Appendix C - Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of SMART Automobiles
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`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 Smart automobiles identified in Blitzsafe's Disclosure of Asserted Claims and
`Infringement Contentions served herewith. 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 Smart’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 Smart, 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 Smart infotainment system includes a device integration system that supports integration of audio devices such
`as smartphones and other smart devices as well as MP3 players (e.g., iPods and iPhones playing MP3 files). Smart
`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 iHeartRadio applications and via online radio stations such
`as Pandora.
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`Appendix C - Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of SMART Automobiles
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`Appendix C - Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of SMART Automobiles
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`Claim
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`Support
`See, e.g., Ex. A (2011 Smart Audio system navigation/multimedia supplement), at p. 88-89.1
`
`
`
`1 Blitzsafe has produced Ex. A, 2011 Smart Audio system navigation/multimedia supplement, simultaneously with these Infringement Contentions as a
`document bearing production numbers BS-MB-00000271-BS-MB-00000386. All pin-cites are to manual pages.
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`Appendix C - Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of SMART Automobiles
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`Claim
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`Support
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`See, e.g., Ex. B (2012 Smart Audio system navigation/multimedia supplement), at p. 83-84.2
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`2 Blitzsafe has produced Ex. B, 2012 Smart Audio system navigation/multimedia supplement, simultaneously with these Infringement Contentions as a
`document bearing production numbers BS-MB-00000387-BS-MB-00000496. All pin-cites are to manual pages.
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`Appendix C - Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of SMART Automobiles
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`Appendix C - Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of SMART Automobiles
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`Claim
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`Support
`See, e.g., Ex. C (2014 Smart ForTwo Operator’s Manual), at p. 99.3
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`
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`3 Blitzsafe has produced Ex. C, 2014 Smart ForTwo Operator’s Manual, simultaneously with these Infringement Contentions as a document bearing production
`numbers BS-MB-00000767-BS-MB-00000992. All pin-cites are to manual pages.
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`Claim
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`Support
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`See, e.g., Ex. D (2015 Smart ForTwo Operator’s Manual), at p. 994
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`Claim
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`Support
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`4 Blitzsafe has produced Ex. D, 2014 Smart ForTwo Operator’s Manual, simultaneously with these Infringement Contentions as a document bearing production
`numbers BS-MB-00001263-BS-MB-00001488. All pin-cites are to manual pages.
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`Appendix C - Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of SMART Automobiles
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`Claim
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`Support
`See, e.g., Ex. E (2017 Smart Audio System Operator’s Manual), at p. 10, 11, 17, 18.5
`
`
`[1A] a first
`connector
`electrically
`connectable to a
`car stereo;
`
`Source: https://www.smart.com/en/en/index/smart-fortwo-forfour-453/connectivity.html
`Each accused Smart 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, etc.
`
`Plaintiff contends that this element is literally present in each accused infotainment system. Plaintiff reserves the right to
`rely upon the Doctrine of Equivalents as discovery progresses.
`
`The car stereo includes at least the front display and controls of the infotainment system, shown below:
`
`
`
`
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`5 Blitzsafe has produced Ex. E, 2017 Smart Audio System Operator’s Manual, simultaneously with these Infringement Contentions as a document bearing
`production numbers BS-MB-00001489-BS-MB-00001522. All pin-cites are to manual pages.
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`Claim
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`Support
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`See, e.g., Ex. A (2011 Smart Audio system navigation/multimedia supplement), at p. 8-9.
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`Claim
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`Support
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`See, e.g., Ex. B (2012 Smart Audio system navigation/multimedia supplement), at p. 8-9.
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`Claim
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`Support
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`See, e.g., Ex. C (2014 Smart ForTwo Operator’s Manual), at p. 99.
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`Claim
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`Support
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`See, e.g., Ex. D (2015 Smart ForTwo Operator’s Manual), at p. 99
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`Claim
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`Support
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`
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`See, e.g., Ex. E (2017 Smart Audio System Operator’s Manual), at p. 10, 11.
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`The car stereo also includes the vehicle’s speakers, and associated amplifiers.
