Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`AGREED CONSTRUCTIONS
`
`1
`
`2
`
`"integration" /
`"integrating"
`
`
`’786 Patent, claims 1,
`5, 57, 86, 92
`
`"integration" /
`"integrating"
`
`
`’342 Patent, claims
`49, 50, 53, 54, 56, 66,
`70, 73, 74, 77, 78, 79,
`80, 94, 97, 99, 102,
`103, 106, 113, 120
`
`"Connecting one or more external
`devices or inputs to an existing car radio
`or stereo via an interface, processing
`and handling signals and audio
`channels, allowing a user to control the
`devices via the car stereo, and
`displaying data from the devices on the
`radio."
`
`"Connecting one or more external
`devices or inputs to an existing car
`stereo or video system via an interface,
`processing and handling signals, audio,
`and/or video information, allowing a
`user to control the devices via the car
`stereo or video system, and displaying
`data from the devices on the car stereo
`or video system"
`
`3
`
`"auxiliary input
`source"
`
`’786 Patent, claims 1,
`14
`
`"a device that outputs audio by
`headphone jack or other connector"
`
`
`
`
`
`
`
`
`
`1
`
`Page 1 of 18
`
`BMW EXHIBIT 1009
`
`
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`AGREED CONSTRUCTIONS
`
`1
`
`2
`
`"integration" /
`"integrating"
`
`
`’786 Patent, claims 1,
`5, 57, 86, 92
`
`"integration" /
`"integrating"
`
`
`’342 Patent, claims
`49, 50, 53, 54, 56, 66,
`70, 73, 74, 77, 78, 79,
`80, 94, 97, 99, 102,
`103, 106, 113, 120
`
`"Connecting one or more external
`devices or inputs to an existing car radio
`or stereo via an interface, processing
`and handling signals and audio
`channels, allowing a user to control the
`devices via the car stereo, and
`displaying data from the devices on the
`radio."
`
`"Connecting one or more external
`devices or inputs to an existing car
`stereo or video system via an interface,
`processing and handling signals, audio,
`and/or video information, allowing a
`user to control the devices via the car
`stereo or video system, and displaying
`data from the devices on the car stereo
`or video system"
`
`3
`
`"auxiliary input
`source"
`
`’786 Patent, claims 1,
`14
`
`"a device that outputs audio by
`headphone jack or other connector"
`
`
`
`
`
`
`
`
`
`1
`
`Page 1 of 18
`
`BMW EXHIBIT 1009
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`4
`
`5
`
`"channeling audio
`signals" / "audio
`signals . . . are
`selectively
`channeled"
`
`"device presence
`signal"
`
`6
`
`"portable"
`
`7
`
`"pre-programmed"
`
`’786 Patent, claims 1,
`14
`’342 Patent, claims
`97, 113, 120
`
`’786 Patent, claims 6,
`57, 86, 92
`’342 Patent, claims
`56, 106
`
`’786 Patent, claims
`57, 92, 94, 97
`’342 Patent, claims
`49, 52, 53, 54, 56, 57,
`62, 63, 64, 66, 70, 71,
`73, 76, 77, 78, 80, 94,
`95, 97, 100, 101, 103,
`106, 109, 110, 111,
`113, 115, 120
`
`’786 Patent, claims 1,
`7, 8, 57, 60, 86, 90,
`91, 92
`
`"receiving and transmitting audio"
`
`“a continuously transmitted signal
`indicating an audio device is present”
`
`“capable of being moved about”
`
`Plain and ordinary meaning
`
`
`
`
`
`
`
`
`
`
`
`2
`
`Page 2 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`’786 Patent, claims 1,
`2, 4, 5, 57, 86, 97
`
`Plain and ordinary meaning
`
`
`
`“connector
`electrically
`connectable to” /
`“electrical connector”
`/ “connectable”
`
`PRESENTLY DISPUTED CONSTRUCTIONS
`
`"channeling audio" /
`"channels audio" /
`"channels video"
`
`’786 Patent, claims 1
`’342 Patent, claims
`97, 99, 113
`
`"receiving and transmitting audio”
`or
`“receives and transmits [audio/video]”
`
`Judge Payne’s Claim Construction
`Memorandum Opinion and Order,
`Dkt. 146, in Blitzsafe Texas, LLC v.
`Honda Motor Co., Ltd., et al., Case
`No. 2:15-cv-1274-JRG-RSP, as
`well as all briefing and evidence
`referred to therein.
