps

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http://google.com/products?q=KDS+R50... Filed 11/15/2007 Page 16 of 44 My Shopping List

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Sony KDS-R50XBR1

Sony KDS-R50XBR1 CNET did not review the Sony KDS-R50XBR1, but we did review the larger version, the Sony KDS-R60XBR1. Specs: Rear projection TV, 50 in, ... 47 reviews - Add to Shopping List

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SONY KDS R50XBR1. Display = Rear projection TV. Numb. 47 reviews - Add to Shopping List -

Sony KDS-R50XBR1

50" Grand WEGATM SXRDTM Rear Projection HDTV. 47 reviews - Add to Shopping List

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EXHIBIT E

SonyStyle.com | REFURBISHED - 50" Gra...Document Case 3:07-cv-02126-BEN-RBB

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REFURBISHED - 50" Grand WEGATM SXRDTM Rear Projection HDTV

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Thin, but powerful, the Sony KDS-R50XBR1 Grand WEGATM SXRDTM Rear Projection HDTV is equipped with SXRD technology and offers a brilliant, colorful image pleasing to any pair of eyes. SXRD technology employs three Silicon X-tal Reflective Display panels, which aid in the response time of image changes and movement. Each one of these panels is associated to a primary color: red, blue or green. These panels combine their monochromatic colors into one creating a single, full color image that is displayed onto the screen via an energy-efficient high output lamp (RGB Image 1920 x 1080). Other features of the KDS-R50XBR1 include WEGA GATETM Easy Operation Guide for easy channel and television function use as well as CineMotion® technology, which provides reverse 3:2 pull down technology for smoother picture movement when playing back movies or other video sources on film. Sony's WEGA EngineTM system also minimizes signal distortion providing you with the best HD picture and sound for hours of viewing pleasure. SXRDTM Panels SXRD technology is a new display technology developed by the legendary television engineers at Sony® to meet and exceed the demands of a High Definition image at its full 1080 line resolution. Digitally transmitted High Definition signals can contain over 2 million individual detail points that need to be displayed accurately and rapidly. SXRD displays those 2 million detail points per SXRD panel accurately since the 3 SXRD panels actually contain enough pixels to fully display a 1080 line picture without interlacing it. SXRD has the speed to create a smooth, film like image. The SXRD panels have a blistering 2.5ms response time (total rise and fall time), which exceeds the demands of even the most rapidly moving High Definition images. And SXRD creates highly accurate, natural colors because the 3-panel design displays all the colors, all the time. Cinema Black Pro Cinema Black Pro is an exclusive Sony function designed to improve contrast expression especially in darker scenes. The Cinema Black Pro function is enabled by using either one or both of two features - Iris Control and Advanced Iris. The Iris Control function sets the maximum size of the iris opening and sets the overall level of brightness. There are six settings that allow the user to adjust the iris opening to best match the room lighting conditions. The Advanced Iris function is a dynamic adjustment that automatically opens and closes the iris according to the gamma level of the picture on the screen. There are four different adjustments. The "High" setting is ideal for movies and music video content. And the "Off" setting works great for sports and news content. WEGA EngineTM HD Because of the special demands HDTV places on signal quality a new generation of Sony's exclusive WEGA EngineTM advanced picture quality system has evolved into WEGA EngineTM HD. Two innovative digital imaging processes have been added to improve overall picture quality. A High Contrast Image processor dynamically detects the histogram of each frame and instantly applies the ideal contrast level for crisper images. And the Natural High Density Picture image processor reduces noise elements by intelligently separating the noise from the video signal for a purer more detailed picture. Enjoy a stunning display of realistic images, amazing detail and sharpness, reduced noise and enhanced clarity with improved depth and contrast. HDMITM and PC Inputs Designed for maximum versatility, Sony's Grand WEGATM XBR® line is equipped with a comprehensive range of input interfaces. The HDMI (High-Definition Multimedia Interface) is the first industry-supported, uncompressed, all-digital audio/video interface. HDMI technology supports enhanced or High Definition video, together with multi-channel digital audio to provide matchless image and sound reproduction. The PCD input (HD-15-pin) offers easy connection to your PC, allowing you to use your high resolution Grand WEGA XBR TV as a computer monitor.

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EXHIBIT F

Amazon.com: SONY KDS-R60XBR1 60 Inch Grand Weg...

