Case 6:20-cv-01131-ADA Document 1-2 Filed 12/11/20 Page 1 of 5
`Case 6:20-cv-01131-ADA Document 1-2 Filed 12/11/20 Page 1 of 5
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`APPENDIX A
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`APPENDIX A
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`Case 6:20-cv-01131-ADA Document 1-2 Filed 12/11/20 Page 2 of 5
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`Infringement of U.S. Patent No. 8,166,081
`By the Volkswagen Group
`Volkswagen Group automobiles provide an infotainment console that infringes the ’081 patent, for example claim 9. Many recent
`Volkswagen and Audi automobile models integrate Apple CarPlay™ and HD Radio™, FM radio with RBDS, SiriusXM®, or other
`platforms into the head unit with functionality claimed in the ’081 patent, for example claim 9. These platforms are available in many
`Volkswagen models, (e.g., the Spacefox (2016), CC (2016-18), Scirocco (2016-18), Amarok (2016-20), Beetle (2016-19), Beetle
`Cabriolet (2016-19), Golf R (2016-19), Caddy (2016-20), California (2016-20), Caravelle (2016-20), e-Golf (2016-20), Fox (2016-
`20), Golf (2016-20), Golf Cabriolet (2016-20), Golf SportsVan (2016-20), Golf Variant (2016-20), Golf SportWagen (2016-20), GTI
`(2016-20), Jetta (2016-20), Lamando (2016-20), Multivan (2016-20), Passat Variant (2016-20), Polo (2016-20), Sharan (2016-20),
`Tiguan (2016-20), Touran (2016-20), Transporter (2016-20), Passat (2016-20), Atlas (2017-20), Crafter (2017-20), CrossFox (2017-
`20), Gol (2017-20), Saveiro (2017-20), Voyage (2017-20), Arteon (2018-20), Bora (2018-20), Magotan (2018-20), Sagitar (2018-20)
`and T-Roc (2018-20)), as well as many Audi models (e.g., the A3 (2017-20), A4 (2017-20), A5 (2017-20), A6 (2017-20), A7 (2017-
`20), Q2 (2017-20), Q7 (2017-20), R8 (2017-20), TT (2017-20), Q5 (2018-20), e-tron (2019-20), Q8 (2019-20), and Q3 (2020)), which
`may have HD Radio™ or SiriusXM®, and CarPlay™ integrated or retrofitted.1 Many Volkswagen and Audi vehicles include HD
`Radio™, and may additionally include SiriusXM® or FM radio with RBDS, which enables receiving of radio broadcasts. Platforms
`like CarPlay™ enable a user to receive and process SMS messages (and other communications) while receiving music, navigation and
`Siri, via the infotainment console, thereby infringing the ’081 patent, for example claim 9.
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`1 Data from Apple Carplay page, accessed on October 13, 2020 at https://www.apple.com/ios/carplay/available-models/
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`1
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`Claim
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`9.Pre
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`9.a
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`9.b
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`Case 6:20-cv-01131-ADA Document 1-2 Filed 12/11/20 Page 3 of 5
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`Volkswagen Audi A3 HD Radio and Apple Carplay
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`A system for
`combining multiple
`media comprising:
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`a first receiver
`module configured
`to receive at least a
`first media content
`and data enabling
`the identification of
`a specific instance of
`the first media
`content from a first
`broadcast medium;
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`a second receiver
`module configured
`to receive at least a
`second media signal
`content and uniquely
`identifying data
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`The Volkswagen Head Unit Console has functionality to support Apple CarPlay, as well as HD Radio,
`SiriusXM and FM Radio features. The Volkswagen Head Unit is capable of displaying multiple items
`describing these functionalities and features at the same time on the console display. For example, the
`Volkswagen Head Unit is capable of presenting to the user an HD Radio screen including information
`about the currently broadcast song and station while also presenting to the user a banner notification
`including information about a received SMS message.
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`See:
`- 2020 Audi A3 Sedan Owner’s Manual, p. 228.2
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`The Volkswagen Head Unit Console includes a radio receiver for receiving HD Radio, FM Radio with
`RBDS, and/or Sirius XM broadcasts. The radio receiver is capable of receiving radio broadcasts
`including an audio stream of audio songs and other programming and a data stream including data
`related to a currently playing song or program, such as song title, artist, and unique identifiers associated
`with the broadcast station.
