Exhibit 3 to the Complaint.

1

U.S. Patent No. 8,671,195 v. Sirius XM Radio, Inc.

Claims 1, 2, 3, 13, 17, 18, 19, 23.

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 1 of 102 PageID #: 30
Exhibit 3 to the Complaint.

2

1. Claim Chart

Claim Analysis

[1.P] A 

digital media 

communicati

on protocol, 

comprising:

Sirius XM Radio, Inc. (“Company”) makes, uses, sells and/or offers to sell a digital media communication protocol.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, Company provides SiriusXM for Business which is an internet-based radio service. It includes a SXBR3, 

streaming player which is designed for streaming music channels. This device receives music channels from a SiriusXM 

server through a wireless internet connection, facilitating the streaming of music channels. The wireless internet 

connection is used by the SiriusXM for Business to deliver music ("digital media communication protocol").

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 2 of 102 PageID #: 31
Exhibit 3 to the Complaint.

3

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

Source: https://www.siriusxm.com/business

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 3 of 102 PageID #: 32
Exhibit 3 to the Complaint.

4

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 5

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 4 of 102 PageID #: 33
Exhibit 3 to the Complaint.

5

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[1.1] at least 

one media 

terminal 

disposed in 

an accessible 

Company makes, uses, sells and/or offers to sell at least one media terminal disposed in an accessible relation to at least 

one interactive computer network.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 5 of 102 PageID #: 34
Exhibit 3 to the Complaint.

6

rela

tion to at least 

one 

interactive 

computer 

network,

For example, the SXBR3 player ("media terminal") receives music channels from the SiriusXM server through a wireless 

internet connection ("interactive computer network") to stream music channels. The SXBR3 player scans multiple 

wireless network connections, allowing the user to choose one. Once a wireless network is selected, the user enters the 

password for the chosen connection. After successfully entering the password, the SXBR3 player establishes a 

connection to the internet, enabling it (“accessible relation “) to receive music channels from the SiriusXM server. 

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 6 of 102 PageID #: 35
Exhibit 3 to the Complaint.

7

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

media 

terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 7 of 102 PageID #: 36
Exhibit 3 to the Complaint.

8

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 (annotated)

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 8 of 102 PageID #: 37
Exhibit 3 to the Complaint.

9

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[1.2] a 

wireless 

Company makes, uses, sells and/or offers to sell a wireless range structured to permit authorized access to said at least 

one interactive computer network.

media 

terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 9 of 102 PageID #: 38
Exhibit 3 to the Complaint.

10

range 

structured to 

permit 

authorized 

access to

said at least 

one 

interactive 

computer 

network,

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player scans multiple wireless network connections, allowing the user to choose one. Once a 

wireless network is selected, the user enters the password for the chosen connection. After successfully entering the 

password (“permit authorized access”), the SXBR3 player establishes a connection to the internet, enabling it to receive 

music channels from the SiriusXM server. It would be apparent to a person of ordinary skill in the art that wireless range 

is structured to permit authorized access to at least one interactive computer network.

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 10 of 102 PageID #: 39
Exhibit 3 to the Complaint.

11

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 8 of 42 

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 11 of 102 PageID #: 40
Exhibit 3 to the Complaint.

12

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 12 of 102 PageID #: 41
Exhibit 3 to the Complaint.

13

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[1.3] at least 

one media 

node 

disposable 

within said 

Company makes, uses, sells and/or offers to sell at least one media node disposable within said wireless range, wherein 

said at least one media node is detectable by said at least one media terminal.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 13 of 102 PageID #: 42
Exhibit 3 to the Complaint.

14

wireless

range, 

wherein said 

at least one 

media node is 

detectable

by said at 

least one 

media 

terminal,

For example, the SXBR3 player receives multiple music channels from the SiriusXM server (“media node”) through the 

selected wireless internet connection. Utilizing this connection, the SXBR3 player communicates with the SiriusXM 

server regarding the available music channels. The user then selects a music channel from the list presented on the 

SXBR3 player. Following the user's selection, the SXBR3 player sends a streaming request for the chosen music channel 

to the SiriusXM server, initiating the streaming process. It would be apparent to a person of ordinary skill in the art that 

at least one media node is disposable within the wireless range, wherein at least one media node is detectable by at least 

one media terminal.