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`Claim
`
`[1B] a second
`connector
`electrically
`connectable to
`an after-market
`audio device
`external to the
`car stereo;
`
`Support
`The device integration system includes “a first connector electrically connectable to a car stereo.” 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, e.g., the connector between the touch screen/controls and the remainder of the head unit.
`
`Each accused Smart 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
`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 iHeartRadio.
`
`Each Smart infotainment system contains a “second connector” that is electrically connectible to an after-market audio
`device external to the car stereo, such as a USB connector connectable to an iPhone.
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`Claim
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`Support
`
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`See, e.g., Ex. A (2011 Smart Audio system navigation/multimedia supplement), at p. 88-89.
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`Claim
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`Support
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`See, e.g., Ex. B (2012 Smart Audio system navigation/multimedia supplement), at p. 83-84.
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`Claim
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`Support
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`See, e.g., Ex. C (2014 Smart ForTwo Operator’s Manual), at p. 99.
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`Claim
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`Support
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`See, e.g., Ex. D (2015 Smart ForTwo Operator’s Manual), at p. 99
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`Claim
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`Support
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`See, e.g., Ex. E (2017 Smart Audio System Operator’s Manual), at p. 10, 11.
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`Claim
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`Support
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`
`
`Source: https://www.smart.com/en/en/index/smart-fortwo-forfour-453/connectivity.html
`
`Each accused Smart 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, Smart infotainment systems are provided
`with an auxiliary input jack that receives signals from the after-market audio devices inside the car, e.g., 3.5mm inputs or RCA
`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
`output from the automobile’s speakers.
`
`Each Smart infotainment system contains a “third connector” that is electrically connectible to an auxiliary input source
`external to the car stereo, such as an AUX connection.
`
`
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`[1C] a third
`connector
`electrically
`connectable to
`one or more
`auxiliary input
`sources external
`to the car stereo
`and the after-
`market audio
`device;
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`Claim
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`Support
`
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`See, e.g., Ex. A (2011 Smart Audio system navigation/multimedia supplement), at p. 88-89.
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`Claim
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`
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`Support
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`See, e.g., Ex. B (2012 Smart Audio system navigation/multimedia supplement), at p. 83-84.
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`Claim
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`Support
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`See, e.g., Ex. C (2014 Smart ForTwo Operator’s Manual), at p. 99.
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`Claim
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`Support
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`See, e.g., Ex. D (2015 Smart ForTwo Operator’s Manual), at p. 99
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`Claim
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`Support
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`See, e.g., Ex. E (2017 Smart Audio System Operator’s Manual), at p. 10, 11.
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`Claim
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`Support
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`[1D] an interface
`connected
`between said
`first and second
`electrical
`connectors for
`channeling
`audio signals to
`the car stereo
`from the after-
`market audio
`device,
`
`
`
`Source: https://www.smart.com/en/en/index/smart-fortwo-forfour-453/connectivity.html
`Each accused Smart 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) is the Head Unit or other similar component (or a component within the
`Head unit or other similar component) 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 of the primary functions of the device integration system is to permit audio stored on or
`streamed from an after-market audio device to output from the car’s stereo speakers.
`
`For example, the “interface” in the device integration system may be an integrated circuit within the head unit, including any
`software and/or firmware executed thereon. The “interface” may also be a circuit board or portion of a circuit board within
`the head unit, or may be entirely separate from the head unit.
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`Claim
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`Support
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`See, e.g., Ex. A (2011 Smart Audio system navigation/multimedia supplement), at p. 90-91.
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`Claim
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`
`
`Support
`
`
`
`See, e.g., Ex. B (2012 Smart Audio system navigation/multimedia supplement), at p. 85-86.
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`Claim
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`Support
`
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`See, e.g., Ex. E (2017 Smart Audio System Operator’s Manual), at p. 18.
