Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`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 the identified BMW automobiles, including those sold under the BMW and Mini
`brands. Blitzsafe does not concede that any claims of the ’786 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
`1[P]. An audio
`device
`integration
`system
`comprising:
`
`Support
`Each accused BMW infotainment system includes a device integration system supports docking integration of audio 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 infotainment 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 137
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`Page 1 of 137
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`BMW EXHIBIT 1013
`
`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
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`Page 2 of 137
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`Page 2 of 137
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 BMW 3-series Owner's Manual), at p. 190, 210-211.1
`
`
`
`
`1 Blitzsafe has produced Ex. A, 2011 BMW 3-series Owner’s Manual, simultaneously with these Infringement Contentions as a document bearing production
`numbers BS-BMW-0000001. All pin-cites are to manual pages.
`
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
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`Page 4 of 137
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`Page 4 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. B (2015 BMW Navigation, Entertainment, Communication Owner's Handbook), at p. 34, 52-53.2
`
`
`
`
`
`2 Blitzsafe has produced Ex. B, 2015 BMW Navigation, Entertainment, Communication Owner's Handbook, simultaneously with these Infringement Contentions
`as a document bearing production numbers BS-BMW-0000326. All pin-cites are to manual pages.
`
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. C (BMW F30 Entertainment and Communication Technical Training), at 8.3
`
`
`
`
`3 Blitzsafe has produced Ex. C, BMW F30 Entertainment and Communication Technical Training, simultaneously with these Infringement Contentions as a
`document bearing production numbers BS-BMW-0000482. All pin-cites are to document pages.
`
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. D (BMW ConnectedDrive A to Z), at 21.4
`
`
`
`
`
`4 Blitzsafe has produced Ex. D, BMW ConnectedDrive A to Z, simultaneously with these Infringement Contentions as a document bearing production numbers
`BS-BMW-0000534. All pin-cites are to document pages.
`
`
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`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. E (2013 Headunit High Technical Training), at p. 26.5
`
`
`
`
`
`
`5 Blitzsafe has produced Ex. E, 2013 Headunit High Technical Training, simultaneously with these Infringement Contentions as a document bearing production
`numbers BS-BMW-00000555. All pin-cites are to document pages.
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`
`See also https://youtu.be/qlIAWvZicAw; https://youtu.be/2VG-4AONXmc.
`Each accused BMW infotainment system includes a first connector that is electrically connectable to a car stereo, including
`one or more car stereo components such as, e.g., a separate head unit containing car stereo software, virtual buttons,
`display unit, amplifiers, speakers, control units (including but not limited to the iDrive controller), etc.
`
`Plaintiff contends that this element is literally present in each accused infotainment system, regardless of configuration.
`Plaintiff reserves the right to rely upon the Doctrine of Equivalents as discovery progresses.
`
`The first connector includes at least one of: (1) the connection between the "Combox" or other similar component and the
`"CIC" on the BMW device integration system (which may be a MOST bus); or (2) the connection between the “CIC” and the
`
`Page 9 of 137
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`[1A] a first
`connector
`electrically
`connectable to a
`car stereo;
`
`
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`Page 9 of 137
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`“CID,” and/or the connection between the controls (such as the iDrive controller and the steering wheel controls) and the
`“CIC”, shown annotated below:
`
`
`
`First Connector
`(MOST)
`
`See, e.g., Ex. C (BMW F30 Entertainment and Communication Technical Training), at 13.
`
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`Page 10 of 137
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
`
`First Connector
`(MOST)
`
`Claim
`
`
`
`
`
`
`
`
`
`
`
`Alternatively, the "first connector" may be the connector between the "CIC" and the "CID" and/or the connector between
`the controller (including but not limited to the iDrive controller and/or the steering wheel controls) and the “CIC,” (which
`upon information and belief is the CAN connector, but may also be the Ethernet connector) shown annotated in blue below:
`
`
`
`
`
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`Page 11 of 137
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`First Connector (Alternate)
`APIX and/or CAN/Ethernet
`
`
`See, e.g., Ex. C (BMW F30 Entertainment and Communication Technical Training), at 13.
