`
`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 Kia 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 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 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
`1[P]. An audio
`device
`integration
`system
`comprising:
`
`[1A] a first
`connector
`electrically
`connectable to
`a car stereo;
`
`Support
`Each accused Kia 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, iPhones
`and Zune devices playing MP3 files, as well as Android devices). Accused Kia automobiles employing UVO technology 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 Kia 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 iPod, iPhone, or Zune 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. B, Page 1
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`[1B] a second
`connector
`electrically
`connectable to
`an after-
`market audio
`device external
`to the car
`
`
`
`Each device integration system of accused Kia 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 a
`USB connector in the device integration system that is connectable to a USB port in the accused Kia automobiles for mating
`via a cable (including, in some cases, a combination USB/AUX cable) with an after-market audio device external to the car
`stereo, such as an iPhone or other smart device playing MP3 files or streaming radio and other audio content from the
`Internet or from applications such as Pandora.
`
`2
`
`Petitioners
`Exhibit 1005, App. B, Page 2
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`stereo;
`
`
`
`Support
`
`
`
`
`
`3
`
`Petitioners
`Exhibit 1005, App. B, Page 3
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 4:145.1
`
`
`
`
`
`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. B, Page 4
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:19.2
`Each device integration system of accused Kia automobiles includes “a third connector electrically connectable to one or
`[1C] a third
`more auxiliary input sources external to the car stereo and the after-market audio device.” Specifically, accused Kia
`connector
`
`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.
`
`
`
`5
`
`Petitioners
`Exhibit 1005, App. B, Page 5
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`electrically
`connectable to
`one or more
`auxiliary input
`sources
`external to the
`car stereo and
`the after-
`market audio
`device;
`
`
`
`Support
`automobiles are provided with an AUX terminal at one or more locations in the automobile, such as in the center console.
`The AUX terminal 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 AUX terminal
`to be played through the automobile’s speakers, which are driven by the device integration system.
`
`
`
`
`
`
`6
`
`Petitioners
`Exhibit 1005, App. B, Page 6
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`7
`
`Petitioners
`Exhibit 1005, App. B, Page 7
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`8
`
`Petitioners
`Exhibit 1005, App. B, Page 8
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`9
`
`Petitioners
`Exhibit 1005, App. B, Page 9
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 4:145, 176.
`
`
`
`
`10
`
`Petitioners
`Exhibit 1005, App. B, Page 10
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`11
`
`Petitioners
`Exhibit 1005, App. B, Page 11
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:19, 26.
`Each device integration system of an accused Kia automobile includes, among other things, an interface for connecting the
`car stereo to external audio devices via a USB connector (which interface comprises at least the software and hardware
`shown in the yellow dashed boxes below, including at least a Freescale microcontroller) is coupled to the USB and/or AUX
`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 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 Kia automobiles is to permit audio stored on or streamed from an after-market audio device to play via the
`car’s stereo speakers.
`
`
`
`12
`
`
`
`[1D] an
`interface
`connected
`between said
`first and
`second
`electrical
`connectors for
`channeling
`audio signals to
`
`
`
`Petitioners
`Exhibit 1005, App. B, Page 12
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Support
`
`
`
`Claim
`the car stereo
`from the after-
`market audio
`device,
`
`
`
`
`
`13
`
`
`
`Petitioners
`Exhibit 1005, App. B, Page 13
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`14
`
`
`
`Petitioners
`Exhibit 1005, App. B, Page 14
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`15
`
`Petitioners
`Exhibit 1005, App. B, Page 15
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`16
`
`Petitioners
`Exhibit 1005, App. B, Page 16
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`17
`
`Petitioners
`Exhibit 1005, App. B, Page 17
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`18
`
`Petitioners
`Exhibit 1005, App. B, Page 18
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`19
`
`Petitioners
`Exhibit 1005, App. B, Page 19
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 4:154, 159, 160, 171-72, 174.
`
`
`
`
`
`
`20
`
`Petitioners
`Exhibit 1005, App. B, Page 20
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`21
`
`Petitioners
`Exhibit 1005, App. B, Page 21
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`22
`
`Petitioners
`Exhibit 1005, App. B, Page 22
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`23
`
`Petitioners
`Exhibit 1005, App. B, Page 23
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:19-22
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:23-25, 35-37.
