Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 1 of 13 PageID #: 1218
`Case 2:l5—cv—0l274—JRG—RSP Document 88-1 Filed 04/01/16 Page 1 of 13 Page|D #: 1218
` 
`
`  
`
`EXHIBIT A 
`
`EXHIBIT A
`
` 
`
`

`
`Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 2 of 13 PageID #: 1219
`Blitzsafe’s P.R. 4-3 Disclosures
`
`P.R. 4-3 DISCLOSURES FOR U.S. PATENT NO.
`
`CLAIM TERM
`
`“interface”
`
`BLITZSAFE’S PROPOSED
`CONSTRUCTION
`“a device configured to
`integrate an external device
`with a car stereo”
`
`INTRINSIC SUPPORT1
`
`EXTRINSIC SUPPORT2
`
`
`
`’786 Patent, Figs 1, 2A–2C, 2E–2H and accompanying
`descriptions; 2:50–52; 4:46–56, 59–67; 5:14–24, 27–
`37; 5:38–55; 6:1–15; 6:25–33; 7:10–13.
`
`10/316,961, Response to Office Action dated June 5,
`2006 at 21-23; 10/316,961, Response to Office Action
`dated Nov. 14, 2006 at 26-36; 10/316,961, Response to
`Office Action / Request for Continued Examination
`dated June 28, 2006 at 26-38; 10/316,961, Response to
`Office Action dated July 12, 2007 at 29-37;
`10/316,961, Response to Office Action / Request for
`Continued Examination dated Feb. April 21, 2008 at
`29-34; Notice of Allowance dated July 31, 2008.
`
`’342 Patent, Figs. 1–2H, 9–11A, 12A, 13A–13B, 15,
`17–23, and accompanying descriptions; 3:21–24; 3:44–
`5:19; 9:10–16, 41–63; 9:64–11:25, 11:53–12:31;
`12:60–64; 13:55–58; 28:7–25; 34:9–18; 35:28–32 .
`
`11/475,847, Response to Office Action dated Nov. 30,
`2009, at 31–33, 35; Response to Office Action dated
`Jan. 29, 2012 at 32; Notice of Allowance dated Feb. 16,
`2012.
`
`
`
`ASSERTED
`CLAIM(S)
`’786 Patent,
`Claims 1, 5,
`6, 10, 14, 23,
`44, 57, 64,
`86, 88, 92, 97
`
`’342 Patent,
`49, 51, 52,
`73, 75, 76,
`97, 120
`
`
`
`
`1, 2
`Blitzsafe expressly reserves the right to rely upon (i) all intrinsic support cited for the ’786 Patent as extrinsic evidence for the ’342 Patent; (ii)
`all intrinsic and extrinsic evidence cited or referenced by Defendants, including all extrinsic evidence cited by parties in the Ford and Dice
`Electronics litigations; (iii) the file histories of any continuation applications related to the ’342 patent.
`
`
`
`

`
`Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 3 of 13 PageID #: 1220
`
`
`
`ASSERTED
`CLAIM(S)
`’786 Patent,
`Claims 1, 44,
`57, 90, 92
`
`’342 Patent,
`Claims 53,
`77, 97
`
`CLAIM TERM
`
`“format
`incompatible
`with the [after-
`market audio
`device,
`portable
`device, video
`device,
`portable audio
`device, MP3
`player]”
`
`P.R. 4-3 DISCLOSURES FOR U.S. PATENT NO.
`
`BLITZSAFE’S PROPOSED
`CONSTRUCTION
`Plain Meaning
`
`INTRINSIC SUPPORT1
`
`EXTRINSIC SUPPORT2
`
`Compatible: 5:
`designed to work with
`another device or system
`without modification;
`esp: being a computer
`designed to operate in
`the same manner and
`use the same software as
`another computer.
`Merriam-Webster’s
`Collegiate Dictionary
`(10th ed. 1994)
`[BLITZSAFE-0012296]
`
`’786 Patent, Abstract; Figs. 4A–4C and accompanying
`description; 1:36–44, 60–64; 2:35–40; 4:40–42; 4:59–
`67; 5:49–67; 6:11–19; 8:7–12, 22–27, 46–55; 9:45–55;
`11:30–38; 12:55–66; 13:22–25, 35–46; 14:19–30;
`17:23–18:4, including Table 1; 18:63–67.
`
`10/316,961, Response to Office Action dated June 5,
`2006 at 21-23; 10/316,961, Response to Office Action
`dated November 14, 2006 at 26-36; 10/316,961,
`Response to Office Action dated July 12, 2007 at 31,
`32, 36; Notice of Allowance dated July 31, 2008.
`
`’342 Patent, Abstract, Figs. 4A–4C and accompanying
`descriptions; 1:54–58, 60–63; 3:7–9, 47–57; 4:19–22,
`34–40, 50–55; 5:4–6, 19–23; 8:55–57; 9:10–16; 10:
`38–42; 10:43–46; 13:9–14; 14:8–14; 15:59–63; 17:19–
`30; 18:3–15; 18:58–19:2; 22:7–59 including Table 1;
`23:53–24:38 including Tables 3 and 4; 28:25–28, 51–
`54; 29:59–63; 30:31–36, 54–58; 34:19–32; 35:56–61.
`
`11/475,847, Response to Office Action dated Aug. 5,
`2011, at 32; Response to Office Action dated Jan. 29,
`2012 at 36–38; Notice of Allowance dated Feb. 16,
`2012.
`
`-2-
`
`

