`
`In these Infringement Contentions, Blitzsafe contends that at least the following claims of U.S. Patent No. 8,155,342 (“’342 patent”)
`identified below are infringed by the infotainment systems in accused Kia automobiles. Blitzsafe does not concede that any claims of the ’342
`patent that are not listed below are not infringed by the infotainment systems in accused Kia automobiles. Moreover, the citations to certain
`documents and other information below are intended to be exemplary only and in no way foreclose Blitzsafe from citing or relying on additional
`documents, information, and/or testimony at a later time. These contentions are preliminary in nature, and an analysis of Kia’s infotainment
`systems, internal documentation, source code, and/or testimony from relevant witnesses may be necessary to more fully and accurately
`describe the infringing features of its accused products. Accordingly, Blitzsafe reserves the right to supplement, correct, modify, and/or amend
`these contentions once such additional information is made available to Blitzsafe. Furthermore, Blitzsafe reserves the right to supplement,
`correct, modify, and/or amend these contentions as discovery in this case progresses; in view of the Court’s claim construction order(s); in view
`of any positions taken by Kia, including but not limited to positions on claim construction, invalidity, and/or non-infringement; and in connection
`with the preparation and exchange of expert reports.
`
`Claim
`49[P]. A
`multimedia
`device
`integration
`system,
`comprising:
`[49A] an
`integration
`subsystem in
`communication
`with a car
`audio/video
`system; and
`
`Support
`Each accused Kia automobile includes a device integration system that supports integration of audio/video devices, such as
`freely lying smartphones and other smart devices connected via Bluetooth, as well as MP3 players (e.g., iPods, iPhones and
`Zune devices playing MP3 files). Accused Kia automobiles also permit audio streaming over Bluetooth from smartphone
`apps, such as Pandora, iTunes streaming, and Apple Music.
`
`
`Each device integration system of an accused Kia automobile includes, among other things, an integration subsystem for
`connecting the car audio/video system to portable devices via a Bluetooth connection. The integration subsystem, which
`comprises at least the software and hardware shown in the yellow dashed boxes below, including at least a Freescale
`microcontroller and memory modules, is in communication with the car audio/video system. The integration subsystem
`channels audio signals to the car stereo from a portable device (such as an iPod, iPhone, Zune device or other smart device)
`external to the car audio/video system.
`
`
`
`
`1
`
`Petitioners
`Exhibit 1005, App. D, Page 1
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`2
`
`Petitioners
`Exhibit 1005, App. D, Page 2
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`3
`
`Petitioners
`Exhibit 1005, App. D, Page 3
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2014 Kia Soul User’s Manual) at 4:178.1
`
`
`
`
`
`1 Blitzsafe has produced Ex. A, 2014 Kia Soul User’s Manual, simultaneously with these Infringement Contentions as a document bearing production numbers
`BS-HK-0000880 – 1379. All pin-cites are to manual pages.
`
`
`
`4
`
`Petitioners
`Exhibit 1005, App. D, Page 4
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`5
`
`Petitioners
`Exhibit 1005, App. D, Page 5
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:27-28.2
`
`See, e.g., video (Stream Music from Your Smart Phone - 2014 Kia Uvo eServices Infotainment System with Navigation:
`https://www.youtube.com/watch?v=4LvVqYtcTho).
`
`Each device integration system of the accused Kia automobiles includes a first wireless interface (a Bluetooth interface in
`the form of a Bluetooth controller and/or antenna and related circuitry, including at least the circuitry shown in the yellow
`
`
`
`[49B] a first
`wireless
`
`
`2 Blitzsafe has produced Ex. B, 2015 Kia Soul UVO Manual, simultaneously with these Infringement Contentions as a document bearing production numbers BS-
`HK-0000739 – 875. All pin-cites are to manual pages.