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`3
`
`8
`
`1
`
`
`
`Page 3 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`2
`
`"maintain . . . in an
`operational state"
`
`’786 Patent, claims
`57, 86, 92
`
`"maintain in a state responsive to
`processed data and audio signals from
`the external device"
`
`3
`
`"maintaining . . . in a
`state responsive" /
`"maintain . . . in a
`state responsive"
`
`’786 Patent, claim 6
`’342 Patent, claims
`56, 106
`
`"preventing the car stereo from shutting
`off, entering a sleep mode, or otherwise
`being unresponsive to signals and/or
`data from an external source"
`
`Judge Payne’s Claim Construction
`Memorandum Opinion and Order,
`Dkt. 146, in Blitzsafe Texas, LLC v.
`Honda Motor Co., Ltd., et al., Case
`No. 2:15-cv-1274-JRG-RSP, as
`well as all briefing and evidence
`referred to therein.
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`Judge Payne’s Claim Construction
`Memorandum Opinion and Order,
`Dkt. 146, in Blitzsafe Texas, LLC v.
`Honda Motor Co., Ltd., et al., Case
`No. 2:15-cv-1274-JRG-RSP, as
`well as all briefing and evidence
`referred to therein.
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`
`
`4
`
`Page 4 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`4
`
`"interface"
`
`’786 Patent, claims 1,
`5, 6, 10, 14, 23, 57,
`64, 86, 88, 92, 97
`
`“a device that includes a microcontroller
`and that is a functionally and
`structurally separate component from
`the car stereo, which integrates an
`external aftermarket device with a car
`stereo”
`
`5
`
`"integration
`subsystem"
`
`’342 Patent, claims
`49, 50, 53, 54, 55, 56,
`57, 66, 70, 73, 77, 78,
`79, 80, 97, 99, 102,
`103, 106, 113, 120
`
`Not subject to 35 U.S.C. § 112 p.6
`“a subsystem that includes a
`microcontroller configured to integrate
`an external device with a car
`audio/video system”
`
`Judge Payne’s Claim Construction
`Memorandum Opinion and Order,
`Dkt. 146, in Blitzsafe Texas, LLC v.
`Honda Motor Co., Ltd., et al., Case
`No. 2:15-cv-1274-JRG-RSP, as
`well as all briefing and evidence
`referred to therein.
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`Judge Payne’s Claim Construction
`Memorandum Opinion and Order,
`Dkt. 146, in Blitzsafe Texas, LLC v.
`Honda Motor Co., Ltd., et al., Case
`No. 2:15-cv-1274-JRG-RSP, as
`well as all briefing and evidence
`referred to therein.
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`
`
`5
`
`Page 5 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`6
`
`"after-market
`[audio/video] device"
`
`’786 Patent, claims 1,
`4, 5, 7, 8, 10, 23
`
`Plain and ordinary meaning
`
`7
`
`"generated by the
`portable device over
`the [or said] wireless
`communication link
`for playing on the car
`audio/video system"
`
`’342 Patent, claims
`49, 66, 73, 94
`
`“produced by the portable device as
`decoded audio signals for playing on the
`car audio/video system”
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`Judge Payne’s Claim Construction
`Memorandum Opinion and Order,
`Dkt. 146, in Blitzsafe Texas, LLC v.
`Honda Motor Co., Ltd., et al., Case
`No. 2:15-cv-1274-JRG-RSP, as
`well as all briefing and evidence
`referred to therein.
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`
`
`6
`
`Page 6 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`Defendants’ proposed
`term for construction:
`"generated by the
`portable device to the
`car audio/video
`system using the
`wireless
`communication link"
`Blitzsafe’s proposed
`term for construction:
`“generated by the
`portable device . . .
`using the wireless
`communication link
`for subsequent
`playing of the audio
`on the car
`audio/video system”
`
`8
`
`
`
`’342 Patent, claims
`97, 120
`
`No construction necessary
`/ “produced by the portable device as
`decoded audio signals for playing on the
`car audio/video system”
`
`Judge Payne’s Claim Construction
`Memorandum Opinion and Order,
`Dkt. 146, in Blitzsafe Texas, LLC v.
`Honda Motor Co., Ltd., et al., Case
`No. 2:15-cv-1274-JRG-RSP, as
`well as all briefing and evidence
`referred to therein.
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`7
`
`Page 7 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`9
`
`"external"
`
`’786 Patent, claims 1,
`57, 86, 92
`’342 Patent, claims
`49, 73, 97, 120
`
`“outside and alien to the environment of
`an OEM or after-market [car stereo/car
`audio/video system]”
`
`
`10
`
`"car stereo"
`
`’786 Patent, claims 1,
`2, 6, 13, 14, 57, 58,
`60, 63, 86, 90, 91, 92
`
`
`
`“All presently existing car stereos and
`radios, such as physical devices that are
`present at any location within a vehicle,
`in addition to software and /or
`graphically-or display-driven receivers.