`
`Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 4 of 13 PageID #: 1221
`
`
`
`ASSERTED
`CLAIM(S)
`’786 Patent,
`Claim 60
`
`’342 Patent,
`Claims 54,
`70, 78, 120
`
`CLAIM TERM
`
`“format
`incompatible
`with the car
`stereo” /
`“format
`incompatible
`with the car
`audio/video
`system”
`
`P.R. 4-3 DISCLOSURES FOR U.S. PATENT NO.
`
`BLITZSAFE’S PROPOSED
`CONSTRUCTION
`Plain Meaning
`
`INTRINSIC SUPPORT1
`
`EXTRINSIC SUPPORT2
`
`Compatible: 5:
`designed to work with
`another device or system
`without modification;
`esp: being a computer
`designed to operate in
`the same manner and
`use the same software as
`another computer.
`Merriam-Webster’s
`Collegiate Dictionary
`(10th ed. 1994)
`[BLITZSAFE-0012296]
`
`’786 Patent, Abstract; 1:36–44; 1:60–2:6; 2:40–50;
`4:32–36, 59–67; 5:51–55; 5:51–54; 6:11–15, 19–24;
`8:7–12, 22–27, 55–64; 55–60; 11:38–42; 12:42–48;
`14:3–12; 18:5–67, including Table 2.
`
`
`10/316,961, Response to Office Action dated June 5,
`2006 at 21-23; 10/316,961, Response to Office Action
`dated November 14, 2006 at 26-36; 10/316,961,
`Response to Office Action / Request for Continued
`Examination dated June 28, 2006 at 26-38; 10/316,961,
`Response to Office Action dated July 12, 2007 at 31,
`32, 36; Notice of Allowance dated July 31, 2008.
`
`’342 Patent, 1:58–63; 2:23–28; 3:11–19, 57–60; 4:22–
`25, 34–40, 50–55; 5:1–3, 23–28; 9:10–20; 10:11–15,
`38–49; 10:64–11:1; 13:15–19; 14:14–19; 15:64–16:1;
`17:6–9, 57–63; 22:60–23:52 including Table 2; 26:31–
`34; 28:21–25; 29:33–39; 30:54–58; 31:66–32:3; 34:32–
`42; 35:56–61.
`
`11/475,847, Response to Office Action dated Jan. 29,
`2012, at 36–38; Notice of Allowance dated Feb. 16,
`2012.
`
`-3-
`
`

