EXHIBIT D

Case 6:20-cv-00441-ADA Document 1-4 Filed 05/29/20 Page 1 of 12
CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS

U.S. Patent No. 8,224,569

1

Note: All internet sources last accessed and downloaded May 28, 2020.

Ex. D - U.S. Patent No. 8,224,569 – Volvo Car Corporation and Volvo Car USA, LLC

Claim 2

Omnitek Partners LLC (“Omnitek”) provides evidence of infringement of claim 2 of U.S. Patent No. 8,224,569 (hereinafter “the ’569 patent”) 

by Volvo Car Corporation and Volvo Car USA, LLC (collectively “Volvo”). In support thereof, Omnitek provides the following claim charts.

“Accused Instrumentalities” as used herein refers to at least the following products and services: Volvo Sensus Navigation (See

https://www.volvocars.com/intl/why-volvo/human-innovation/future-of-driving/connectivity/sensus-navigation),available on Volvo vehicles. The 

Volvo Sensus Navigation product line was introduced by at least 2013 (See https://www.digitaltrends.com/car-reviews/2013-volvo-xc60-review/ and 

https://www.jdpower.com/cars/volvo/new-2013-volvo)(describing the Sensus navigation system found in a model year 2013 Volvo vehicle.)

Therefore, the infringement has been occurring since at least that time. These claim charts demonstrate Volvo’s infringement, and provide notice of 

such infringement, by comparing each element of the asserted claims to corresponding components, aspects, and/or features of the Accused 

Instrumentalities. These claim charts are not intended to constitute an expert report on infringement. These claim charts include information 

provided by way of example, and not by way of limitation.

The analysis set forth below is based only upon information from publicly available resources regarding the Infringing Instrumentalities, as 

Volvo has not yet provided any non-public information. An analysis of Volvo’s (or other third parties’) technical documentation, and/or software 

source code, may assist in fully identifying all infringing features and functionality. Accordingly, Omnitek reserves the right to supplement this 

infringement analysis once such information is made available to Omnitek. Furthermore, Omnitek reserves the right to revise this infringement 

analysis, as appropriate, upon issuance of a court order construing any terms recited in the asserted claims.

Unless otherwise noted, Omnitek contends that Volvo directly infringes the ’569 patent in violation of 35 U.S.C. § 271(a) by selling, offering 

to sell, making, using, and/or importing the Infringing Instrumentalities. The following exemplary analysis demonstrates that infringement. Unless 

otherwise noted, Omnitek further contends that the evidence below supports a finding of indirect infringement under 35 U.S.C. §§ 271(b) and/or (c), 

in conjunction with other evidence of liability under one or more of those subsections. Volvo makes, uses, sells, imports, or offers for sale in the 

United States, or has made, used, sold, imported, or offered for sale in the past, without authority, or induces others to make, use, sell, import, or offer 

for sale in the United States, or has induced others to make, use, sell, import, or offer for sale in the past, without authority products, equipment, or 

services that infringe claim 2 of the ’569 patent, including without limitation, the Accused Instrumentalities. 

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CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS

U.S. Patent No. 8,224,569

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Note: All internet sources last accessed and downloaded May 28, 2020.

Unless otherwise noted, Omnitek believes and contends that each element of each claim asserted herein is literally met through Volvo’s

provision of the Infringing Instrumentalities. However, to the extent that Volvo attempts to allege that any asserted claim element is not literally met, 

Omnitek believes and contends that such elements are met under the doctrine of equivalents. More specifically, in its investigation and analysis of 

the Infringing Instrumentalities, Omnitek did not identify any substantial differences between the elements of the patent claims and the corresponding 

features of the Infringing Instrumentalities, as set forth herein. In each instance, the identified feature of the Infringing Instrumentalities performs at 

least substantially the same function in substantially the same way to achieve substantially the same result as the corresponding claim element.