`
`
`
`6
`
`Petitioners
`Exhibit 1005, App. D, Page 6
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Support
`dashed box below) in communication with the integration subsystem. The Bluetooth interface of the car audio/video
`system is operable to establish a wireless link with Bluetooth interfaces (second wireless interfaces) of and/or in
`communication with one or more portable devices external to the car audio/video system.
`
`
`Claim
`interface in
`communication
`with said
`integration
`subsystem, said
`first wireless
`interface
`establishing a
`wireless
`communication
`link with a
`second wireless
`interface in
`communication
`with a portable
`device external
`to the car
`audio/video
`system,
`
`
`
`7
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 7
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`8
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 8
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. C (Apple iPhone webpage).3
`
`See, e.g., http://developer.android.com/guide/topics/connectivity/bluetooth.html (discussing Bluetooth support for the
`
`3 Blitzsafe has produced Ex. C, iOS: Supported Bluetooth profiles, simultaneously with these Infringement Contentions as a document bearing production
`numbers BS-HK-0000001 – 3. All pin-cites are to manual pages.
`
`
`
`
`
`9
`
`Petitioners
`Exhibit 1005, App. D, Page 9
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Android platform)
`
`See also Ex. D (Kia Bluetooth Compatibility List).4
`
`Support
`
`
`
`
`
`
`
`
`4 Blitzsafe has produced Ex. D, Kia Bluetooth Compatibility List, simultaneously with these Infringement Contentions as a document bearing production
`numbers BS-HK-0000876 – 879. All pin-cites are to manual pages.
`
`
`
`10
`
`Petitioners
`Exhibit 1005, App. D, Page 10
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`11
`
`Petitioners
`Exhibit 1005, App. D, Page 11
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`12
`
`Petitioners
`Exhibit 1005, App. D, Page 12
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`13
`
`Petitioners
`Exhibit 1005, App. D, Page 13
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2014 Kia Soul User’s Manual) at 4:180-84.
`
`
`
`
`
`
`14
`
`Petitioners
`Exhibit 1005, App. D, Page 14
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`15
`
`Petitioners
`Exhibit 1005, App. D, Page 15
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`16
`
`Petitioners
`Exhibit 1005, App. D, Page 16
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`[49C] wherein
`
`
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 3:4-6.
`
`See, e.g., video (Stream Music from Your Smart Phone - 2014 Kia Uvo eServices Infotainment System with Navigation:
`https://www.youtube.com/watch?v=4LvVqYtcTho).
`
`After establishing a wireless link with the portable device, information about an audio file stored on the portable device
`
`17
`
`Petitioners
`Exhibit 1005, App. D, Page 17
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Support
`(such as the audio itself, as well as song title information) is communicated wirelessly from the portable device to the
`integration subsystem of the car audio/video system via the first and second wireless interfaces (i.e., a Bluetooth interface
`of the car audio/video system and another in communication with and part of the portable device). The integration
`subsystem then transmits this information to the car audio/video system for subsequent display of the information on a
`display of the car audio/video system.
`
`
`Claim
`said integration
`subsystem
`obtains, using
`said wireless
`communication
`link, information
`about an audio
`file stored on
`the portable
`device,
`transmits the
`information to
`the car
`audio/video
`system for
`subsequent
`display of the
`information on a
`display of the
`car audio/video
`system,
`
`
`
`18
`
`Petitioners
`Exhibit 1005, App. D, Page 18
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`19
`
`Petitioners
`Exhibit 1005, App. D, Page 19
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`20
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 20
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`21
`
`Petitioners
`Exhibit 1005, App. D, Page 21
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`22
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 22
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 4:178.
`
`
`
`
`
`
`23
`
`Petitioners
`Exhibit 1005, App. D, Page 23
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`24
`
`Petitioners
`Exhibit 1005, App. D, Page 24
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:27-28.
`
`See, e.g., video (Stream Music from Your Smart Phone - 2014 Kia Uvo eServices Infotainment System with Navigation:
`https://www.youtube.com/watch?v=4LvVqYtcTho).