`
`The interface of each device integration system of the accused Kia automobiles includes one or more microcontrollers
`(including at least a Freescale 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 Freescale microcontroller of the interface (and potentially other microcontrollers on one or more circuit boards of the
`
`
`
`24
`
`[1E] said
`interface
`including a
`microcontroller
`
`
`
`Petitioners
`Exhibit 1005, App. B, Page 24
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Support
`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, and/or is contained within firmware elsewhere in the interface (such as
`within the Freescale microcontroller itself).
`
`
`Claim
`in electrical
`communication
`with said first
`and second
`electrical
`connectors,
`said
`microcontroller
`pre-
`programmed
`to execute:
`
`
`
`25
`
`
`
`Petitioners
`Exhibit 1005, App. B, Page 25
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`[1F] a first pre-
`programmed
`code portion
`for remotely
`
`
`
`The interface of each device integration system of the accused Kia automobiles is pre-programed to execute “a first 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
`
`26
`
`Petitioners
`Exhibit 1005, App. B, Page 26
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`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
`
`
`
`Support
`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 Freescale microcontroller), where they are processed and
`converted using pre-programmed software from a format understandable and compatible with the car stereo and
`associated Kia 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 Freescale 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, and/or is contained within firmware
`elsewhere in the interface (such as within the Freescale microcontroller itself).
`
`
`27
`
`Petitioners
`Exhibit 1005, App. B, Page 27
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Support
`
`
`
`
`
`28
`
`Claim
`connector for
`execution by
`the after-
`market audio
`device;
`
`
`
`Petitioners
`Exhibit 1005, App. B, Page 28
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`29
`
`
`
`Petitioners
`Exhibit 1005, App. B, Page 29
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`30
`
`Petitioners
`Exhibit 1005, App. B, Page 30
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`31
`
`Petitioners
`Exhibit 1005, App. B, Page 31
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 171-72, 174.
`
`
`
`
`
`
`32
`
`Petitioners
`Exhibit 1005, App. B, Page 32
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`33
`
`Petitioners
`Exhibit 1005, App. B, Page 33
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`34
`
`Petitioners
`Exhibit 1005, App. B, Page 34
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`35
`
`Petitioners
`Exhibit 1005, App. B, Page 35
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`36
`
`Petitioners
`Exhibit 1005, App. B, Page 36
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`37
`
`Petitioners
`Exhibit 1005, App. B, Page 37
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`38
`
`Petitioners
`Exhibit 1005, App. B, Page 38
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`39
`
`Petitioners
`Exhibit 1005, App. B, Page 39
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`40
`
`Petitioners
`Exhibit 1005, App. B, Page 40
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`41
`
`Petitioners
`Exhibit 1005, App. B, Page 41
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`42
`
`Petitioners
`Exhibit 1005, App. B, Page 42
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`43
`
`Petitioners
`Exhibit 1005, App. B, Page 43
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`44
`
`Petitioners
`Exhibit 1005, App. B, Page 44
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 1:2-5, 20-25, 35-37.
`The interface of each device integration system of the accused Kia 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
`
`
`
`45
`
`[1G] a second
`pre-
`programmed
`code portion
`for receiving
`
`
`
`Petitioners
`Exhibit 1005, App. B, Page 45
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Support
`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, 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 Kia protocols). The
`formatted data is then transmitted by the interface (including at least the Freescale microcontroller) to the car stereo via
`the first connector for display by the car stereo. At least the Freescale 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, and/or is contained within firmware elsewhere in the interface (such as within the Renesas microcontroller itself).
`
`
`Claim
`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
`
`
`
`46
`
`Petitioners
`Exhibit 1005, App. B, Page 46
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`47
`
`
`
`Petitioners
`Exhibit 1005, App. B, Page 47
`
`
`
`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
`
`Claim
`
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`48
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`Exhibit 1005, App. B, Page 48
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Exhibit 1005, App. B, Page 49
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Support
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`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 171, 174.
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`Exhibit 1005, App. B, Page 50
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Exhibit 1005, App. B, Page 51
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`Exhibit 1005, App. B, Page 52
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
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`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:20-22.
