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Appendix B
`Claim Chart for US Patent No. 8,155,342 Against Accused Infotainment Systems of BMW Automobiles
`
`
`
`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 the identified BMW automobiles, including those sold under the BMW and Mini
`brands. Blitzsafe does not concede that any claims of the ’342 patent that are not listed below are not infringed by the identified products.
`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, source code, and/or testimony at a later time. These contentions are preliminary in
`nature, and an analysis of BMW's products, internal documentation, source code, and/or testimony from relevant witnesses may 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 BMW, 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:
`
`
`
`Support
`Each accused BMW infotainment system includes a multimedia device integration system that supports 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). BMW multimedia device integration systems also support device integration of
`smartphones and other smart devices (e.g., iPods and iPhones) for playing audio streamed over the Internet, such as via
`the Aha and iHeart applications and via online radio stations such as Pandora.
`
`
`
`
`Page 1 of 109
`
`Patent Owner Blitzsafe Texas, LLC – Exhibit 2003
`BMW of North America v. Blitzsafe, IPR2018-00926
`Page 1
`
`

`

`
`
`Claim
`
`Appendix B
`Claim Chart for US Patent No. 8,155,342 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
`
`
`
`
`Each BMW infotainment system allows a user to input commands via buttons and controls of the car audio/video system
`to: (i) select a track or album; (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. Audio generated by the portable device 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 and part of the portable device). The audio generated by the portable device is then played via the
`car’s speakers.
`
`
`
`
`Page 39 of 109
`
`[49D] said
`integration
`subsystem …
`instructs the
`portable device
`to play the
`audio file in
`response to a
`user selecting
`the audio file
`using controls of
`the car
`
`
`
`Ex. 2003 - Page 2
`
`

`

`Appendix B
`Claim Chart for US Patent No. 8,155,342 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
`
`
`
`
`
`Claim
`audio/video
`system, and
`receives audio
`generated by
`the portable
`device over said
`wireless
`communication
`link for playing
`on the car
`audio/video
`system.
`
`
`
`Page 40 of 109
`
`Ex. 2003 - Page 3
`
`

`

`
`
`Claim
`
`Appendix B
`Claim Chart for US Patent No. 8,155,342 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
`
`
`
`
`
`
`
`Page 41 of 109
`
`Ex. 2003 - Page 4
`
`

`

`
`
`Claim
`
`Appendix B
`Claim Chart for US Patent No. 8,155,342 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
`
`
`See, e.g., Ex. A (2011 BMW 3-series Owner's Manual), at p. 213, 215, 216.
`
`
`
`
`Page 42 of 109
`
`Ex. 2003 - Page 5
`
`

`

`
`
`Claim
`
`Appendix B
`Claim Chart for US Patent No. 8,155,342 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
`
`
`
`
`
`Page 43 of 109
`
`Ex. 2003 - Page 6
`
`

`

`
`
`Claim
`
`Appendix B
`Claim Chart for US Patent No. 8,155,342 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
`
`
`See, e.g., Ex. B (2015 BMW Navigation, Entertainment, Communication Owner's Handbook), at p. 56-58
`
`
`
`
`Page 44 of 109
`
`Ex. 2003 - Page 7
`
`

`

`
`
`Claim
`
`Appendix B
`Claim Chart for US Patent No. 8,155,342 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
`
`See, e.g., Ex. D (BMW ConnectedDrive A to Z), at p. 3
`
`
`
`
`
`
`
`
`
`
`
`Each BMW infotainment system includes the integration subsystem positioned within the vehicle for connecting to
`external portable devices (such as iPhones) via a wireless Bluetooth interface. Once connected, the portable device may
`
`Page 45 of 109
`
`
`50. The system
`of claim 49,
`
`
`
`Ex. 2003 - Page 8
`
`

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