`
`With respect to each device integration system of the accused Kia automobiles, a user can input commands via buttons and
`controls of the car audio/video system to (i) select a track; (ii) fast forward and reverse a track; and (iii) play and pause a
`track. When a user selects an audio file to play using buttons and/or controls of the car audio/video system, the integration
`subsystem instructs the portable device to play the audio file, which is received by the integration subsystem via the first
`and second wireless interfaces (i.e., a Bluetooth interface of the car audio/video system and another in communication with
`
`
`
`25
`
`[49D] said
`integration
`subsystem …
`instructs the
`portable device
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 25
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Support
`and part of the portable device). The audio file is then played via the car’s speakers.
`
`Claim
`to play the
`audio file in
`response to a
`user selecting
`the audio file
`using controls of
`the car
`audio/video
`system, and
`receives audio
`generated by
`the portable
`device over said
`wireless
`communication
`link for playing
`on the car
`audio/video
`system.
`
`
`
`
`
`
`
`26
`
`Petitioners
`Exhibit 1005, App. D, Page 26
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 4:159, 178.
`
`
`
`
`
`
`27
`
`Petitioners
`Exhibit 1005, App. D, Page 27
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`28
`
`Petitioners
`Exhibit 1005, App. D, Page 28
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`29
`
`Petitioners
`Exhibit 1005, App. D, Page 29
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`30
`
`Petitioners
`Exhibit 1005, App. D, Page 30
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 1:2-3, 2:27-28.
`
`See, e.g., video (Stream Music from Your Smart Phone - 2014 Kia Uvo eServices Infotainment System with Navigation:
`https://www.youtube.com/watch?v=4LvVqYtcTho).
`
`
`Each car audio/video system of the accused Kia automobiles includes the integration subsystem for connecting to external
`
`
`
`31
`
`
`50. The system
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 31
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Support
`portable devices (such as iPhones, Zune devices and other smart devices) via a wireless Bluetooth interface. Once
`connected, the portable device may be controlled directly from the car audio/video system. Commands, which are received
`from buttons and other controls of the car audio/video system, may be communicated wirelessly via the Bluetooth
`interface to the portable device. The portable device then responds to the received commands by channeling audio and
`other information (such as track name and artist information) to the car audio/video system by way of the first and second
`wireless interfaces and the integration subsystem.
`
`Claim
`of claim 49,
`wherein said
`integration
`subsystem is
`positioned
`within the car
`audio/video
`system.
`
`
`
`32
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 32
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`33
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 33
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2014 Kia Soul User’s Manual) at 4:178.
`
`
`
`
`
`
`34
`
`Petitioners
`Exhibit 1005, App. D, Page 34
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`35
`
`Petitioners
`Exhibit 1005, App. D, Page 35
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:27-28.
`
`
`The first wireless interface (i.e., the Bluetooth interface) is part of the car audio/video system.
`
`
`
`
`36
`
`
`51. The system
`of claim 50,
`wherein said
`first wireless
`interface is
`positioned
`within the car
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 36
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`audio/video
`system.
`
`Support
`
`
`
`
`
`37
`
`Petitioners
`Exhibit 1005, App. D, Page 37
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`38
`
`Petitioners
`Exhibit 1005, App. D, Page 38
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2014 Kia Soul User’s Manual) at 4:178.
`
`
`
`
`
`
`39
`
`Petitioners
`Exhibit 1005, App. D, Page 39
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`40
`
`Petitioners
`Exhibit 1005, App. D, Page 40
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:27-28.
`
`
`Portable devices, such as iPhones, Zune devices, Android devices and other smart, portable devices, include Bluetooth
`interfaces.
`
`
`
`
`41
`
`
`52. The system
`of claim 51,
`wherein said
`second wireless
`interface is
`positioned
`within the
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 41
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`portable device.