`An example of such a receiver is a
`software-driven receiver that operated
`on a universal LCD panel within a
`vehicle and is operable by a user via a
`graphical user interface displayed on the
`universal LCD panel. Further, any
`future receiver, whether a hardwired or
`a software/graphical receiver operable
`on one or more displays, is considered
`within the definition of the terms ‘car
`stereo’ and ‘car radio.’”
`
`8
`
`Judge Payne’s Claim Construction
`Memorandum Opinion and Order,
`Dkt. 146, in Blitzsafe Texas, LLC v.
`Honda Motor Co., Ltd., et al., Case
`No. 2:15-cv-1274-JRG-RSP, as
`well as all briefing and evidence
`referred to therein.
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`Judge Payne’s Claim Construction
`Memorandum Opinion and Order,
`Dkt. 146, in Blitzsafe Texas, LLC v.
`Honda Motor Co., Ltd., et al., Case
`No. 2:15-cv-1274-JRG-RSP, as
`well as all briefing and evidence
`referred to therein.
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`Page 8 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`"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
`transmitting the
`formatted command
`to the after-market
`audio device through
`said second connector
`for execution by the
`after-market audio
`device"
`
`11
`
`
`
`’786 Patent, claim 1 Not subject to 35 U.S.C. § 112, p. 6.
`Plain and ordinary meaning
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`9
`
`Page 9 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`"a first pre-
`programmed code
`portion for generating
`a device presence
`signal and
`transmitting the
`signal to the car
`stereo to maintain the
`car stereo in an
`operational state" / "a
`first pre-programmed
`code portion for
`generating a device
`presence signal and
`transmitting the
`signal to the car
`stereo through said
`first electrical
`connector to maintain
`the car stereo in an
`operational state
`responsive to signals
`generated by the
`after-market video
`device"
`
`12
`
`
`
`’786 Patent, claim 86 Not subject to 35 U.S.C. § 112, p. 6.
`Plain and ordinary meaning
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`10
`
`Page 10 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`"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
`a 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"
`
`13
`
`
`
`’786 Patent, claim 1 Not subject to 35 U.S.C. § 112, p. 6.
`Plain and ordinary meaning
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`11
`
`Page 11 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`’786 Patent, claim 91 Not subject to 35 U.S.C. § 112, p. 6.
`Plain and ordinary meaning
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`14
`
`"a third code portion
`for receiving data
`from the video device
`incompatible with the
`car stereo, processing
`received data into
`formatted data
`compatible with the
`car stereo, and
`transmitting
`formatted data . . ."
`
`
`
`12
`
`Page 12 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`"a third pre-
`programmed code
`portion for remotely
`controlling the MP3
`player using the car
`stereo by receiving a
`control command
`from the car stereo
`through said first
`electrical connector
`in a format
`incompatible with the
`MP3 player,
`processing the control
`command into a
`formatted control
`command compatible
`with the MP3 player,
`and transmitting the
`formatted control
`command to the MP3
`player through said
`second electrical
`connector for
`execution by the MP3
`player."
`
`15
`
`
`
`’786 Patent, claim 57 Not subject to 35 U.S.C. § 112, p. 6.
`Plain and ordinary meaning
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`13
`
`Page 13 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`Extrinsic Evidence
`
`’786 Patent, claim 1 Not subject to 35 U.S.C. § 112, p. 6.
`Plain and ordinary meaning
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`16
`
`"a third pre-
`programmed code
`portion for switching
`to one or more
`auxiliary input
`sources connected to
`said third electrical
`connector"
`
`17
`
`"car audio/video
`system"
`
`Plain and ordinary meaning
`
`’342 Patent, claims
`49, 50, 51, 53, 54, 56,
`57, 66, 70, 73, 74, 75,
`77, 78, 94, 97, 106,
`113, 120
`
`Judge Payne’s Claim Construction
`Memorandum Opinion and Order,
`Dkt. 146, in Blitzsafe Texas, LLC v.
`Honda Motor Co., Ltd., et al., Case
`No. 2:15-cv-1274-JRG-RSP, as
`well as all briefing and evidence
`referred to therein.
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`18
`
`"video device"
`
`’786 Patent, claims
`10, 86
`
`Plain and ordinary meaning
`
`
`
`14
`
`Page 14 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`19
`
`"video file"
`
`’342 Patent, claims
`66, 68, 94, 113, 115
`
`Plain and ordinary meaning
`
`20
`
`"first pre-
`programmed means
`for generating a
`device presence
`signal"
`
`’786 Patent, Claim 92 Subject to 35 U.S.C. § 112, p. 6.