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SONY KDS-R60XBR1 60 Inch Grand Wega(TM) XBR(R) HDTV
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Technical Details
SXRD Technology with WEGA Engine HD System Cinema Black Pro ATSC Integrated Tuner with CableCARD Slot WEGA GATE - Easy Operation Guide HDMI (High Definition Multimedia Interface)

> See more technical details Product Details
Product Manual [3.90mb PDF] Product Dimensions: 136 pounds Shipping Weight: 295.7 pounds ASIN: B000BN7BDA Item model number: KDS-R60XBR1 Average Customer Review: (8 customer reviews) Amazon.com Sales Rank: #46,784 in Electronics (See Bestsellers in Electronics) Popular in this category: (What's this?) #51 in Electronics > TVs & HDTVs > Projection TVs > LCD Projection TVs Date first available at Amazon.com: November 26, 2006 Would you like to update product info or give feedback on images? (We'll ask you to sign in so we can get back to you)

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Case 3:07-cv-02126-BEN-RBB Product Description

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Product Description This 60" Grand Wega(TM) Rear-projection LCD TV is a magnificent widescreen TV. When viewed at different angles and different situations, other rear-projection television models pale in comparison. With a built-in ATSC TV tuner, you can receive free off-the-air HDTV broadcasts (an optional HDTV antenna is required). And this set has a 1080p service resolution for up to 1920x1080 resolution. It can also be used as a PC display - imagine playing videogames or viewing the Internet on this 60" (diagonal) screen. This is home-theater extraordinaire. PC Input (D-Sub 15pin) CineMotion Reverse 3 - 2 Pulldown SRS TruSurround XT equipped for 2 channel virtual surround sound (for 5.1 channels or more, check out one of the optional Sony home-theater dream systems) S-Master Digital Amplifier Twin-View - Picture and Picture SteadySound(TM) keeps volume at a constant listening level Memory Stick Media Viewer Native Resolution - 1080i (3 SXRD Panels - 1920 x 1080) / 0.61 SXRD Panel (1920 x 1080) 120 Watt Lamp TOS Link - Digital Optical Output Audio Optical Output (TOS Link) New ?Edge? Design Connections - i.LINK(R) Interface - 3 (1 Front / 2 Rear) / Component video (Y/Pb/Pr ) Input(s) - 2 (2 Rear) / S-VIDEO INPUT(s) - 3 (1 Front / 2 Rear) Auto Detect on Video 1 only / Composite Video Input(s) - 3 (1 Front / 2 Rear) / RF Connection Input(s) - 2 (2 Rear) / Audio In - 6 (1 Front / 5 Rear) / Digital Audio Output(s) - 1 (1 Rear) - PCM/Dolby Digital (Optical) / Analog Audio Output(s) - 1 (1 Rear) - Fixed / Variable / Control-S Input(s) - 1 (1 Rear) / Control-S Output(s) - 1 (1 Rear) 15 Watts by 2 channel stereo sound to built-in speakers Unit Dimensions Width - 66 x Height - 39 3/4 x Depth - 20 1/4 // Unit Weight (Approx.) - 112 lbs 7 oz

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Average Customer Review (8 customer reviews)

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The easiest way to shoot video reviews. Most Recent Customer Reviews Very Disappointed again in Sony I purchased this television 15 months ago from AFEES. Now I see I paid too much. Too bad they only back their purchases for one year. Read more
Published 22 days ago by Paul Lampley

Most Helpful Customer Reviews 58 of 59 people found the following review helpful: Elegant design, Spectacular Picture, October 27, 2005 By Dave - See all my reviews I bought Sony's 60" SXRD after spending the last year researching big screen TVs. The picture quality is top notch- blacks on par with those of a CRT or plasma television and stunning visual clarity. The liquid crystal on Silicon (LCoS) technology combines the best qualities of DLP and LCD projection TV sets; the picture quality of Sony's SXRD LCoS impressed me more than JVC's D-ILA LCoS. There is no screen door effect on this TV and it displays motion well. The user interface is very user friendly and I was able to access the vast majority of the television's functions without referencing the user's manual. There are more open inputs than I need (8 total, including a few accessible from the front) and the Picture in Picture can be used from both multiple inputs (e.g. DVD and Cable) or from the same input (e.g. both frames from the cable box) Analog TV appears as good or better than other TVs this size and HD is incredible. With any TV this size, however, be aware that flaws in the picture quality of a broadcast signal will be more apparent. This hasn't been a problem with DVDs or HD channels. The 60" SXRD also looks more elegant than other sets in this range, nice given that a set this size will dominate any room it's in. It's also light weight enough to be moved easily by two people. I'm happy that I bought this model and strongly recommend it. Comment | Permalink | Was this review helpful to you? (Report this)