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

media node

media node

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 14 of 102 PageID #: 43
Exhibit 3 to the Complaint.

15

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[1.4] at least 

one digital 

Company makes, uses, sells and/or offers to sell at least one digital media file initially disposed on at least one of said at 

least one media terminal or said at least one media node, said at least one media terminal being structured to detect said 

media terminal

media terminal

media terminal transmits 

a streaming request to 

the media node

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 15 of 102 PageID #: 44
Exhibit 3 to the Complaint.

16

media file 

initially 

disposed on 

at least one of 

said at least 

one media 

terminal or 

said at least 

one media 

node, said at 

least one 

media 

terminal 

being 

structured to 

detect said at 

least one 

media node 

disposed 

within said 

wireless 

range,

at least one media node disposed within said wireless range.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player receives multiple music channels from the SiriusXM server (“media node”) through the 

selected wireless internet connection. Utilizing this connection, the SXBR3 player communicates with the SiriusXM 

server regarding the available music channels. The user then selects a music channel (“digital media file”) from the list 

presented on the SXBR3 player. Following the user's selection, the SXBR3 player sends a streaming request for the 

chosen music channel to the SiriusXM server, initiating the streaming process. It would be apparent for a person having 

ordinary skills in the art that digital media file is initially disposed on a media node (SiriusXM server) and at least one 

media terminal (SXBR3 player) is structured to detect at least one media node located within the wireless range.

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 16 of 102 PageID #: 45
Exhibit 3 to the Complaint.

17

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

media node

media node

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 17 of 102 PageID #: 46
Exhibit 3 to the Complaint.

18

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[1.5] a 

communicati

Company makes, uses, sells and/or offers to sell a communication link structured to dispose said at least one media 

terminal and said at least one media node in a communicative relation with one another via said at least one interactive 

media 

terminal

media terminal transmits 

a streaming request to 

the media node

digital media file

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 18 of 102 PageID #: 47
Exhibit 3 to the Complaint.

19

on link 

structured to 

dispose said 

at least one

media 

terminal and 

said at least 

one media 

node in a

communicati

ve relation 

with one 

another via 

said at least

one 

interactive 

computer 

network, 

computer network.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player streams music channels from the SiriusXM servers through internet connection

(“communication link”). Therefore, it would be apparent to a person of ordinary skill in the art that communication link 

structured to dispose said at least one media terminal and said at least one media node in a communicative relation with 

one another via said at least one interactive computer network.

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/

Source: 

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 19 of 102 PageID #: 48
Exhibit 3 to the Complaint.

20

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 20 of 102 PageID #: 49
Exhibit 3 to the Complaint.

21

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 21 of 102 PageID #: 50
Exhibit 3 to the Complaint.

22

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 4:44 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 22 of 102 PageID #: 51
Exhibit 3 to the Complaint.

23

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[1.6] said 

communicati

on link being 

initiated by 

said at least 

one

media 

terminal,

Company makes, uses, sells and/or offers to sell said communication link being initiated by said at least one media 

terminal.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player (“media terminal”) enables the user to input the username and password associated with 

their SiriusXM subscription, facilitating music channel streaming from SiriusXM server (media node) via the selected 

wireless internet connection. Following this, the SXBR3 player grants the user the option to select a music channel from 

the available list. It would be apparent to a person having ordinary skill in the art that the communication link is initiated 

by at least one media terminal.

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 23 of 102 PageID #: 52
Exhibit 3 to the Complaint.

24

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 24 of 102 PageID #: 53
Exhibit 3 to the Complaint.

25

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

media 

terminal

interactive 

computer 

network

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 25 of 102 PageID #: 54
Exhibit 3 to the Complaint.

26

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 4:44 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

media terminal

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 26 of 102 PageID #: 55
Exhibit 3 to the Complaint.