`
`Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 5 of 13 PageID #: 1222
`
`P.R. 4-3 DISCLOSURES FOR U.S. PATENT NO.
`
`INTRINSIC SUPPORT1
`
`EXTRINSIC SUPPORT2
`
`Subsystem [ENG] A
`major part of a system
`which itself has the
`characteristics of a
`system, usually
`consisting of several
`components. McGraw-
`Hill Dictionary of
`Scientific and Technical
`Terms (1st ed. 1974)
`[BLITZSAFE-0012292]
`
`Expert declaration of
`Mr. Joseph
`McAlexander regarding
`how a person of
`ordinary skill in the art
`would understand this
`claim term.
`
`
`
`10/316,961, Response to
`Office Action / Request
`for Continued
`Examination dated
`February April 21, 2008
`at 30.
`
`’342 Patent, Abstract; Figs. 3A–D, 4A–G, 10–24 and
`accompanying descriptions; 1:19–28; 2:8–11, 44–54;
`2:58–3:3; 5:7–15, 19–29, 53–54; 8:64–9:7; 12:58–
`16:29; 16:40–24:47; 25:40–47; 27:26–34, 37–41;
`27:65– 34:48–54; 27:35–28:1; 28:7–38:48..
`
`11/475,847, Response to Office Action dated Nov. 30,
`2009 at 31–36; Notice of Allowance dated Feb. 16,
`2012.
`
`10/316,961, Response to Office Action dated June 5,
`2006, at 21–23, 25, 27; Response to Office Action
`dated November 14, 2006, at 26–36; Response to
`Office Action / Request for Continued Examination
`dated June 28, 2006, at 26–38; Response to Office
`Action dated July 12, 2007 at 29, 34–37; Notice of
`Allowance dated July 31, 2008.
`
`-4-
`
`BLITZSAFE’S PROPOSED
`CONSTRUCTION
`“one or more components of a
`system or device configured
`to integrate an external device
`with a car audio/video
`system”
`
`Blitzsafe disagrees with
`Defendants’ contention that
`this term should be governed
`by 35 U.S.C. § 112, ¶ 6.
`
`Pursuant to P.R. 4-2(a), if the
`Court determines that this
`term is governed by 35 U.S.C.
`§ 112, ¶ 6, Blitzsafe agrees
`with Defendants’ recitation of
`the function of this term, and
`identifies the following
`exemplary “structure(s),
`act(s), or material(s)” that
`may correspond to this term:
`See, e.g., ’342 Patent, Figs
`3A–D, 4A–G, 10–24; 12:58–
`16:29; 16:40–24:47; 28:7–
`38:48.
`
`CLAIM TERM
`
`“integration
`subsystem”
`
`
`
`ASSERTED
`CLAIM(S)
`’342 Patent,
`Claims 49,
`50, 53–57,
`66, 70, 73,
`74, 77–80,
`94, 97, 99,
`102, 103,
`106, 113, 120
`
`

`
`
`
`ASSERTED
`CLAIM(S)
`’786 Patent,
`Claims 6, 57,
`86, 92
`
`’342 Patent,
`Claims 56,
`106
`
`Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 6 of 13 PageID #: 1223
`
`P.R. 4-3 DISCLOSURES FOR U.S. PATENT NO.
`
`CLAIM TERM
`
`“device
`presence
`signal”
`
`BLITZSAFE’S PROPOSED
`CONSTRUCTION
`Plain Meaning
`
`Or if the Court believes that
`this term requires
`construction, then: “a signal
`indicating an audio device is
`present”
`
`INTRINSIC SUPPORT1
`
`EXTRINSIC SUPPORT2
`
`
`
`’786 Patent, Figs. 4A–4G and accompanying
`descriptions; 12:29–35; 13:15–18, 62–65; 14:48–51;
`15:35–43; 16:12–20, 57–63.
`
`10/316,961, Response to Office Action dated June 5,
`2006, at 21, 25–30; Response to Office Action dated
`November 14, 2006, at 33–36; Response to Office
`Action / Request for Continued Examination, dated
`June 28, 2006, at 35–37; Response to Office Action
`dated July 12, 2007, at 34, 35; Response to Office
`Action / Request for Continued Examination dated
`February April 21, 2008, at 31, 32; Notice of
`Allowance dated July 31, 2008.
`
`’342 Patent, Figs. 4A– 4G, 11B, 12B and
`accompanying descriptions; 3:3–6; 16:52–17:1; 17:46–
`57; 18:24–27; 18:31–38; 19:20–27; 20:9–15, 57–63;
`21:39–45; 29:16–25.
`
`11/465,847, Reply to Office Action dated January 29,
`2012 at 38–39; Notice of Allowance dated Feb. 16,
`2012.
`
`-5-
`
`