1080p TV, is that right? I purchased this TV April 2006. The TV was advertised as 1080p capable. Salesperson in a store said that it can show 1080p resolution pictures. Read more
Published 10 months ago by D. Paik

GREAT SHARP PICTURE BUT...... This is picture perfect TV, I always loves SONY TV'S and I always buy SONY brand comes to buy TV'S most my life. Read more
Published 18 months ago by Benjamin Kidman

The best option out there. We've had our Grand Wega for over a year now and it is the most amazing tv out there. Nothing compares to it. Read more
Published 22 months ago by Ellen

What is the deal? $4100 for 60" and $4000 for 50" as of 12/26/05 at amazon.com I noticed an earlier poster commented on price flucuations. As of Monday 26 December 2005 Amazon.com is quoting "$ 4099.99 for a 60 inch Sony SXRD KDS-R60XBR1 and $3999. Read more

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Published 22 months ago by George from Washington

48 of 51 people found the following review helpful: Stunning picture quality!, November 28, 2005 By G.E. (Seattle, WA) - See all my reviews I looked at half a dozen 1080p true HDTVs in October 2005 before settling on the KDS-R50XBR1 (the 50" little brother to this TV). I am thrilled with the picture quality, especially after fine-tuning the Brightness, Contrast, Picture, and RGB balance settings using the Avia calibration DVD. Especially on true HDTV 1920x1080 sources, this TV has an absolutely outstanding picture! In fact, it's more like watching a film or looking out a window than a mere television picture. The SXRD picture is liquid smooth and silky with no screen door effect or harsh "graininess" you see in competing technologies such as DLP, LCD, and even plasma. One important note: If you are debating between the 50" and 60" models, you should know that both models use the same 120 watt bulb. With the 60" model having approximately 20% more screen surface area to light up, that translates to approximately a 20% dimmer picture than the 50 inch model. (If you ask me, it's not a "bright" idea to use the same bulb wattage for two projection TVs of different sizes, but I guess it keeps manufacturing costs down.) Compare the two models side by side on the same HDTV content (I did) and you'll see a marked difference in the vividness of the whites and bright colors. The KDS-R50XBR1 50" really "pops" (like looking out the window on a sunny day); whereas the KDS-R60XBR1 60" looks merely average in the brightness department (the overall picture is still excellent, just a bit dimmer). For me, I decided that a smaller screen with a brighter picture was more important than a big screen with a slightly dimmer picture - especially since this TV sits in a daylight room. Hopefully Sony will correct this oversight in a future SXRD model because the 60" picture is considerably more impressive purely from a size perspective. The pros: Its magnificent picture quality! SXRD is probably the finest picture you can buy for under $12,000. It has advanced picture fine-tuning feature for prosumers. The 50" model has a dazzling bright display that outshines everything I've seen so far. The cons: The side speakers are relatively weak with no bass response (as one would expect from their diminutive size). They are not detachable, and add a considerable amount of horizontal width to this TV's footprint. They ought to be made detachable or placed beneath the screen instead at the sides. Also, there are only 2 HDMI ports. It is quite conceivable that a person might have 3-4 HDMI devices (Bluray DVD, Playstation 3, Dish Network, Digital Cable, etc.) but most TVs on the market only have 1-2 HDMI ports so this is not unusual. Daytime viewing is generally very good as long as no direct light hits the TV screen; however, projection TVs still don't seem as bright as the old cathode ray tube (CRT) TVs. Comment | Permalink | Was this review helpful to Search Customer Reviews
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37 of 38 people found the following review helpful: Price has decreased 25% in 2 months since introduction and before Christmas/New Years/Superbowl season., December 6, 2005 By Elegant_gentleman "Engineer" (Federal Way, Washington (state) USA) - See all my reviews I welcome the opportunity to share my perspective as an owner of a SONY SXRD KDS-R60XBR1. I notice that the Amazon.com price has decreased 25% since the item became widely available in October 2005. I obtained mine through a traditional brick and mortar retailer, but believe the associates of Amazon.com can perform just as well. The item performs an excellent job. Once I had the cable card installed by the cable company the performance was outstanding, the best I've ever seen. On standard digital (SD) transimissions such as a 4:3 NTSC 480i HBO thru the cable card, I was wondering why the "16:9 HD" picture was cropped. It was an optical illusion. The clean-up, etc. circuits were that perfect. There are a minimum of 22 adjusts possible on "Pro" view mode. There are many others that only a ISF certified calibration technician with professional equipment should use for greyscale. A few notes about the information on this Amazon.com webpage as of 06 December 2005 --- the mass/weight of the item is about 120 pounds, not 300 pounds. The brightness of the 60" unit is fine in my living room at mid-day with all the lights on and shades open. (My windows face west). Hands down I think it beats the JVC LCOS, any wobulator DLP, and in most situations "all" front projectors (which require ideal conditions). As of December 2005 I have not seen a Hitachi LCOS or LG LCOS, but do not expect them (a first generation product) to be on par with this second generation Sony. (Sony Quallia was first generation). I have heard second hand from folks that have visited the trade show in Las Vegas that the Toshiba/Canon SED will not be price competitive. (Their opinions vary with regrd to performance results of the pre-production SED). If you have not seen a Sony SXRD LCOS 1080P display being feed with a dedicated source, you owe it to yourself. NOTE: Some retailers have Mitsi wobulator DLPs feed one on one by hard drives with true 1080P source. That is a huge advantage compared to a splitter of over-the=-air HDTV signal. But it is not realistic for the average consumer. Before you buy any TV display based on your subject viewing, watch it for 15 minutes and find out the quality of the source feed and how many times it is split upstream of your desired representative product. Bottom line is it looks like JVC low-balled the prices on their LCOS and retailers are cutting (the substantial) margin on the Sony LCOS SXRD to match. Sony is adding a 1000 humans and who knows how many robots in their factory in Pittsburgh, PA, USA to crank these babbies out. If you are a babby boomer, you know the meaning of the Wall Street Journal article of April 2005 that revealed that Sony's business mocel is to re-establish their dominance of the (HD)TV market with the SXRD in the years 2006, 2007 much like the Sony Trinitron made their reputation in the late 1960's. Thank you Sony. I'll report back after my unit is ISF calibrated. Comment | Permalink | Was this review helpful to