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`Appendix C - Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of SMART Automobiles
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`Claim
`[1E] said
`interface
`including a
`microcontroller
`in electrical
`communication
`with said first
`and second
`electrical
`connectors, said
`microcontroller
`pre-
`programmed to
`execute:
`[1F] 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
`
`
`
`Support
`The interface of each device integration system of the accused Smart automobiles 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 reserves the right to supplement after inspection of relevant source code.
`
`The specific location of the claimed “microcontroller” in the Smart interfaces may be more ascertainable upon receipt of
`discovery from Smart, including but not limited to the inspection of source code. Each Smart interface includes a
`microcontroller in electrical communication with the first and second connectors.
`
`The interface [see support for element [1D], above] of each accused Smart 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
`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 Smart 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 reserves the right to supplement after inspection of relevant source code.
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`
`Claim
`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;
`
`
`
`Support
`
`
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`Claim
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`Support
`
`
`See, e.g., Ex. A (2011 Smart Audio system navigation/multimedia supplement), at p. 90-92.
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`Support
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`Appendix C - Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of SMART Automobiles
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`Claim
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`Support
`
`See, e.g., Ex. B (2012 Smart Audio system navigation/multimedia supplement), at p. 85-87.
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`Appendix C - Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of SMART Automobiles
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`Claim
`
`Support
`
`
`See, e.g., Ex. E (2017 Smart Audio System Operator’s Manual), at p. 18, 19.
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`Appendix C - Claim Chart for US Patent No. 7,489,786 Against Accused Infotainment Systems of SMART Automobiles
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`Claim
`
`[1G] a second
`pre-
`programmed
`code portion for
`receiving data
`from the after-
`market audio
`device through
`said second
`connector in a
`format
`incompatible
`with the car
`stereo,
`processing the
`received data
`into formatted
`data compatible
`with the car
`stereo, and
`transmitting the
`formatted data
`to the car stereo
`through said
`first connector
`for display by
`the car stereo;
`and
`
`
`
`Support
`
`
`The interface [see support for element [1D], above] of each accused Smart infotainment system is pre-programmed to
`execute “a second pre-programmed code portion for receiving data from the after-market audio device through said second
`connector in a format incompatible with the car stereo, processing the received data into formatted data compatible with
`the car stereo, and transmitting the formatted data to the car stereo through said first connector for display by the car
`stereo.” More specifically, in response to one or more formatted commands executed by the after-market audio device, the
`after-market audio device transmits data (such as audio, video, songs, album, track, cover art, genre and artist information)
`to the device integration system via the USB connector (i.e., the second connector). The data is then received by the
`interface of the device integration system (including at least a microcontroller), where the data is processed and converted
`using pre-programmed software from a format incompatible with the car stereo and understandable and compatible with
`the after-market audio device (i.e., USB and device-specific protocols understandable to the after-market audio device) into
`formatted data compatible with the car stereo (i.e., formatted data understandable and compatible with the car stereo and
`Smart protocols). The formatted data is then transmitted by the interface (including at least the microcontroller) to the car
`stereo via the first connector for display by the car stereo. At least the 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).
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`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 Smart Audio system navigation/multimedia supplement), at p. 91-92.
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`
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`Claim
`
`Support
`
`See, e.g., Ex. B (2012 Smart Audio system navigation/multimedia supplement), at p. 85-87.
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`
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`Claim
`
`Support
`
`
`See, e.g., Ex. E (2017 Smart Audio System Operator’s Manual), at p. 18, 19.
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`
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`
`Claim
`[1H] a third pre-
`programmed
`code portion for
`switching to one
`or more
`auxiliary input
`sources
`connected to
`said third
`electrical
`connector.
`
`Support
`The interface [see support for element [1D], above] of each accused Smart infotainment system is pre-programmed 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 microcontroller of the interface [see support for element [1E], above], (and potentially other microcontrollers on
`one or more circuit boards of the device integration system) executes pre-programmed code to perform at least a portion of
`this function. It is believed that this code is stored in onboard flash and/or other memory modules (such as flash memory
`modules), and/or is contained within firmware elsewhere in the interface (such as within the microcontroller itself).
`
`Plaintiff reserves the right to supplement after inspection of relevant source code.
