This is from the Netflix Analyst Day 2008 webcast:
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On May 28th, from 'Netflix Analyst Day 2008': The other 3 Instant Watch hardware partners are on target for 08/09 releases. Netflix has created an SDK that can be added to existing Blu-Ray players (that have internet connections) to allow them to stream Netflix movies the same way the The Roku Netflix Player does. It is now up to the Blu-Ray player makers to add this feature into their firmware. The same applies to the XBox 360.
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It seems as if the ball is now in Sony's court. As a long time Netflix subscriber I would love to see this implemented for the PS3.