`Structure: “ports J2A1, X2, RCH, and
`LCH, connected to a power source (i.e.
`battery) that are provided for allowing
`connection between the interface system
`of the present invention and an after-
`market device, or an auxiliary input
`source” and “a microcontroller (U1)
`with hardware components such as
`resistors, diodes, capacitors, and
`oscillators.”
`Function: “generating a device presence
`signal to the car stereo”
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`"first pre-
`programmed means
`for . . . transmitting
`the signal to the car
`stereo to maintain the
`car stereo in an
`operational state"
`
`’786 Patent, Claim 92 Subject to 35 U.S.C. § 112, p. 6.
`Structure: the “resistors, diodes,
`capacitors, transistors, transformers,
`amplifiers, oscillator” of FIG. 3B”
`Function: “transmitting the signal to the
`car stereo to maintain the car stereo in
`an operational state”
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`15
`
`21
`
`
`
`Page 15 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`"a second code
`portion for receiving
`a control signal from
`the car . . . ,
`processing a received
`control signal . . .,
`and transmitting the
`formatted control
`signal . . ."
`
`"a third code portion
`for receiving data
`from the MP3 player
`. . ., processing
`received data . . ., and
`transmitting
`formatted data . . ."
`
`22
`
`23
`
`
`
`’786 Patent, claim 90 Not subject to 35 U.S.C. § 112, p. 6.
`Plain and ordinary meaning
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`’786 Patent, claim 60 Not subject to 35 U.S.C. § 112, p. 6.
`Plain and ordinary meaning
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`16
`
`Page 16 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`"second pre-
`programmed means
`for remotely
`controlling the
`portable audio device
`using the car stereo
`by receiving a control
`command from the
`car stereo in a format
`incompatible with the
`portable audio
`device"
`
`"second pre-
`programmed means
`for remotely
`controlling the
`portable audio device
`using the car stereo
`by . . . processing the
`control command into
`a formatted control
`command compatible
`with the portable
`audio device"
`
`’786 Patent, Claim 92 Subject to 35 U.S.C. § 112, p. 6.
`Structure: “a microcontroller, which is
`comprised of a 16F873 microcontroller
`manufactured by MICROCHIP, Inc.;
`and a plurality of resistors (R1-R7),
`capacitors (C1-C2), and amplifier (A1).”
`Function: “remotely controlling the
`portable audio device using the car
`stereo by receiving a control command
`from the car stereo in a format
`incompatible with the portable audio
`device.”
`
`’786 Patent, Claim 92 Subject to 35 U.S.C. § 112, p. 6.
`Structure: “the code or algorithm
`illustrated in Tables 1 and 2 of the ’786
`patent.”
`Function: “remotely controlling the
`portable audio device by processing a
`control command from the car stereo in
`a format compatible with the portable
`audio device.”
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`17
`
`24
`
`25
`
`
`
`Page 17 of 18
`
`
`
`Appendix A
`
`Plaintiff Blitzsafe Texas, LLC’s Proposed Constructions and Extrinsic Evidence
`Pursuant to Patent Rule 4-2
`
`Blitzsafe’s Preliminary Construction
`
`Extrinsic Evidence
`
`No. Claim Term/Phrase
`
`Patent/Claims
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`Blitzsafe may rely on the expert
`testimony of Mr. Joseph
`McAlexander in connection with
`this claim term.
`
`26
`
`"second pre-
`programmed means
`for remotely
`controlling the
`portable audio device
`using the car stereo
`by . . . transmitting
`the formatted control
`command to the
`portable audio device
`for execution
`thereby"
`
`27
`
`"means for
`transmitting audio
`from the portable
`audio device to the
`car stereo"
`
`
`
`
`
`’786 Patent, Claim 92 Subject to 35 U.S.C. § 112, p. 6.
`Structure: “circuit in Figure 3B . . .
`having a plurality of resistors, diodes,
`capacitors, transistors, transformers,
`amplifiers, oscillator, among other
`structural components that provide the
`hardware framework, for the
`microcontroller to act as an interface in
`integrating an after-market device with a
`car stereo”
`Function: “transmitting the formatted
`control command to the portable audio
`device for execution thereby”
`
`’786 Patent, Claim 92 Subject to 35 U.S.C. § 112, p. 6.
`Structure: “circuit in Figure 3B . . .
`having a plurality of resistors, diodes,
`capacitors, transistors, transformers,
`amplifiers, oscillator, among other
`structural components that provide the
`hardware framework, for the
`microcontroller to act as an interface in
`integrating an after-market device with a
`car stereo”
`Function: “transmitting audio from the
`portable audio device to the car stereo”
`
`18
`
`Page 18 of 18
`
`
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