`
`
`
`
`
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`
`Claim
`
`Support
`
`
`See, e.g., Ex. A (2011 Smart Audio system navigation/multimedia supplement), at p. 91.
`
`
`
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`
`Claim
`
`Support
`
`
`See, e.g., Ex. B (2012 Smart Audio system navigation/multimedia supplement), at p. 86.
`
`
`
`
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`
`Claim
`
`Support
`
`
`See, e.g., Ex. C (2014 Smart ForTwo Operator’s Manual), at p. 99.
`
`
`
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`Claim
`
`Support
`
`See, e.g., Ex. D (2015 Smart ForTwo Operator’s Manual), at p. 99
`
`
`
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`Claim
`
`Support
`
`
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`
`Claim
`
`Support
`
`
`See, e.g., Ex. E (2017 Smart Audio System Operator’s Manual), at p. 10, 11, 19.
`
`The car stereo (which may comprise portions of a head unit containing controls, virtual buttons, display unit, controls,
`amplifiers, speakers, etc.) has components that are manufactured by at least TomTom for Smart.
`
`51
`
`
`2. The apparatus
`of claim 1,
`wherein the car
`stereo further
`comprises an
`Original
`Equipment
`Manufacturer
`(OEM) car
`stereo
`connected to
`said first
`
`
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`Claim
`electrical
`connector.
`
`Support
`
` Source: https://www.tomtom.com/en_gb/in-dash-navigation/smart-media-system/
`
`
`Each accused Smart infotainment system allows for the connection of one or more of: MP3 players, iPods, iPhones or other
`smart devices, including those that receive digital audio.
`
`
`
`
`
`52
`
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`4. The apparatus
`of claim 1,
`wherein the
`after-market
`audio device
`further
`comprises a CD
`player, CD
`
`
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`Support
`
`Claim
`changer, MP3
`player, Digital
`Audio Broadcast
`(DAB) receiver,
`or satellite
`receiver
`connected to
`said second
`electrical
`connector.
`
`
`See, e.g., Ex. A (2011 Smart Audio system navigation/multimedia supplement), at p. 88, 91.
`
`
`
`
`
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`
`Claim
`
`Support
`
`
`
`See, e.g., Ex. B (2012 Smart Audio system navigation/multimedia supplement), at p. 83, 86.
`
`
`
`
`
`
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`
`Claim
`
`Support
`
`
`See, e.g., Ex. C (2014 Smart ForTwo Operator’s Manual), at p. 99.
`
`
`
`
`
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`Claim
`
`Support
`
`See, e.g., Ex. D (2015 Smart ForTwo Operator’s Manual), at p. 99
`
`
`
`
`
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`
`Claim
`
`Support
`
`
`See, e.g., Ex. E (2017 Smart Audio System Operator’s Manual), at p. 17.
`
`
`Each accused Smart infotainment system 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 accused Smart device integration systems, 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 accused
`Smart infotainment systems, which includes the requirement that the third-party accessory includes a chip to decode
`communications between the accessory and a device that has identified itself as an iPod or iPhone. See, e.g.,
`http://www.objectpartners.com/2010/09/14/communicating-with-external-devices-from-the-iphone-and-ipad/.
`
`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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`57
`
`
`5. The apparatus
`of claim 1,
`wherein said
`interface further
`comprises a
`plug-and-play
`mode for
`automatically
`detecting a
`device type of
`the after-market
`audio device
`connected to
`said second
`
`
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`
`Claim
`electrical
`connector and
`integrating the
`after-market
`audio device
`based upon the
`device type.
`
`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 specific manner in which the interface implements the plug-and-play mode of this claim may be more ascertainable by
`reviewing the source code of the interface in the accused Smart infotainment systems. Plaintiff reserves the right to
`supplement after inspection of relevant source code.
`
`
`
`Each accused Smart infotainment system includes an interface that generates 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. When a
`compatible after-market audio device is connected and recognized, the car stereo is maintained in a state responsive to the
`processed data and audio signals from the portable device.
`
`The device presence signal is generated when at least the 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 a