`
`In these Infringement Contentions, Blitzsafe contends that at least the following claims of U.S. Patent No. 7,489,786 (“’786 patent”)
`identified below are infringed by the infotainment systems in accused Hyundai automobiles. Blitzsafe does not concede that any claims of the
`’786 patent that are not listed below are not infringed by the infotainment systems in accused Hyundai 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 Hyundai’s
`infotainment systems, internal documentation 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 Hyundai, 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
`1[P]. An audio
`device
`integration
`system
`comprising:
`[1A] a first
`connector
`electrically
`connectable to
`a car stereo;
`
`Support
`Each accused Hyundai automobile includes a device integration system, which supports docking integration of audio/video
`devices, such as freely lying or docked smartphones and other smart devices, as well as MP3 players (e.g., iPods and iPhones
`playing MP3 files, as well as Android devices). Accused Hyundai automobiles also support audio streaming from iPhones
`and other smart devices using downloadable apps, such as Google Play Music, Spotify and Pandora apps.
`
`Each device integration system of accused Hyundai automobiles includes the car stereo, including one or more car stereo
`components, such as, for example, DSPs, coils, tuner circuitry, car stereo software, virtual buttons, display unit, etc. The
`device integration system also includes an interface for, among other things, channeling audio signals to the car stereo from
`an after-market audio device, such as an iPhone, iPad or Android Device, connected via a USB connector. The device
`integration system includes “a first connector electrically connectable to a car stereo” because, as set forth below, the car
`stereo controls may be used to control the after-market audio device, and because the car stereo receives information from
`the after-market audio device regardless of the particular configuration of the device integration system. The “first
`connector electrically connectable to a car stereo” may include an electrical connector such as a circuit board connector,
`soldered connector, wired connector or software/virtual connector that is connectable to the car stereo or any component
`thereof, including at least the connector set forth in the yellow dashed box below.
`
`
`
`
`1
`
`Petitioners
`Exhibit 1005, App. A, Page 1
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`2
`
`Petitioners
`Exhibit 1005, App. A, Page 2
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`3
`
`Petitioners
`Exhibit 1005, App. A, Page 3
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`4
`
`Petitioners
`Exhibit 1005, App. A, Page 4
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 Hyundai Elantra Owner’s Manual) at 4:99, 4:115-16.1
`
`See also Ex. B (2016 Hyundai Sonata Android Audio).2
`
`1 Blitzsafe has produced Ex. A, 2011 Hyundai Elantra Owner’s Manual, simultaneously with these Infringement Contentions as a document bearing production
`numbers BS-HK-0000004 – 385. All pin-cites are to manual pages.
`2 Blitzsafe has produced Ex. B, 2016 Hyundai Sonata Android Audio, simultaneously with these Infringement Contentions as a document bearing production
`numbers BS-HK-0000694 – 701. All pin-cites are to manual pages.
`
`
`
`
`
`5
`
`Petitioners
`Exhibit 1005, App. A, Page 5
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`[1B] a second
`connector
`electrically
`connectable to
`an after-
`market audio
`device external
`to the car
`stereo;
`
`Support
`
`
`Each device integration system of accused Hyundai automobiles includes “a second connector electrically connectable to an
`after-market audio device external to the car stereo” because, as set forth below, the after-market audio device receives
`commands for controlling its operation from the car stereo, and because the car stereo receives information from the after-
`market audio device regardless of the particular configuration of the device integration system. The second connector is for
`connecting to a USB cable (or, in some cases, a combination USB/AUX cable) for mating with an after-market audio device
`external to the car stereo, such as an iPad, iPhone or other smart device playing MP3 files or streaming radio and other
`audio content from the Internet or from applications, such as Google Play Music, Spotify and Pandora apps.
`
`
`
`
`6
`
`Petitioners
`Exhibit 1005, App. A, Page 6
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`7
`
`
`
`Petitioners
`Exhibit 1005, App. A, Page 7
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`8
`
`
`
`
`
`Petitioners
`Exhibit 1005, App. A, Page 8
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`9
`
`Petitioners
`Exhibit 1005, App. A, Page 9
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`10
`
`Petitioners
`Exhibit 1005, App. A, Page 10
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 Hyundai Elantra Owner’s Manual) at 4:97, 99, 115-16.