`
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`Page 12 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
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`
`
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`
`
`First Connector (Alternate)
`
`APIX and/or CAN/Ethernet
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`
`
`
`Alternatively, BMW, through at least its supplier Alpine, also provides iPod interface kits under at least part numbers 65-11-
`
`0-439-425, 65-11-0-439-427, and 65-11-0-439-429. In such a configuration, the claimed “first connector” may be the
`connection between the iPod interface kit and the Head Unit (via the MOST bus or other connection):
`
`
`First Connector (Alternate)
`
`APIX and/or CAN/Ethernet
`
`
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`Page 14 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`First Connector (To MOST) bus)
`
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`Page 15 of 137
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`First Connector (To Head) Unit)
`
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`Page 16 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`First Connector (To MOST) bus)
`
`
`
`
`
`Upon information and belief, certain BMW device integration systems do not include a separate "Combox," or a separate
`iPod interface kit, rather, the USB and auxiliary input ports are connected directly to the head unit. See, e.g., Ex. E (2013
`Headunit High Technical Training), at p. 16-17:
`
`
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`See, e.g. Ex. E (2013 Headunit High Technical Training), at p. 16-17.
`
`In these BMW device integration systems, the “first connector electrically connectable to a car stereo” may include an
`electrical connector such as a circuit board connector, soldered connector, wired connector, optical connector, or
`software/virtual connector that is connectable to the car stereo or any component thereof, including at least the connectors
`between the Headunit High and car stereo components (including at least amplifiers, speakers, controls, and/or the CID
`display). Such first connector may also be, for example, the CAN bus connection on the head unit which receives commands
`from the controller (or other such connection for receiving commands from the controller) and/or the APIX bus connection
`which sends video information to the display and receives commands from the touchscreen.
`
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`First Connector
`(Alternate)
`
`APIX and/or CAN
`
`See, e.g. Ex. E (2013 Headunit High Technical Training), at p. 16.
`
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`First Connector
`(Alternate)
`
`APIX and/or CAN
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`
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`First Connector
`(Alternate)
`
`APIX and/or CAN
`
`
`See, e.g., Ex. E (2013 Headunit High Technical Training), at p. 29.
`
`As set forth below, the car stereo controls may be used to control the after-market audio device, and the car stereo receives
`information from the after-market audio device regardless of the particular configuration of the device integration system
`(e.g., regardless of whether the device integration system is a Combox, Head Unit, iPod interface kit, or a combination of all
`or some of these components).
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`
`
`Support
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
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`Page 23 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 BMW 3-series Owner's Manual), at p. 210-213
`
`
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. B (2015 BMW Navigation, Entertainment, Communication Owner's Handbook), at p. 53-55
`
`
`See, e.g., Ex. D (BMW ConnectedDrive A to Z), at 21.
`
`Each accused BMW infotainment system 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
`
`
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`Page 26 of 137
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`[1B] a second
`connector
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`
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`Page 26 of 137
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`electrically
`connectable to
`an after-market
`audio device
`external to the
`car stereo;
`
`Support
`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 automobile for mating via a 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 Aha and iHeart.
`
`
`
`
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`Page 27 of 137
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`Second Connector
`(USB)
`
`
`
`
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. C (BMW F30 Entertainment and Communication Technical Training), at 13-14.
`
`
`
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`Page 29 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`Second Connector
`(USB)
`
`
`
`
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`Second Connector
`(USB)
`
`
`
`See, e.g. Ex. E (2013 Headunit High Technical Training), at p. 18-19.
`
`
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`Second Connector
`(USB)
`
`
`
`
`
`
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`Second Connector
`(USB)
`
`
`
`
`See, e.g., Ex. E (2013 Headunit High Technical Training), at p. 29.
`
`Alternatively, BMW, through at least its supplier Alpine, also provides iPod interface kits under at least part numbers 65-11-
`0-439-425, 65-11-0-439-427, and 65-11-0-439-429. In such a configuration, the claimed “first connector” may be the
`connection between the iPod interface kit and the iPod, iPhone, or other device:
`
`
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`Page 33 of 137
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`Page 33 of 137
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
`
`
`
`
`
`Second Connector
`(USB)
`
`
`
`Claim
`
`
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`Second Connector
`(USB)
`
`
`
`
`
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`Page 35 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`
`
`Second Connector
`(USB)
`
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
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`
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 BMW 3-series Owner's Manual), at p. 210-213
`
`
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
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`Page 40 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. B (2015 BMW Navigation, Entertainment, Communication Owner's Handbook), at p. 53-55
`
`
`See, e.g., Ex. D (BMW ConnectedDrive A to Z), at 21.