27

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[1.7] said at 

least one 

media node 

and said at 

least one 

media

terminal 

being 

structured to 

transmit said 

at least one

digital media 

file 

therebetween 

via said 

communicati

Company makes, uses, sells and/or offers to said at least one media node and said at least one media terminal being 

structured to transmit said at least one digital media file therebetween via said communication link.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SiriusXM server (“media node”) transmits (“structured to transmit”) the selected music channel 

(“digital media file”) to SXBR3 player (“media terminal”). 

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 27 of 102 PageID #: 56
Exhibit 3 to the Complaint.

28

on

link, and

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

media terminal

media node

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 28 of 102 PageID #: 57
Exhibit 3 to the Complaint.

29

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

transmit digital media 

file to media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 29 of 102 PageID #: 58
Exhibit 3 to the Complaint.

30

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 4:44 

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 30 of 102 PageID #: 59
Exhibit 3 to the Complaint.

31

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[1.8] said 

communicati

on link is 

structured to 

bypass at 

least one

media 

terminal 

security 

measure.

Company makes, uses, sells and/or offers to sell said communication link is structured to bypass at least one media 

terminal security measure for a limited permissible use of the communication link by the media node to only transferring 

the at least one digital media file to, and displaying the at least one digital media file on, the at least one media terminal.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player and the SiriusXM server do not require users to input a username and a password 

("security measure") every time they communicate. Instead, the username and password input are necessary during the 

initial connection process, and thereafter, the devices automatically exchange data without requiring users to re-enter the 

username and password ("bypassing the security measure"). Therefore, upon information and belief, the communication 

link is structured to bypass at least one media terminal security measure.

transmit 

digital media 

file

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 31 of 102 PageID #: 60
Exhibit 3 to the Complaint.

32

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 32 of 102 PageID #: 61
Exhibit 3 to the Complaint.

33

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 33 of 102 PageID #: 62
Exhibit 3 to the Complaint.

34

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 4:44 

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

media 

terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 34 of 102 PageID #: 63
Exhibit 3 to the Complaint.

35

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall

supplement these contentions pursuant to production of such source code by the Defendant.

[2] The 

digital media 

communicati

on protocol 

recited in

claim 1 

wherein

said digital 

media file is 

initially 

disposed on 

said at least 

one media 

node.

Company makes, uses, sells and/or offers to sell said digital media file is initially disposed on said at least one media 

node.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SiriusXM server initially stores (“disposed”) the music channel ("digital media file") and transmits the 

music channel to the SXBR3 player through the wireless internet connection.

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 35 of 102 PageID #: 64
Exhibit 3 to the Complaint.

36

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 36 of 102 PageID #: 65
Exhibit 3 to the Complaint.

37

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[3] The 

digital media 

communicati

on protocol 

recited in

claim 2 

wherein

said at least 

one media 

terminal is 

structured to 

display said

at least one 

digital media 

Company makes, uses, sells and/or offers to sell said at least one media terminal is structured to display said at least one 

digital media file.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player displays the selected music channel.

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

digital media file

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 37 of 102 PageID #: 66
Exhibit 3 to the Complaint.

38

file.

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

display digital 

media file 

media 

terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 38 of 102 PageID #: 67
Exhibit 3 to the Complaint.

39

[13] The 

digital media 

communicati

on protocol 

recited in

claim 1 

wherein

said 

communicati

on link is 

structured to 

bypass at 

least one

networking 

device 

security 

measure.

Company makes, uses, sells and/or offers to sell said communication link is structured to bypass at least one networking 

device security measure.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player (“networking device”) and the SiriusXM server do not require users to input a username 

and a password ("security measure") every time they communicate. Instead, the username and password input are 

necessary during the initial connection process, and thereafter, the devices automatically exchange data without requiring 

users to re-enter the username and password ("bypass at least one networking device security measure"). Therefore, upon 

information and belief, the communication link is structured to bypass at least one networking device security measure.

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 39 of 102 PageID #: 68
Exhibit 3 to the Complaint.