`
`
`
`
`
`
`11
`
`Petitioners
`Exhibit 1005, App. A, Page 11
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`12
`
`Petitioners
`Exhibit 1005, App. A, Page 12
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`13
`
`Petitioners
`Exhibit 1005, App. A, Page 13
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`14
`
`Petitioners
`Exhibit 1005, App. A, Page 14
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`15
`
`Petitioners
`Exhibit 1005, App. A, Page 15
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`16
`
`Petitioners
`Exhibit 1005, App. A, Page 16
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`17
`
`Petitioners
`Exhibit 1005, App. A, Page 17
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. C (2016 Hyundai Sonata Multimedia System Manual) at 2:30-373
`
`See also Ex. B (2016 Hyundai Sonata Android Audio);
`
`See, e.g., 2012 Hyundai Veloster – Pandora: https://www.youtube.com/watch?v=eqvvfxgj2KQ; Hyundai i30 iPod demo:
`https://www.youtube.com/watch?v=Hty_7vvJtyw.
`
`3 Blitzsafe has produced Ex. C, 2016 Hyundai Sonata Multimedia System Manual, simultaneously with these Infringement Contentions as a document bearing
`production numbers BS-HK-0000386 – 693. All pin-cites are to manual pages.
`
`
`
`
`
`18
`
`Petitioners
`Exhibit 1005, App. A, Page 18
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Support
`
`
`Each device integration system of accused Hyundai automobiles includes “a third connector electrically connectable to one
`or more auxiliary input sources external to the car stereo and the after-market audio device.” Specifically, accused Hyundai
`automobiles are provided with an “AUX terminal” at one or more locations in the automobile, such as in the center console.
`The auxiliary input jack is connected via the third connector, which is believed to be included in one of the connectors
`within the yellow dashed box below, to the device integration system and permits audio from a device connected to the
`auxiliary input jack to be played through the automobile’s speakers.
`
`
`Claim
`
`[1C] a third
`connector
`electrically
`connectable to
`one or more
`auxiliary input
`sources
`external to the
`car stereo and
`the after-
`market audio
`device;
`
`
`
`19
`
`Petitioners
`Exhibit 1005, App. A, Page 19
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`20
`
`Petitioners
`Exhibit 1005, App. A, Page 20
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`21
`
`Petitioners
`Exhibit 1005, App. A, Page 21
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 Hyundai Elantra Owner’s Manual) at 4:97
`
`
`
`
`
`
`22
`
`Petitioners
`Exhibit 1005, App. A, Page 22
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. C (2016 Hyundai Sonata Multimedia System Manual) at 2:37.
`
`Each device integration system of the accused Hyundai automobiles includes, among other things, an interface for
`connecting the car stereo to external audio devices via a USB connector. The interface contained within the device
`integration system (which interface comprises at least the software and hardware shown in the yellow dashed boxes below,
`including at least a Telechips microcontroller) is coupled to the USB connector (i.e., the second connector) as well as to at
`least one car stereo component via the first connector, such as via a circuit board connector, soldered connector, wired
`connector or software/virtual connector. The interface necessarily channels audio signals to the car stereo from the after-
`market audio device, as one of the primary functions of the infotainment system within accused Hyundai automobiles is to
`
`
`
`23
`
`[1D] an
`interface
`connected
`between said
`first and
`second
`electrical
`
`
`
`Petitioners
`Exhibit 1005, App. A, Page 23
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Support
`permit audio stored on or streamed from an after-market audio device to play via the car stereo’s speakers.
`
`
`Claim
`connectors for
`channeling
`audio signals to
`the car stereo
`from the after-
`market audio
`device,
`
`
`
`
`
`24
`
`
`
`
`
`Petitioners
`Exhibit 1005, App. A, Page 24
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Support
`The interface of each device integration system of the accused Hyundai automobiles includes one or more microcontrollers
`(including at least a Telechips microcontroller) in electrical communication with the first and second electrical connectors
`for controlling various operations of the infotainment system, such as the radio, display, and interface operations. At least
`the Telechips microcontroller of the interface (and potentially other microcontrollers on one or more circuit boards of the
`device integration system, some of which are shown in the yellow dashed box below) executes code to perform various
`interface functions and is, thus, “pre-programmed” to perform these functions. It is believed that this code is stored in
`onboard flash and/or other memory modules (such as the Micron flash memory module), and/or is contained within
`firmware elsewhere in the interface (such as within the Telechips microcontroller itself).
`
`Claim
`[1E] said
`interface
`including a
`microcontroller
`in electrical
`communication
`with said first
`and second
`electrical
`connectors,
`said
`microcontroller
`pre-
`programmed
`to execute:
`
`
`
`25
`
`Petitioners
`Exhibit 1005, App. A, Page 25
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`26
`
`Petitioners
`Exhibit 1005, App. A, Page 26
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`27
`
`
`
`
`
`Petitioners
`Exhibit 1005, App. A, Page 27
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`28
`
`Petitioners
`Exhibit 1005, App. A, Page 28
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`29
`
`Petitioners
`Exhibit 1005, App. A, Page 29
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 Hyundai Elantra Owner’s Manual) at 4:97, 99, 115-16.