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1. Sound And Vision Magazine: Sony KDS-R60XBR1 Unless otherwise indicated, all tests were conducted with 1080i-format signals via the TV's HDMI input. Color temperature (Low color temperature ... > Read full review at www.soundandvisionmag.com 2. Home Theater: Sony KDS-R60XBR1 LCOS HDTV I just can't resist poking fun at Sony's seemingly unending supply of strange and unpronounceable nomenclature. It has no direct ... > Read full review at www.hometheatermag.com 3. Ultimate AV: Sony VPL-VW100 SXRD Video Projector Part I When our Photo Research PR-650 SpectraScan Colorimeterthe tool we use to calibrate most of the projectors we reviewwent into the ... > Read full review at www.ultimateavmag.com << Previous | Next >>

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No. 07cv2126-JM(NLS)

EXHIBIT G

Amazon.com: Sony KDS-R50XBR1 50" Grand Wega SXR...

http://www.amazon.com/gp/product/B000BN65NM/sr=8...

Case 3:07-cv-02126-BEN-RBB

Document 7-3

Filed 11/15/2007

Page 32 of 44

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Sony KDS-R50XBR1 50" Grand Wega SXRD high-definition 1080p rear-projection TV
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Technical Details
high-definition TV -- receives and decodes digital standard-definition and HDTV signals from over-the-air broadcasts (antenna required) and cable TV service (CableCARD required) widescreen 16:9 aspect ratio 1080p 3-SXRD light engine (1920 x 1080 pixels)

> See more technical details Product Details
Product Manual [3.90mb PDF] Product Dimensions: 124 pounds Shipping Weight: 113 pounds ASIN: B000BN65NM Item model number: KDS-R50XBR1 Average Customer Review: (23 customer reviews) Amazon.com Sales Rank: #43,424 in Electronics (See Bestsellers in Electronics) Popular in these categories: (What's this?) #15 in Electronics > TVs & HDTVs > HDTVs > HDTV LCoS Projection TVs #29 in Electronics > TVs & HDTVs > HDTVs > HDTV CRT Projection TVs Date first available at Amazon.com: April 18, 2005 Would you like to update product info or give feedback on images? (We'll ask you to sign in so we can get back to you)

1 of 8

11/13/2007 01:17 PM

Amazon.com: Sony KDS-R50XBR1 50" Grand Wega SXR...

http://www.amazon.com/gp/product/B000BN65NM/sr=8...