`
`Support
`
`See, e.g., Ex. C (Apple iPhone webpage).
`
`
`
`
`42
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 42
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`
`53. The system
`of claim 49,
`wherein said
`integration
`subsystem
`receives a
`control
`command
`issued at the car
`audio/video
`system in a
`format
`incompatible
`with the
`portable device,
`processes the
`control
`command into a
`formatted
`command
`compatible with
`the portable
`device, and
`dispatches the
`processed
`control
`command to the
`
`
`
`Support
`See, e.g., http://developer.android.com/guide/topics/connectivity/bluetooth.html (discussing Bluetooth support for the
`Android platform).
`
`See, e.g., Ex. D (Kia Bluetooth Compatibility List).
`
`
`The integration subsystem of each accused Kia automobile “receives a control command issued at the car audio/video
`system in a format incompatible with the portable device, processes the control command into a formatted command
`compatible with the portable device, and dispatches the processed control command to the portable device for execution
`thereby.” More specifically, once a portable device is connected, commands are received by the integration subsystem
`from the car audio/video system, where they are processed and converted from a format understandable and compatible
`with the car audio/video system and associated Kia protocols (i.e., a format incompatible with the portable device) into
`formatted commands that are compatible with the portable device (i.e., converted into Bluetooth, application and/or
`device-specific protocols understandable to the portable device). These formatted commands are then dispatched to the
`portable device via the first and second wireless interfaces (i.e., the Bluetooth interface of the car audio/video system car
`audio/video system and one or more Bluetooth interfaces in communication with and part of the portable device), where
`they are executed by the portable device. At least the Freescale microcontroller of the integration subsystem (and
`potentially other microcontrollers on one or more circuit boards of the device integration system) executes pre-
`programmed code to perform at least a portion of these functions. It is believed that this code is stored in onboard flash
`and/or other memory modules, and/or is contained within firmware elsewhere in the integration subsystem (such as within
`the Freescale microcontroller itself).
`
`43
`
`Petitioners
`Exhibit 1005, App. D, Page 43
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`portable device
`for execution
`thereby.
`
`Support
`
`
`
`44
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 44
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`45
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 45
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`46
`
`Petitioners
`Exhibit 1005, App. D, Page 46
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 4:159, 178.
`
`
`
`
`
`
`47
`
`Petitioners
`Exhibit 1005, App. D, Page 47
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`48
`
`Petitioners
`Exhibit 1005, App. D, Page 48
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
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`
`49
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`Petitioners
`Exhibit 1005, App. D, Page 49
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
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`
`50
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`Petitioners
`Exhibit 1005, App. D, Page 50
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 1:2-3, 2:27-28.
`
`See, e.g., video (Stream Music from Your Smart Phone - 2014 Kia Uvo eServices Infotainment System with Navigation:
`https://www.youtube.com/watch?v=4LvVqYtcTho).
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`
`
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`51
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`Petitioners
`Exhibit 1005, App. D, Page 51
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
`54. The system
`of claim 49,
`wherein said
`integration
`subsystem
`receives data
`generated by
`the portable
`device in a
`format
`incompatible
`with the car
`audio/video
`system,
`processes the
`data into
`formatted data
`compatible with
`the car
`audio/video
`system, and
`transmits the
`processed data
`to the car
`audio/video
`system for
`subsequent
`display of the
`processed data
`on a display of
`the car
`audio/video
`system.