`
`
`
`
`
`
`30
`
`Petitioners
`Exhibit 1005, App. A, Page 30
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`31
`
`Petitioners
`Exhibit 1005, App. A, Page 31
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`32
`
`Petitioners
`Exhibit 1005, App. A, Page 32
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`33
`
`Petitioners
`Exhibit 1005, App. A, Page 33
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`34
`
`Petitioners
`Exhibit 1005, App. A, Page 34
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`35
`
`Petitioners
`Exhibit 1005, App. A, Page 35
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`36
`
`Petitioners
`Exhibit 1005, App. A, Page 36
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. C (2016 Hyundai Sonata Multimedia System Manual) at 2:30-2:37
`
`See also Ex. B (2016 Hyundai Sonata Android Audio).
`
`See, e.g., 2012 Hyundai Veloster – Pandora: https://www.youtube.com/watch?v=eqvvfxgj2KQ; Hyundai i30 iPod demo:
`https://www.youtube.com/watch?v=Hty_7vvJtyw.
`
`The interface of each device integration system of the accused Hyundai automobiles is pre-programed to execute “a first
`
`
`
`37
`
`[1F] a first pre-
`
`
`
`Petitioners
`Exhibit 1005, App. A, Page 37
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`programmed
`code portion
`for remotely
`controlling the
`after-market
`audio device
`using the car
`stereo by
`receiving a
`control
`command from
`the car stereo
`through said
`first connector
`in a format
`incompatible
`with the after-
`market audio
`device,
`processing the
`received
`control
`command into
`a formatted
`command
`compatible
`with the after-
`market audio
`device, and
`transmitting
`the formatted
`command to
`the after-
`
`
`
`Support
`pre-programmed code portion for remotely controlling the after-market audio device using the car stereo by receiving a
`control command from the car stereo through said first connector in a format incompatible with the after-market audio
`device, processing the received control command into a formatted command compatible with the after-market audio
`device, and transmitting the formatted command to the after-market audio device through said second connector for
`execution by the after-market audio device.” More specifically, once connected, commands are received from the car
`stereo and channeled through the first connector to the interface (including at least the Telechips microcontroller), where
`they are processed and converted using pre-programmed software from a format understandable and compatible with the
`car stereo and associated Hyundai protocols (i.e., a format incompatible with the after-market audio device) into formatted
`commands that are compatible with the after-market audio device (i.e., converted into USB and device-specific protocols
`understandable to the after-market audio device). These formatted commands are then transmitted to the after-market
`audio device via the USB connector (i.e., the second connector). The formatted commands are then executed by the after-
`market audio device. At least the Telechips microcontroller of the interface (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 (such as the Micron
`flash memory module), and/or is contained within firmware elsewhere in the interface (such as within the Telechips
`microcontroller itself).
`
`38
`
`Petitioners
`Exhibit 1005, App. A, Page 38
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`market audio
`device through
`said second
`connector for
`execution by
`the after-
`market audio
`device;
`
`Support
`
`
`
`
`
`
`
`39
`
`Petitioners
`Exhibit 1005, App. A, Page 39
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`40
`
`Petitioners
`Exhibit 1005, App. A, Page 40
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`41
`
`Petitioners
`Exhibit 1005, App. A, Page 41
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 Hyundai Elantra Owner’s Manual) at 4:99, 116-117.
`
`
`
`
`
`42
`
`Petitioners
`Exhibit 1005, App. A, Page 42
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`43
`
`Petitioners
`Exhibit 1005, App. A, Page 43
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`44
`
`Petitioners
`Exhibit 1005, App. A, Page 44
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`See, e.g., Ex. C (2016 Hyundai Sonata Multimedia System Manual) at 2:34-36.
`
`See also Ex. B (2016 Hyundai Sonata Android Audio);
`
`
`
`
`45
`
`Petitioners
`Exhibit 1005, App. A, Page 45
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`[1G] a second
`pre-
`programmed
`code portion
`for receiving
`data from the
`after-market
`audio device
`through said
`second
`connector in a
`format
`incompatible
`with the car
`stereo,
`processing the
`received data
`into formatted
`data
`compatible
`with the car
`stereo, and
`transmitting
`the formatted
`data to the car
`stereo through
`said first
`connector for
`display by the
`car stereo; and
`
`
`
`Support
`See, e.g., 2012 Hyundai Veloster – Pandora: https://www.youtube.com/watch?v=eqvvfxgj2KQ; Hyundai i30 iPod demo:
`https://www.youtube.com/watch?v=Hty_7vvJtyw.