Case 3:07-cv-02126-BEN-RBB Product Description

Document 7-3

Filed 11/15/2007

Page 33 of 44

Product Description high-definition TV -- receives and decodes digital standard-definition and HDTV signals from over-the-air broadcasts (antenna required) and cable TV service (CableCARD required) * widescreen 16:9 aspect ratio * 1080p 3-SXRD light engine (1920 x 1080 pixels) *

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2 of 8

11/13/2007 01:17 PM

Amazon.com: Sony KDS-R50XBR1 50" Grand Wega SXR...

http://www.amazon.com/gp/product/B000BN65NM/sr=8...

Case 3:07-cv-02126-BEN-RBB

Document 7-3

Filed 11/15/2007

Page 34 of 44

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Customer Reviews
5 4 3 2 1 23 Reviews star: (8) star: (0) star: (2) star: (5) star: (8)

Average Customer Review (23 customer reviews)

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The easiest way to shoot video reviews. Most Recent Customer Reviews It WAS too good to be true. When "everyone" (friends, co-workers, consumer reviews) said the Sony Wega SXRD was THE BEST HDTV, I splurged and spent $2600 in January 2007 on a KDS-R50BR1 as a retirement gift... Read more
Published 26 days ago by April Elizabeth

Most Helpful Customer Reviews 67 of 67 people found the following review helpful: Stunning picture quality!, November 28, 2005 By G.E. (Seattle, WA) - See all my reviews I looked at half a dozen 1080p true HDTVs in October 2005 before settling on the KDS-R50XBR1 (there is also a KDS-R60XBR1 60" big brother to this TV). I am thrilled with the picture quality, especially after fine-tuning the Brightness, Contrast, Picture, and RGB balance settings using the Avia calibration DVD. Especially on true HDTV 1920x1080 sources, this TV has an absolutely outstanding picture! In fact, it's more like watching a film or looking out a window than a mere television picture. The SXRD picture is liquid smooth and silky with no screen door effect or harsh "graininess" you see in competing technologies such as DLP, LCD, and even plasma.

Defective Design, This model on recall list!!! This model and the 60 " version are on the recall list. Stay away from this one. Defective light engine which is the heart of the TV. Read more
Published 1 month ago by M. harris

3 of 8

11/13/2007 01:17 PM

Amazon.com: Sony KDS-R50XBR1 50" Grand Wega SXR...

http://www.amazon.com/gp/product/B000BN65NM/sr=8...

Case 3:07-cv-02126-BEN-RBB

Document 7-3

Filed 11/15/2007

Page 35 of 44

One important note: If you are debating between the 50" and 60" models, you should know that both models use the same 120 watt bulb. With the 60" model having approximately 20% more screen surface area to light up, that translates to approximately a 20% dimmer picture than the 50 inch model. (If you ask me, it's not a "bright" idea to use the same bulb wattage for two projection TVs of different sizes, but I guess it keeps manufacturing costs down.) Compare the two models side by side on the same HDTV content (I did) and you'll see a marked difference in the vividness of the whites and bright colors. The KDS-R50XBR1 50" really "pops" (like looking out the window on a sunny day); whereas the KDS-R60XBR1 60" looks merely average in the brightness department (the overall picture is still excellent, just a bit dimmer). For me, I decided that a smaller screen with a brighter picture was more important than a big screen with a slightly dimmer picture - especially since this TV sits in a daylight room. Hopefully Sony will correct this oversight in a future SXRD model because the 60" picture is considerably more impressive purely from a size perspective. The pros: Its magnificent picture quality! SXRD is probably the finest picture you can buy for under $12,000. It has advanced picture fine-tuning feature for prosumers. The 50" model has a dazzling bright display that outshines everything I've seen so far. The cons: The side speakers are relatively weak with no bass response (as one would expect from their diminutive size). They are not detachable, and add a considerable amount of horizontal width to thi