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`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:23-25 (similar displayed information for Zune), 2:35-37 (similar displayed
`information for Pandora app).
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`The interface of each device integration system of the accused Kia 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 Freescale microcontroller of the interface (and potentially other microcontrollers on one or more circuit boards
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`53
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`[1H] a third
`pre-
`programmed
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`Exhibit 1005, App. B, Page 53
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Support
`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, and/or is contained within firmware
`elsewhere in the interface (such as within the Freescale microcontroller itself).
`
`
`
`Claim
`code portion
`for switching to
`one or more
`auxiliary input
`sources
`connected to
`said third
`electrical
`connector.
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`54
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`Exhibit 1005, App. B, Page 54
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Exhibit 1005, App. B, Page 55
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Exhibit 1005, App. B, Page 56
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
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`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 4:145, 176.
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`Exhibit 1005, App. B, Page 57
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Exhibit 1005, App. B, Page 58
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
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`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:19, 26.
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`The device integration systems of accused Kia automobiles are manufactured for Kia by at least Hyundai Mobis Co., Ltd..
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`59
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`2. The
`apparatus of
`claim 1,
`wherein the
`car stereo
`further
`comprises an
`Original
`Equipment
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`Exhibit 1005, App. B, Page 59
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`E
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`Each device integration system of the accused Kia automobiles allows for the connection of at least MP3 players (iPods),
`iPhones, Zune devices and other smart devices.
`
`Claim
`Manufacturer
`(OEM) car
`stereo
`connected to
`said first
`electrical
`connector.
`
`
`4. The
`apparatus of
`
`
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`Petitioners
`Exhibit 1005, App. B, Page 60
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Support
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`
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`Claim
`claim 1,
`wherein the
`after-market
`audio device
`further
`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 (2014 Kia Soul User’s Manual) at 4:154.
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`Exhibit 1005, App. B, Page 61
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
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`Exhibit 1005, App. B, Page 62
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
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`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 4, 2:19.
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`Each device integration system of the accused Kia 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 Kia 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 Kia automobiles, which includes the
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`63
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`5. The
`apparatus of
`claim 1,
`wherein said
`interface
`further
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`Petitioners
`Exhibit 1005, App. B, Page 63
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
`comprises a
`plug-and-play
`mode for
`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.
`
`
`
`Support
`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/.
`
`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.
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`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 Kia automobiles.
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`64
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`Exhibit 1005, App. B, Page 64
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
`
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`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:19-20
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`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:23 (similar disclosure for “Zune Mode”).
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`Petitioners
`Exhibit 1005, App. B, Page 65
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
`6. The
`apparatus of
`claim 1,
`wherein said
`interface
`generates a
`device
`presence signal
`for maintaining
`the car stereo
`in a state
`responsive to
`processed data
`and audio
`signals.
`
`Support
`The interface of the device integration system of each accused Kia automobile 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 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 interface of 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 Freescale 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, and/or within firmware elsewhere in the interface (such as within the
`Freescale 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 Kia automobiles.
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`
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`66
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`Petitioners
`Exhibit 1005, App. B, Page 66
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
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`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 4:174.
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`67
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`Petitioners
`Exhibit 1005, App. B, Page 67
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
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`68
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`Petitioners
`Exhibit 1005, App. B, Page 68
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
`
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`See, e.g., Ex. B (2015 Kia Soul UVO Manual) at 2:20, 23.
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`
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`69
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`Petitioners
`Exhibit 1005, App. B, Page 69
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Support
`Each device integration system of the accused Kia automobiles displays the track and time information of songs being
`played from a connected after-market audio device.
`
`
`Claim
`7. The
`apparatus of
`claim 1,
`wherein said
`second pre-
`programmed
`code portion
`processes data
`generated by
`the after-
`market audio
`device
`including track
`and time
`information.
`
`See, e.g., Ex. A (2014 Kia Soul Owner’s Manual) at 4:171.
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`
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`70
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`Petitioners
`Exhibit 1005, App. B, Page 70
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`Appendix B - Claim Chart for US Patent No. 7,489,786 Against Infotainment Systems of Accused Kia Automobiles
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`Claim
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`Support
`
`See, e.g., Ex. B (2015 Kia Soul UVO