`
`The interface of each device integration system of the accused Hyundai automobiles is pre-programed to execute “a second
`pre-programmed code portion for receiving data from the after-market audio device through said second connector in a
`format incompatible with the car stereo, processing the received data into formatted data compatible with the car stereo,
`and transmitting the formatted data to the car stereo through said first connector for display by the car stereo.” More
`specifically, in response to one or more formatted commands executed by the after-market audio device, the after-market
`audio device transmits data (such as audio, video, songs, album, track, cover art, genre and artist information) to the device
`integration system via the USB connector (i.e., the second connector). The data is then received by the interface of the
`device integration system (including at least the Telechips microcontroller), where the data is processed and converted
`using pre-programmed software from a format incompatible with the car stereo and understandable and compatible with
`the after-market audio device (i.e., USB and device-specific protocols understandable to the after-market audio device) into
`formatted data compatible with the car stereo (i.e., formatted data understandable and compatible with the car stereo and
`associated Hyundai protocols). The formatted data is then transmitted by the interface (including at least the Telechips
`microcontroller) to the car stereo via the first connector for display by the car stereo. At least the Telechips microcontroller
`of the interface (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 (such as the Micron flash memory module), and/or is contained within
`firmware elsewhere in the interface (such as within the Telechips microcontroller itself).
`
`46
`
`Petitioners
`Exhibit 1005, App. A, Page 46
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`47
`
`Petitioners
`Exhibit 1005, App. A, Page 47
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 Hyundai Elantra Owner’s Manual) at 4:116.
`
`
`
`
`
`
`48
`
`Petitioners
`Exhibit 1005, App. A, Page 48
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`49
`
`Petitioners
`Exhibit 1005, App. A, Page 49
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. C (2016 Hyundai Sonata Multimedia System Manual) at 2:34, 36.
`
`See also Ex. B (2016 Hyundai Sonata Android Audio).
`
`See, e.g., 2012 Hyundai Veloster – Pandora: https://www.youtube.com/watch?v=eqvvfxgj2KQ; Hyundai i30 iPod demo:
`https://www.youtube.com/watch?v=Hty_7vvJtyw.
`
`
`
`
`
`
`50
`
`Petitioners
`Exhibit 1005, App. A, Page 50
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Support
`The interface of each device integration system of the accused Hyundai automobiles is pre-programed to execute “a third
`pre-programmed code portion for switching to one or more auxiliary input sources connected to said third electrical
`connector.” At least the Telechips microcontroller of the interface (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 this
`function. It is believed that this code is stored in onboard flash and/or other memory modules (such as the Micron flash
`memory module), and/or is contained within firmware elsewhere in the interface (such as within the Telechips
`microcontroller itself).
`
`
`
`Claim
`[1H] a third
`pre-
`programmed
`code portion
`for switching to
`one or more
`auxiliary input
`sources
`connected to
`said third
`electrical
`connector.
`
`
`
`51
`
`Petitioners
`Exhibit 1005, App. A, Page 51
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`52
`
`Petitioners
`Exhibit 1005, App. A, Page 52
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 Hyundai Elantra Owner’s Manual) at 4:97
`
`
`
`
`
`
`53
`
`Petitioners
`Exhibit 1005, App. A, Page 53
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. C (2016 Hyundai Sonata Multimedia System Manual) at 2:37.
`
`
`The device integration systems of accused Hyundai automobiles are manufactured for Hyundai by at least Hyundai Mobis
`Co., Ltd.
`
`
`
`
`54
`
`
`2. The
`apparatus of
`claim 1,
`wherein the
`car stereo
`further
`
`
`
`Petitioners
`Exhibit 1005, App. A, Page 54
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Support
`
`
`
`55
`
`
`
`Each device integration system of the accused Hyundai automobiles allows for the connection of at least MP3 players
`(iPods), iPhones, Android devices and other smart devices.
`
`
`Claim
`comprises an
`Original
`Equipment
`Manufacturer
`(OEM) car
`stereo
`connected to
`said first
`electrical
`connector.