To the extent the chart of an asserted claim relies on evidence about certain specifically-identified Accused Instrumentalities, Omnitek asserts 

that, on information and belief, any similarly-functioning instrumentalities also infringes the charted claim. Omnitek reserves the right to amend this 

infringement analysis based on other products made, used, sold, imported, or offered for sale by Volvo. Omnitek also reserves the right to amend 

this infringement analysis by citing other claims of the ’569 patent, not listed in the claim chart, that are infringed by the Accused Instrumentalities. 

Omnitek further reserves the right to amend this infringement analysis by adding, subtracting, or otherwise modifying content in the “Accused 

Instrumentalities” column of each chart.

Case 6:20-cv-00441-ADA Document 1-4 Filed 05/29/20 Page 3 of 12
CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS

U.S. Patent No. 8,224,569

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Note: All internet sources last accessed and downloaded May 28, 2020.

Volvo Car Corporation - Sensus

Sensus Navigation is the fully integrated, connected navigation system that helps you get where you want to go as easily as possible. Helpful features include 

Send to Car, which allows you to send destinations to your car, either from your browser or through the Volvo On Call app. Sensus Navigation also gives you 

access to navigation-related services and apps that help you find new experiences and new places to go, in a way that’s intuitive and easy to understand.

Source: https://www.volvocars.com/intl/why-volvo/human-innovation/future-of-driving/connectivity/sensus-navigation

Case 6:20-cv-00441-ADA Document 1-4 Filed 05/29/20 Page 4 of 12
CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS

U.S. Patent No. 8,224,569

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Note: All internet sources last accessed and downloaded May 28, 2020.

Claim US Patent 

8,224,569

Description of the Infringement

Indep.

Cl. 2

2-p

A method for 

electronically 

generating driving 

directions without 

text entry, the 

method 

comprising:

Volvo integrates navigation functions (electronically generating driving directions) in the Sensus multimedia system installed in 

their cars. 

Source: Volvo Sensus Navigation as featured in the V90 Cross Country https://www.telegraph.co.uk/business/sme-library/fleetmanagement/connected-cars-questions-answered/ (annotation added)

Source: Volvo Sensus Navigation Tutorial @0:20, https://www.youtube.com/watch?v=KVlujeJ67N0 (annotation added)

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CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS

U.S. Patent No. 8,224,569

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Note: All internet sources last accessed and downloaded May 28, 2020.

Claim US Patent 

8,224,569

Description of the Infringement

In the Volvo Sensus Navigation system “Several navigation system functions can be activated with voice commands.” (without 

text entry)

Source: Sensus Navigation Manual, p.9, 

https://az685612.vo.msecnd.net/pdfs/60e30a5db4efb136ed86c99e372daac667634796/SensusNavigation_MY19_en-GB_TP28352.pdf

(emphasis added)

Case 6:20-cv-00441-ADA Document 1-4 Filed 05/29/20 Page 6 of 12
CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS

U.S. Patent No. 8,224,569

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Note: All internet sources last accessed and downloaded May 28, 2020.

Claim US Patent 

8,224,569

Description of the Infringement

2-a indicating a 

starting address or 

starting location 

on a map without 

text entry;

The Volvo Sensus Navigation system uses the current location provided by the GPS controller and displayed on the screen as the 

starting location (indicating a starting location without text entry).

Source: Sensus Navigation Manual, p.4, 

https://az685612.vo.msecnd.net/pdfs/60e30a5db4efb136ed86c99e372daac667634796/SensusNavigation_MY19_en-GB_TP28352.pdf

(annotation added)

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U.S. Patent No. 8,224,569

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Note: All internet sources last accessed and downloaded May 28, 2020.

Claim US Patent 

8,224,569

Description of the Infringement

2-b indicating an 

ending address or 

ending location on 

a map without 

text entry;

The Volvo Sensus Navigation system recognizes the voice command “Go to [Address]” which “Specifies an address as a 

destination” (indicating an ending address or ending location on a map without text entry).