`
`Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 7 of 13 PageID #: 1224
`
`
`
`P.R. 4-3 DISCLOSURES FOR U.S. PATENT NO.
`
`ASSERTED
`CLAIM(S)
`’786 Patent,
`Claims 1, 14
`
`CLAIM TERM
`
`“auxiliary
`input source”
`
`BLITZSAFE’S PROPOSED
`CONSTRUCTION
`“3.5 millimeter jack input
`source”
`
`“pre-
`programmed”
`
`’786 Patent,
`Claims 1, 7,
`8, 44, 57, 60,
`86, 92
`
`Plain Meaning
`
`Or if the Court believes that
`this term requires
`construction, then:
`“programmed prior to its use”
`
`INTRINSIC SUPPORT1
`
`EXTRINSIC SUPPORT2
`
`’786 Patent, Figs. 1, 2D–2H, 3A–3B, 4D, 4F, 5, 6 and
`accompanying descriptions; 1:25–30; 2:7–18, 23–29;
`4:43–46; 5:16–27; 6:44–51; 7:23–30, 38–46, 50–58;
`8:31–38, 42–55; 9:22–27, 38–62; 15:45–67; 16:1–4,
`40–43; 17:1–20; 19:4–11.
`
`10/316,961, Response to Office Action dated June 5,
`2006, at 21, 23–25; Response to Office Action dated
`November 14, 2006, at 26; Response to Office Action
`dated July 12, 2007, at 30, 33, 34; Response to Office
`Action / Request for Continued Examination dated
`February April 21, 2008, at 30; Notice of Allowance
`dated July 31, 2008.
`10/316,961, Response to Office Action dated April, 21
`2008, at 30–31; Notice of Allowance dated July 31,
`2008.
`
`
`
`
`
`-6-
`
`

`
`
`
`ASSERTED
`CLAIM(S)
`’786 Patent,
`Claims 1, 97
`
`’342 Patent,
`Claims 49,
`73, 97, 120
`
`Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 8 of 13 PageID #: 1225
`
`P.R. 4-3 DISCLOSURES FOR U.S. PATENT NO.
`
`CLAIM TERM
`
`“external”
`
`BLITZSAFE’S PROPOSED
`CONSTRUCTION
`“a device that is outside and
`alien to the environment of an
`OEM or after-market stereo
`system but for the inclusion of
`an interface”
`
`INTRINSIC SUPPORT1
`
`EXTRINSIC SUPPORT2
`
`
`
`’786 Patent, 1:25–35; 1:45–2:18; 2: 43–46, 50–60;
`4:47–52, 59–67; 8:22–27; 17:22–26; 18:5–10; 18:67–
`19:3; 19:7–11; 20:44–47.
`
`10/316,961, Response to Office Action dated June 5,
`2006 at 21–30; Response to Office Action dated
`November 14, 2006, at 26, 27, 29–35; Response to
`Office Action dated November 14, 2006, at 26–36;
`Response to Office Action dated July 12, 2007, at 29–
`30, 32–36; Response to Office Action / Request for
`Continued Examination dated February April 21, 2008,
`at 31; Notice of Allowance dated July 31, 2008.
`
`’342 Patent, 1:51–53; 1:64–2:17; 2:17–23; 3:14–19,
`25–28, 44–57; 4:15–16; 8:51–54; 8:64–9:3; 9:10–20;
`11:26–30; 12:49–54.
`
`11/475,847, Response to Office Action, dated Nov. 30,
`2009, at 31–25; Response to Office Action dated Jan.
`29, 2012, at 28–39; Notice of Allowance dated Feb. 16,
`2012.
`
`-7-
`
`