`
`
`
`Support
`The integration subsystem of each accused Kia automobile “receives data generated by the portable device in a format
`incompatible with the car audio/video system, processes the data into formatted data compatible with the car audio/video
`system, and transmits the processed data to the car audio/video system for subsequent display of the processed data on a
`display of the car audio/video system.” More specifically, the portable device transmits data (such as audio, song and artist
`information) to the integration subsystem via the first and second wireless interfaces (i.e., the Bluetooth interface of the car
`audio/video system and one or more Bluetooth interfaces in communication with and part of the portable device). The
`integration subsystem then processes and converts the data from a format incompatible with the car audio/video system
`and understandable and compatible with the portable device (i.e., Bluetooth, application and/or device-specific protocols
`understandable to the portable device) into formatted data compatible with the car audio/video system (i.e., formatted
`data understandable and compatible with the car audio/video system and associated Kia protocols). The formatted data is
`then transmitted by the integration subsystem to the car audio/video system for subsequent display of the processed data
`on a display of the car audio/video system. At least the Freescale microcontroller of the integration subsystem (and
`potentially other microcontrollers on one or more circuit boards of the device integration system) executes pre-
`programmed code to perform at least a portion of these functions. It is believed that this code is stored in onboard flash
`and/or other memory modules, and/or is contained within firmware elsewhere in the integration subsystem (such as within
`the Freescale microcontroller itself).
`
`
`52
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`Petitioners
`Exhibit 1005, App. D, Page 52
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
`
`
`
`53
`
`
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`Petitioners
`Exhibit 1005, App. D, Page 53
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
`
`
`
`
`
`54
`
`
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 54
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`
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
`
`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 4:178.
`
`
`
`
`
`
`55
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`Petitioners
`Exhibit 1005, App. D, Page 55
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
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`
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`
`
`
`56
`
`Petitioners
`Exhibit 1005, App. D, Page 56
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`
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:27-28.
`
`See, e.g., video (Stream Music from Your Smart Phone - 2014 Kia Uvo eServices Infotainment System with Navigation:
`https://www.youtube.com/watch?v=4LvVqYtcTho).
`
`
`The accused Kia automobiles permit various control and audio commands to be submitted via voice recognition, which is
`processed by a voice recognition subsystem of the car audio/video system. Voice recognition of spoken control commands
`issued by a user may be used by the car audio/video system to instruct the portable device to play audio files.
`
`
`
`
`57
`
`
`55. The system
`of claim 49,
`wherein said
`integration
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 57
`
`
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
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`Support
`
`
`
`Claim
`subsystem
`further
`comprises a
`voice
`recognition
`subsystem for
`receiving and
`processing
`spoken control
`commands
`issued by a user.
`
`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 4:197.
`
`
`
`
`
`
`58
`
`Petitioners
`Exhibit 1005, App. D, Page 58
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`
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 4:11.
`
`
`Each of the accused Kia automobiles includes a device presence signal that “maintain[s] the car audio/video system in a
`state responsive to the portable device.” Specifically, when a portable device is paired via Bluetooth, a Bluetooth graphic
`appears indicating that a compatible device is connected and recognized. Once a compatible portable device is connected
`and recognized, the integration subsystem maintains the car audio/video system in a state responsive to processed data
`
`
`
`59
`
`
`56. The system
`of claim 49,
`wherein said
`integration
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 59
`
`
`
`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Support
`
`and audio signals from the portable device.
`
`The device presence signal is generated when at least the Freescale microcontroller of the integration subsystem (and
`potentially other microcontrollers on one or more circuit boards of the device integration system) executes pre-
`programmed code stored in onboard flash and/or other memory modules, and/or within firmware elsewhere in the
`interface (such as within the Freescale microcontroller itself) in response to its receipt from the first wireless interface of a
`signal indicating that a portable device has established a connection via Bluetooth.
`
`The device presence signal can be identified by examining the source code in the integration subsystem of the accused Kia
`automobiles.
`
`
`Claim
`subsystem
`generates a
`device presence
`signal and
`transmits the
`device presence
`signal to the car
`audio/video
`system to
`maintain the car
`audio/video
`system in a state
`responsive to
`the portable
`device.
`
`
`
`60
`
`Petitioners
`Exhibit 1005, App. D, Page 60
`
`
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 4:178.
`
`
`
`
`
`
`61
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`Petitioners
`Exhibit 1005, App. D, Page 61
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`
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:27.