`
`Each accused BMW infotainment system 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, BMW infotainment systems are provided
`
`
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`Page 41 of 137
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`[1C] a third
`connector
`
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`Page 41 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`electrically
`connectable to
`one or more
`auxiliary input
`sources external
`to the car stereo
`and the after-
`market audio
`device;
`
`Support
`with an auxiliary input jack that receives signals from the after-market audio devices inside the car, e.g., 3.5mm inputs, or
`other connectors separate from the first and second connectors. The auxiliary input jack is connected via the third connector
`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.
`
`In accused infotainment systems equipped with a “Combox” or other similar component, the third connector may be the
`Aux-in connector at the Combox:
`
`
`
`
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`Page 42 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`Third Connector
`(AUX)
`
`
`
`
`See, e.g., Ex. C (BMW F30 Entertainment and Communication Technical Training), at 13.
`
`
`
`
`
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`
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`Page 43 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`Third Connector
`(AUX)
`
`
`
`
`
`
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`Page 44 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`Third Connector
`(AUX)
`
`
`
`
`Alternatively, in vehicles equipped with or without a “Combox” or other similar components, the “third connector” may be
`the Aux-in connector on the “CIC” or other Head Unit:
`
`
`
`
`
`
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`Page 45 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`Third Connector
`(AUX)
`
`
`
`
`See, e.g. Ex. E (2013 Headunit High Technical Training), at p. 18.
`
`
`
`
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`Page 46 of 137
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`Page 46 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`Third Connector
`(AUX)
`
`
`
`
`
`
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`Page 47 of 137
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`Page 47 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`Third Connector
`(AUX)
`
`
`
`
`
`
`
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`Page 48 of 137
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`Page 48 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`Third Connector
`(AUX)
`
`
`
`
`
`Third Connector
`(AUX)
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`See, e.g., Ex. A (2011 BMW 3-series Owner's Manual), at p. 210-211.
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`Page 50 of 137
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`Page 50 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`
`See, e.g., Ex. B (2015 BMW Navigation, Entertainment, Communication Owner's Handbook), at p. 52.
`Each accused BMW infotainment system includes 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
`necessary hardware, software and/or firmware in: (1) the "Combox" or other similar component; (2) the iPod interface kit or
`other similar component; (3) the Head Unit or other similar component; and/or any combination of these components),
`which 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, optical connector, or
`software/virtual connector. The interface channels audio signals to the car stereo from the after-market audio device, as one
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`Page 51 of 137
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`[1D] an interface
`connected
`between said
`first and second
`electrical
`connectors for
`channeling
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`Page 51 of 137
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`

`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
`of the primary functions of the device integration system is to permit audio stored on or streamed from an after-market
`audio device to play via the car’s stereo speakers.
`
`Claim
`audio signals to
`the car stereo
`from the after-
`market audio
`device,
`
`
`See, e.g., Ex. C (BMW F30 Entertainment and Communication Technical Training), at 13.
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`Page 52 of 137
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`Page 52 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`Alternatively, the interface may include the "CIC" or other Head Unit in addition to the Combox in the accused BMW
`infotainment systems, or the interface may include the “CIC” or other Head Unit on its own:
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`Page 53 of 137
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`Page 53 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. C (BMW F30 Entertainment and Communication Technical Training), at 13.
`
`
`Alternatively, BMW, through at least its supplier Alpine, also provides iPod interface kits under at least part numbers 65-11-
`0-439-425, 65-11-0-439-427, and 65-11-0-439-429. In such a configuration, the claimed “interface” may be the interface kit
`itself.
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`Page 54 of 137
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`Page 54 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
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`
`
`Claim
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`Page 55 of 137
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`Page 55 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
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`Claim
`
`Support
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`Page 56 of 137
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`Page 56 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
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`
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`
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`Upon information and belief, certain accused BMW infotainment systems do not include a separate "Combox," or a separate
`iPod interface kit, rather, the USB and auxiliary input ports are connected directly to the head unit. In such a configuration,
`the interface comprises at least the circuitry in the head unit that translates commands between the portable device and the
`car stereo.