Source: Sensus Navigation Manual, p.9, 

https://az685612.vo.msecnd.net/pdfs/60e30a5db4efb136ed86c99e372daac667634796/SensusNavigation_MY19_en-GB_TP28352.pdf

(emphasis added)

Case 6:20-cv-00441-ADA Document 1-4 Filed 05/29/20 Page 8 of 12
CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS

U.S. Patent No. 8,224,569

8

Note: All internet sources last accessed and downloaded May 28, 2020.

Claim US Patent 

8,224,569

Description of the Infringement

2-c generating driving 

directions based 

on the indicated 

starting address or 

starting location 

and ending 

address or ending 

location; and

The Volvo Sensus Navigation system “Settings are selected ... to define how the route is to be calculated .... in the navigation 

system” (generating driving directions based on the indicated starting address, ending address).

Source: Sensus Navigation Manual, p.22, 

https://az685612.vo.msecnd.net/pdfs/60e30a5db4efb136ed86c99e372daac667634796/SensusNavigation_MY19_en-GB_TP28352.pdf

(emphasis added)

Source: Volvo Sensus Navigation Tutorial @3:27, https://www.youtube.com/watch?v=KVlujeJ67N0 (annotation added) 

Case 6:20-cv-00441-ADA Document 1-4 Filed 05/29/20 Page 9 of 12
CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS

U.S. Patent No. 8,224,569

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Note: All internet sources last accessed and downloaded May 28, 2020.

Claim US Patent 

8,224,569

Description of the Infringement

2-d indicating an 

intermediate 

address or 

location on the 

map 

where the 

generating 

generates driving 

directions 

from the starting 

address or 

location to the 

intermediate 

address and 

location and from 

the intermediate 

address or 

location to the 

ending address or 

location;

The Volvo Sensus Navigation provides for adding a “Junction” as a “Waypoint” to a route (intermediate address) and generating 

an “itinerary” (driving directions from the starting address or location to the intermediate address and location and from the 

intermediate address or location to the ending address or location) .

Source: Volvo Sensus Navigation Tutorial @1:44, https://www.youtube.com/watch?v=KVlujeJ67N0 (annotation added) 

Case 6:20-cv-00441-ADA Document 1-4 Filed 05/29/20 Page 10 of 12
CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS

U.S. Patent No. 8,224,569

10

Note: All internet sources last accessed and downloaded May 28, 2020.

Claim US Patent 

8,224,569

Description of the Infringement

Source: Sensus Navigation Manual, p.15, 

https://az685612.vo.msecnd.net/pdfs/60e30a5db4efb136ed86c99e372daac667634796/SensusNavigation_MY19_en-GB_TP28352.pdf (emphasis added)

2-e wherein the 

intermediate 

address is 

indicated on a 

different map as 

one of the starting 

and ending 

address.

The Volvo Sensus Navigation “displays the itinerary...during road navigation” (the intermediate address is indicated on a 

different map as one of the starting and ending address.)

Source: Sensus Navigation Manual, p.15, 

https://az685612.vo.msecnd.net/pdfs/60e30a5db4efb136ed86c99e372daac667634796/SensusNavigation_MY19_en-GB_TP28352.pdf (emphasis added)

The patent specifications provides for the maps being displayed sequentially on the screen.

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CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS

U.S. Patent No. 8,224,569

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Note: All internet sources last accessed and downloaded May 28, 2020.

Claim US Patent 

8,224,569

Description of the Infringement

Source: US Patent 8,224,569 (See column 5, lines 9-14)

Caveat: The notes and/or cited excerpts utilized herein are set forth for illustrative purposes only and are not meant to be limiting in any manner. For example, 

the notes and/or cited excerpts, may or may not be supplemented or substituted with different excerpt(s) of the relevant reference(s), as appropriate. Further, 

to the extent any error(s) and/or omission(s) exist herein, all rights are reserved to correct the same.

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