`
`See, e.g., video (Stream Music from Your Smart Phone - 2014 Kia Uvo eServices Infotainment System with Navigation:
`https://www.youtube.com/watch?v=4LvVqYtcTho).
`
`
`See claim 55 support.
`
`
`
`62
`
`
`57. The system
`of claim 49,
`wherein said
`
`
`
`Petitioners
`Exhibit 1005, App. D, Page 62
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`
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`integration
`subsystem
`instructs said
`portable device
`to play a desired
`file in response
`to a spoken
`command
`processed by
`the voice
`recognition
`subsystem.
`
`62. The system
`of claim 49,
`wherein the
`portable device
`comprises a
`portable digital
`media player.
`
`63. The system
`of claim 62,
`wherein the
`portable digital
`media player
`comprises a
`video device, a
`portable media
`center, a
`portable media
`player, an MP3
`player, an MP4
`
`
`
`Support
`
`
`Portable devices capable of being connected to car audio/video systems of the accused Kia automobiles include Bluetooth
`compatible smart phones and other smart devices, such as iPhones, iPads, iPods, and Android devices. When storing,
`streaming and playing media (such as audio and/or video), these smart devices constitute digital media players. These
`players are capable of at least playing MP3 song files and streaming audio, such as via applications and online websites (e.g.,
`Pandora, iTunes streaming, and Apple Music).
`
`See, e.g., Ex. C (Kia Bluetooth Phone Compatibility List).
`
`See claim 62 support.
`
`
`63
`
`Petitioners
`Exhibit 1005, App. D, Page 63
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`
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`player, a WMV
`player, an Apple
`iPod, or an
`Apple video
`iPod.
`
`64. The system
`of claim 49,
`wherein the
`portable device
`comprises a
`cellular
`telephone.
`
`71. The system
`of claim 49,
`wherein the
`audio file
`comprises a
`song stored on
`the portable
`device.
`
`[73P]. A
`multimedia
`device
`integration
`system,
`comprising:
`[73A]. an
`integration
`subsystem in
`communication
`
`
`
`
`See claim 62 support.
`
`
`See claim 49 support.
`
`
`See preamble [49P] support.
`
`See element [49A] support.
`
`Support
`
`64
`
`Petitioners
`Exhibit 1005, App. D, Page 64
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`
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`with a car
`audio/video
`system; and
`[73B] a first
`wireless
`interface in
`communication
`with said
`integration
`subsystem, said
`first wireless
`interface
`establishing a
`wireless
`communication
`link with a
`second wireless
`interface in
`communication
`with a portable
`device external
`to the car
`audio/video
`system,
`[73C] wherein
`said integration
`subsystem
`obtains, using
`said wireless
`communication
`link, information
`about an audio
`file received by
`
`
`
`Support
`
`See element [49B] support.
`
`See element [49C] support.
`
`The audio file may be “received” by the portable device from online streaming services, such as Pandora, Spotify, iTunes, or
`Apple Music. Audio files (such as MP3 files) stored on the portable device may also be “received” from other sources, such
`as download websites or the user himself/herself via download.
`
`65
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`Petitioners
`Exhibit 1005, App. D, Page 65
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`
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`Appendix D - Claim Chart for US Patent No. 8,155,342 Against Infotainment Systems of Accused Kia Automobiles
`
`See element [49D] support
`
`Claim
`the portable
`device,
`transmits the
`information to
`the car
`audio/video
`system for
`subsequent
`display of the
`information on a
`display of the
`car audio/video
`system,
`[73D] instructs
`the portable
`device to play
`the audio file in
`response to a
`user selecting
`the audio file
`using controls of
`the car
`audio/video
`system, and
`receives audio
`generated by
`the portable
`device over said
`wireless
`communication
`link for playing
`on the car
`audio/video
`
`
`
`Support
`
`66
`
`Petitioners
`Exhibit 1005,