`
`
`4. The
`apparatus of
`claim 1,
`wherein the
`after-market
`audio device
`further
`
`
`
`
`
`
`
`Petitioners
`Exhibit 1005, App. A, Page 55
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Support
`
`Claim
`comprises a CD
`player, CD
`changer, MP3
`player, Digital
`Audio
`Broadcast
`(DAB) receiver,
`or satellite
`receiver
`connected to
`said second
`electrical
`connector.
`
`See, e.g., Ex. A (2011 Hyundai Elantra Owner’s Manual) at 4:115.
`
`
`
`
`
`
`56
`
`Petitioners
`Exhibit 1005, App. A, Page 56
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`
`See Ex. C (2016 Hyundai Sonata Multimedia System Manual) at 2:32
`
`See also Ex. B (2016 Hyundai Sonata Android Audio).
`
`
`Each device integration system of the accused Hyundai automobiles includes a plug-and-play module that automatically
`detects whether an iPhone/iPod or Android-powered device is attached to the USB port. For example, through Apple’s MFi
`Program, third party-accessories, such as the device integration systems of the accused Hyundai automobiles, are licensed
`to connect electronically to Apple devices such as the iPhone and iPod. See, e.g.,
`https://mfi.apple.com/MFiWeb/getFAQ.action. Apple provides a framework for communications between Apple devices
`and third-party accessories, such as the device integration systems of the accused Hyundai automobiles, which includes the
`requirement that the third-party accessory includes a chip to decode communications between the accessory and a device
`that has identified itself as an iPod or iPhone. See, e.g., http://www.objectpartners.com/2010/09/14/communicating-with-
`external-devices-from-the-iphone-and-ipad/.
`
`57
`
`
`5. The
`apparatus of
`claim 1,
`wherein said
`interface
`further
`comprises a
`plug-and-play
`mode for
`
`
`
`Petitioners
`Exhibit 1005, App. A, Page 57
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Support
`
`
`Similarly, Android provides tools for connecting Android-powered devices to third-party accessories using a USB connection,
`including a means for providing a notification that an Android-powered device is connected to the accessory. See, e.g.,
`http://developer.android.com/guide/topics/connectivity/usb/accessory.html.
`
`The specific manner in which the interface implements the plug-and-play mode of this claim will be ascertainable by
`reviewing the source code of the interface in the accused Hyundai automobiles.
`
`
`Claim
`automatically
`detecting a
`device type of
`the after-
`market audio
`device
`connected to
`said second
`electrical
`connector and
`integrating the
`after-market
`audio device
`based upon the
`device type.
`
`
`
`58
`
`Petitioners
`Exhibit 1005, App. A, Page 58
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 Hyundai Elantra Owner’s Manual) at 4:116.
`
`
`
`
`
`59
`
`Petitioners
`Exhibit 1005, App. A, Page 59
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. C (2016 Hyundai Sonata Multimedia System Manual) at 2:30.
`
`
`Each device integration system of the accused Hyundai automobiles includes a device presence signal that “maintain[s] the
`car stereo in an operational state responsive to processed data and audio signals.” Specifically, when an after-market audio
`device is plugged into the USB port that is connected to the USB connector in the device integration system (i.e., the second
`
`
`
`60
`
`
`6. The
`apparatus of
`claim 1,
`
`
`
`Petitioners
`Exhibit 1005, App. A, Page 60
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`wherein said
`interface
`generates a
`device
`presence signal
`for maintaining
`the car stereo
`in a state
`responsive to
`processed data
`and audio
`signals.
`
`Support
`electrical connector), a USB graphic appears indicating that a compatible device is connected and recognized. Once a
`compatible after-market audio device is connected and recognized, the device integration system maintains the car stereo
`responsive to processed data and audio signals from the portable device.
`
`The device presence signal is generated when at least the TeleChips microcontroller of the interface (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 (such as the Micron flash memory module), and/or within firmware elsewhere
`in the interface (such as within the Telechips microcontroller itself).
`
`The specific manner in which the interface implements the device presence signal of this claim will be ascertainable by
`reviewing the source code of the interface in the accused Hyundai automobiles.
`
`
`
`61
`
`Petitioners
`Exhibit 1005, App. A, Page 61
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. A (2011 Hyundai Elantra Owner’s Manual) at 4:116.
`
`
`
`
`
`
`62
`
`Petitioners
`Exhibit 1005, App. A, Page 62
`
`
`
`Appendix A - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Hyundai Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. C (2016 Hyundai Sonata Multimedia System Manual) at 2:34.
`
`
`Each device integration system of the accused Hyundai automobiles displays the track and time information of songs being
`played from a connected after-market audio device.
`
`63
`
`
`7. The
`apparatus of
`
`
`
`Petitioners
`Exhibit 100