`
`Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 9 of 13 PageID #: 1226
`
`P.R. 4-3 DISCLOSURES FOR U.S. PATENT NO.
`
`INTRINSIC SUPPORT1
`
`EXTRINSIC SUPPORT2
`
`
`
`
`
`’786 Patent, Figs. 2A–2B, 2E, 2G, 3B, 4A–4E, 4G,
`7A–7B and accompanying descriptions; 1:6–12, 25–30;
`2:50–52; 5:41–43; 6:1–4; 7:50–53; 13:1–3; 20:19–20,
`23–24, 55–21:24.
`
`10/316,961, Response to Office Action dated June 5,
`2006, at 21–30; 10/316,961, Response to Office Action
`dated November 14, 2006, at 28, 29, 32, 33, and 37;
`10/316,961, Response to Office Action dated July 12,
`2007, at 34-36.
`
`’342 Patent, Abstract; Figs. 18–24 and accompanying
`descriptions; 2:44–67; 3:21–24; 5:2–15, 46–53; 8:38–
`46; 26:39–41; 27:6–9, 45–47; 29:44–46; 33:28–31, 48–
`56; 35:65–36:4; 36:35–42.
`
`11/475,847, Response to Office Action dated Nov. 11,
`2009, at 31–36: Response to Office Action dated Aug.
`15, 2011, at 30–32; Response to Office Action dated
`January 29, 2012, at 33, 35–39; Notice of Allowance
`dated Feb. 16, 2012.
`’786 Patent, Abstract; 1:14–56; 1:60–2:6; 2:22–32;
`2:40–50; 4:32–36, 59–67; 5:51–55; 5:51–54; 6:11–15,
`19–24; 8:7–12, 22–27, 46–49, 55–64; 9:45–49, 55–60;
`11:30–33, 38–42; 12:42–45; 14:3–7; 18:5–67,
`including Table 2.
`
`10/316,961, Response to Office Action dated June 5,
`2006, at 20–30; Response to Office Action dated
`November 14, 2006, at 28, 30-34; Response to Office
`Action dated November 14, 2006, at 26–38; Notice of
`Allowance dated July 31, 2008.
`-8-
`
`BLITZSAFE’S PROPOSED
`CONSTRUCTION
`Plain Meaning
`
`
`
`CLAIM TERM
`
`“portable”
`
`
`
`ASSERTED
`CLAIM(S)
`’786 Patent,
`Claims 44,
`57, 92, 94, 97
`
`’342 Patent,
`Claims 49,
`52–54, 56,
`57, 62–64,
`66, 70, 71,
`73, 76–78,
`80, 94, 95,
`97, 100, 101,
`103, 106,
`109–111,
`113, 115, 120
`
`
`“car stereo”
`
`’786 Patent,
`Claims 1, 6,
`13, 14, 44,
`57, 58, 60,
`63, 86, 90–92
`
`Plain Meaning
`
`Or if the Court believes that
`this term requires
`construction, then:
`“components that process
`audio signals and produce
`audible output in a car”
`
`

`
`
`
`ASSERTED
`CLAIM(S)
`’342 Patent
`,Claims 49–
`51, 53, 54,
`66, 70, 71,
`73–75, 77,
`78, 94, 97,
`99, 106, 113,
`120
`
`CLAIM TERM
`
`“car
`audio/video
`system”
`
`BLITZSAFE’S PROPOSED
`CONSTRUCTION
`Plain Meaning
`
`’786 Patent,
`Claims 10,
`86
`
`“video
`information”
`
`Plain Meaning
`
`Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 10 of 13 PageID #:
` 1227
`
`P.R. 4-3 DISCLOSURES FOR U.S. PATENT NO.
`
`INTRINSIC SUPPORT1
`
`EXTRINSIC SUPPORT2
`
`’342 Patent, Figs. 10, 11A, 12A, 13A, 15, 17–24 and
`accompanying descriptions; 1:19–28, 54–60; 2:18–54;
`33:57–62; 34:3–8; 35:37–40; 36:27–34.
`
`10/316,961, Response to Office Action dated
`November 14, 2006, at 31–32; 10/316,961, Response
`to Office Action dated July 12, 2007, at 29–37; Notice
`of Allowance dated July 31, 2008.
`
`11/475,847, Response to Office Action dated Nov. 30,
`2009, at 31–36; Response to Office Action dated Aug.
`15, 2011, at 31–32; Response to Office Action dated
`January 29, 2012, at 32–39; Notice of Allowance dated
`Feb. 16, 2012.
`’786 Patent, 2:22–52; 8:22–27; 20:44–54.
`
`10/316,961, Response to Office Action dated June 5,
`2006 at 21; 10/316,961, Response to Office Action
`dated November 14, 2006 at 26-38; 10/316,961,
`Response to Office Action dated July 12, 2007 at 34,
`35.
`
`
`
`
`
`-9-
`
`