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`Page 57 of 137
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`Page 57 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. E (2013 Headunit High Technical Training), at p. 16.
`
`The interface of each BMW device integration system includes one or more microcontrollers 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 a microcontroller 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 microcontroller itself).
`Plaintiff will supplement its contentions, if necessary, after inspection of relevant source code.
`
`Plaintiff contends that this element is literally present in each accused infotainment system, regardless of configuration.
`Plaintiff reserves the right to rely upon the Doctrine of Equivalents as discovery progresses.
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`[1E] said
`interface
`including a
`microcontroller
`in electrical
`communication
`with said first
`and second
`electrical
`
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`Page 58 of 137
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`

`

`Claim
`connectors, said
`microcontroller
`pre-
`programmed to
`execute:
`
`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
`
`
`The specific location of the claimed “microcontroller” in the BMW interfaces may be more ascertainable upon receipt of
`discovery from BMW, including but not limited to the inspection of source code. Upon information and belief, each BMW
`interface includes a microcontroller in electrical communication with the first and second connectors.
`
`For example, the claimed microcontroller may be located in the “Combox” or other similar component, in the Head Unit, or
`in the iPod interface kit depending upon the particular configuration.
`
`
`As an example, the Combox board identified below contains a microcontroller:
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`The claimed “microcontroller” in the Combox may be a Renesas SH-4A, a Renesas V850ES, or other similar integrated circuit.
`
`Alternatively, the claimed “microcontroller” in the iPod interface kit may be the Renesas 64F2506FC26V device in the 65-11-
`0-439-425:
`
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`
`Alternatively, the claimed “microcontroller” in the iPod interface kit may be the Microchip PIC18LP2520 device in the 65-11-
`0-439-4277:
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`Page 61 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`
`
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`
`
`Alternatively, the claimed “microcontroller” in the iPod interface kit may be the Renesas 64F2506FC26V device in the 65-11-
`0-439-429:
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`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
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`
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`Alternatively, the “main processor” in the head unit below may be the “microcontroller.”
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. E (2013 Headunit High Technical Training), at p. 35.
`
`As another example, in the Alpine CI 9 228 917 01 Head Unit, the claimed microcontroller may be the Renesas R8A77850A
`shown below:
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`Page 64 of 137
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`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`
`
`
`As another example, in BMW’s Harman-supplied Head Units, the claimed microcontroller may be the Renesas R8A77850A
`shown below:
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`Page 65 of 137
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`Page 65 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
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`Page 66 of 137
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`Page 66 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`As another example, in BMW’s Harman-supplied Head Units, the claimed microcontroller may be an Intel “Atom” E6 series
`processor and/or the Texas Instruments Jacinto automotive applications processor, or other similar integrated circuit.
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`Page 67 of 137
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`

`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
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`Page 68 of 137
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`Page 68 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`
`
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`Page 69 of 137
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`Page 69 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
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`
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`Page 70 of 137
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`Page 70 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 BMW 3-series Owner's Manual), at p. 210-213
`
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`Page 71 of 137
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`Page 71 of 137
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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
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`Page 72 of 137
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`Page 72 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Claim
`
`Support
`
`
`See, e.g., Ex. B (2015 BMW Navigation, Entertainment, Communication Owner's Handbook), at p. 53-55
`
`
`See, e.g., Ex. D (BMW ConnectedDrive A to Z), at 21.
`
`The interface [see support for element [1D], above] of each accused BMW device integration system is pre-programmed to
`execute “a first pre-programmed code portion for remotely controlling the after-market audio device using the car stereo by
`
`
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`Page 73 of 137
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`[1F] a first pre-
`programmed
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`Page 73 of 137
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`

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`Appendix A
`Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of BMW Automobiles
`
`Support
`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, where they are processed and converted using pre-programmed
`software from a format understandable and compatible with the car stereo and associated BMW 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 a 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 flash memory modules), and/or is contained within firmware elsewhere in the
`interface (such as within the microcontroller itself).
`
`Plaintiff will supplement its contentions, if necessary, after inspection of relevant source code.
`
`
`
`
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`Page 74 of 137
`
`Claim
`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-
`mark