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`See:
`- 2020 Audi A3 Sedan Owner’s Manual, pp. 207, 228.
`- EddieX YouTube Video: “TOUCHSCREEN Audi MMI In-Depth Review and Tutorial!,” posted
`October 16, 2019.3
`- HD Radio Air Interface Design Description, p. 10.
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`The Volkswagen Head Unit Console includes a receiver coupled to a USB input port for use with
`compatible devices such as cell phones. The USB-coupled receiver is capable of receiving information
`from a cell-phone and processing the received information to display to a user on a console display. For
`example, the USB-coupled receiver is capable of receiving information related to a text message, or SMS
`message, received at the coupled cell phone including information that identifies the sender of the message
`and the particular message. The information related to the SMS message is received at the USB-coupled
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`2 https://bordbuch-online.audi.de/AudiBordbuch/docs/aed70582-05b7-4910-ae08-19cf1cc1d50a/206/
`3 https://www.youtube.com/watch?v=ptwrw1rfsp0
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`9.c
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`9.d
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`Case 6:20-cv-01131-ADA Document 1-2 Filed 12/11/20 Page 4 of 5
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`specific to at least
`the second media
`content, the second
`media content
`received discretely
`from the first media
`content;
`an output system
`configured to
`present concurrently
`the first media
`content and the
`second media
`content on an output
`of the first receiver
`module or the
`second receiver
`module;
`an input module
`configured to
`receive at least a
`response input
`responsive to the
`second media
`content; and
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`receiver altogether separately from a radio broadcast stream received at a radio receiver of the
`Volkswagen Head Unit.
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`See:
`- 2020 Audi A3 Sedan Owner’s Manual, pp. 175, 228.
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`The Volkswagen Head Unit Console includes a console display to provide information to the user. The
`Volkswagen Head Unit is capable of displaying information to the user about a song currently playing on
`the HD Radio or SiriusXM Radio, and also at the same time the song information is displayed, presenting
`the user with a banner notification related to a received SMS.
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`See:
`- Apple Support: iPhone User Guide, “Send and receive text messages with CarPlay.”4
`- Britta O’Boyle, Pocket-lint Reviews, July 7, 2020.5
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`The Volkswagen Head Unit Console includes microphones and input buttons (for example on the steering
`wheel and/or console, or on a touch-screen display) to allow a user to make selections related to various
`features. The Volkswagen Head Unit Console is capable of receiving a response from a user to respond to
`the received SMS in a variety of ways. For example, the user can activate Siri (the Apple digital assistant)
`by speaking a particular phrase, and can then instruct Siri to read the received message or send a dictated
`message in a response. Although the cell phone microphone may be used, the instruction input by the user
`is received at an input module of the Head Unit Console to be displayed to the user.
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`See:
`- Audi Atlanta YouTube Video: “Apple CarPlay Tutorial on 2019 Audi MMI Touch Response
`Systems,” posted April 8, 2019.6
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`4 https://support.apple.com/guide/iphone/send-and-receive-text-messages-iphb5d45624c/ios
`5 https://www.pocket-lint.com/cars/news/apple/127690-apple-carplay-explored-taking-ios-on-the-road
`6 https://www.youtube.com/watch?v=yQRUliKQN0k
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`Case 6:20-cv-01131-ADA Document 1-2 Filed 12/11/20 Page 5 of 5
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`a transmitting
`module configured
`to transmit a
`response message
`having at least the
`uniquely identifying
`data specific to the
`second media
`content to a
`computer server.
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`The Volkswagen Head Unit Console includes a processor capable of accepting user inputs on the display
`and transmitting instructions to carry out the user input to the USB-connected cell phone. For example,
`a user dictates a message in response to the received text message and a graphic is displayed on the
`console display. The processor is then capable of transmitting the instructions to send the response to
`the coupled cell phone, including the information about the sender of the original SMS, so that the text
`message can be sent.
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`See:
`- Audi Atlanta YouTube Video: “Apple CarPlay Tutorial on 2019 Audi MMI Touch Response
`Systems,” posted April 8, 2019.
`- Apple iPhone Specifications.7
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`9.e
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`7 https://www.apple.com/iphone-7/specs/
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