`
`Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 11 of 13 PageID #:
` 1228
`
`P.R. 4-3 DISCLOSURES FOR U.S. PATENT NO.
`
`INTRINSIC SUPPORT1
`
`EXTRINSIC SUPPORT2
`
`’786 patent, Figs. 3A, 3C–3D; 8:37–39, 49–59; 9:8–60;
`10:19–48; 11:21–46, 59–12:3.
`
`10/316,961, Response to Office Action dated June 5,
`2006, at 21–30; Response to Office Action dated
`November 14, 2006, at 29; Response to Office Action /
`Request for Continued Examination dated June 28,
`2006, at 27–29, 31–37; Response to Office Action,
`dated July 12, 2007 at 29–36.
`
`Connector [ENG] 1. A
`detachable device for
`connecting electrical
`conductors. McGraw-
`Hill Dictionary of
`Scientific and Technical
`Terms (1st ed. 1974)
`[BLITZSAFE-0012286]
`Electrical [ELEC]
`Related to or associated
`with electricity, but not
`containing it or having
`its properties or
`characteristics; often
`used interchangeably
`with electric. McGraw-
`Hill Dictionary of
`Scientific and Technical
`Terms (1st ed. 1974)
`[BLITZSAFE-0012288]
`
`BLITZSAFE’S PROPOSED
`CONSTRUCTION
`Plain Meaning
`
`
`
`CLAIM TERM
`
`“connector
`electrically
`connectable
`to” / “electrical
`connector” /
`“connectable”
`
`
`
`ASSERTED
`CLAIM(S)
`’786 Patent,
`Claims 1, 2,
`4, 5, 57, 58,
`86, 97
`
`-10-
`
`

`
`
`
`Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 12 of 13 PageID #:
` 1229
`
`P.R. 4-3 DISCLOSURES FOR U.S. PATENT NO.
`
`BLITZSAFE’S PROPOSED
`CONSTRUCTION
`Plain Meaning
`
`ASSERTED
`CLAIM(S)
`’786 Patent,
`Claims 6, 86
`
`’342 Patent,
`Claims 56,
`106
`
`CLAIM TERM
`
`“maintaining
`… in a state
`responsive” /
`“maintain … in
`a state
`responsive”
`
`’342 Patent,
`Claims 49,
`73
`
`
`“generated . . .
`for playing on
`the car
`audio/video
`system”
`
`“produced by the portable
`device during playback”
`
`INTRINSIC SUPPORT1
`
`EXTRINSIC SUPPORT2
`
`
`
`
`
`’786 Patent, 2:32–35; 12:29–35.
`
`10/316,961, Response to Office Action dated June 5,
`2006 at 21, 25, 26, 30; Response to Office Action dated
`November 14, 2006 at 33–35; Response to Office
`Action / Request for Continued Examination dated
`June 28, 2006 at 35–37; Response to Office Action
`dated July 12, 2007 at 34, 35; Response to Office
`Action / Request for Continued Examination dated
`February April 21, 2008 at 31, 32; Notice of Allowance
`dated July 31, 2008.
`
`11/475,847, Response to Office Action dated January
`29, 2012, at 38–39; Notice of Allowance dated Feb. 16,
`2012.
`’342 Patent, 1:58–50; 9:10–16; 26:21–26; 34:32–59;
`35:56–65; 38:25–40.
`
`10/316,961, Response to Office Action dated June 5,
`2006, at 21, 25, 26, 28, 30; Response to Office Action
`dated July 12, 2007, at 33; Notice of Allowance dated
`July 31, 2008.
`
`11/475,847, Response to Office Action dated Nov. 11,
`2009, at 32–33, 35; Response to Office Action dated
`Jan. 29, 2012, at 33, 35, 37–39; Notice of Allowance
`dated Feb. 16, 2012.
`
`-11-
`
`

`
`
`
`Case 2:15-cv-01274-JRG-RSP Document 88-1 Filed 04/01/16 Page 13 of 13 PageID #:
` 1230
`
`P.R. 4-3 DISCLOSURES FOR U.S. PATENT NO.
`
`ASSERTED
`CLAIM(S)
`’786 Patent,
`Claims 2, 58
`
`CLAIM TERM
`
`“Original
`Equipment
`Manufacturer
`(OEM)”
`
`BLITZSAFE’S PROPOSED
`CONSTRUCTION
`Plain Meaning
`
`Or if the Court believes that
`this term requires
`construction, then: “as
`equipped at purchase”
`
`
`62436322 v3-WorkSiteUS-032437/0001
`
`INTRINSIC SUPPORT1
`
`EXTRINSIC SUPPORT2
`
`
`
`’786 Patent, 1:22–24, 30–35, 45–59; 2:22–31.
`
`10/316,961, Response to Office Action dated June 5,
`2006, at 20–22; Response to Office Action dated
`November 14, 2006, at 26, 29, 33–34; Response to
`Office Action / Request for Continued Examination
`dated June 28, 2006 at 26; Notice of Allowance dated
`July 31, 2008.
`
`-12-