40

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 40 of 102 PageID #: 69
Exhibit 3 to the Complaint.

41

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 4:44 

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 41 of 102 PageID #: 70
Exhibit 3 to the Complaint.

42

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[17.P] A 

digital media 

communicati

on protocol, 

comprising

Sirius XM Radio, Inc. (“Company”) makes, uses, sells and/or offers to sell a digital media communication protocol.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, Company provides SiriusXM for Business which is an internet-based radio service. It includes a SXBR3, 

streaming player which is designed for streaming music channels. This device receives music channels from a SiriusXM 

server through a wireless internet connection, facilitating the streaming of music channels. The wireless internet 

connection is used by the SiriusXM for Business to deliver music ("digital media communication protocol").

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 42 of 102 PageID #: 71
Exhibit 3 to the Complaint.

43

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 43 of 102 PageID #: 72
Exhibit 3 to the Complaint.

44

Source: https://www.siriusxm.com/business

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 5

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 44 of 102 PageID #: 73
Exhibit 3 to the Complaint.

45

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 45 of 102 PageID #: 74
Exhibit 3 to the Complaint.

46

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[17.1] at least 

one media 

terminal and 

at least one 

media node

disposed in 

an accessible 

relation with 

at least one 

inter

active 

computer 

network,

Company makes, uses, sells and/or offers to sell at least one media terminal and at least one media node disposed in an 

accessible relation with at least one inter active computer network.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player ("media terminal") receives music channels from the SiriusXM server through a wireless 

internet connection ("interactive computer network") to stream music channels. The SXBR3 player scans multiple 

wireless network connections, allowing the user to choose one. Once a wireless network is selected, the user enters the 

password for the chosen connection. After successfully entering the password, the SXBR3 player establishes a 

connection to the internet, enabling it (“accessible relation “) to receive music channels from the SiriusXM server. 

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 46 of 102 PageID #: 75
Exhibit 3 to the Complaint.

47

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

media 

terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 47 of 102 PageID #: 76
Exhibit 3 to the Complaint.

48

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 (annotated)

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 48 of 102 PageID #: 77
Exhibit 3 to the Complaint.

49

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[17.2] at least 

one digital 

media file 

initially 

Company makes, uses, sells and/or offers to sell at least one digital media file initially disposed on at least one of said 

media terminal or said media node, said at least one media terminal structured to detect said at least one media node.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

media terminal

media 

terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 49 of 102 PageID #: 78
Exhibit 3 to the Complaint.

50

disposed on 

at least

one of said 

media 

terminal or 

said media 

node, said at

least one 

media 

terminal 

structured to 

detect said at 

least

one media 

node,

For example, the SiriusXM server stores (“initially disposed”) the multiple music channels (“digital media file”). The 

SXBR3 player receives multiple music channels from the SiriusXM server. The SXBR3 player receives music channels

from the SiriusXM server, and the user can select one music channel from the list on the SXBR3 player. After the user 

makes their music channel selection, the SXBR3 player sends a streaming request for the chosen music channel to the 

SiriusXM server. Therefore, it would be apparent to a person of ordinary skill in the art that SXBR3 player (“at least one 

media terminal”) is structured to detect SiriusXM server (“at least one media node”).

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

media terminal

media node

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 50 of 102 PageID #: 79
Exhibit 3 to the Complaint.

51

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

media node

media terminal transmits a 

streaming request to the 

media node

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 51 of 102 PageID #: 80
Exhibit 3 to the Complaint.

52

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[17.3] a 

communicati

on link 

structured to 

dispose said 

at least one

media 

terminal and 

said at least 

one media 

node in a

communicati

ve relation 

with one 

another via 

said inter

active 

Company makes, uses, sells and/or offers to sell a communication link structured to dispose said at least one media 

terminal and said at least one media node in a communicative relation with one another via said inter active computer 

network.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player scans multiple wireless network connections, and the user selects one network to enter 

the password for the chosen wireless internet connection. After entering the password, the SXBR3 player connects to the 

internet. Following this connection, the user enters the username and password for their SiriusXM subscription to enable 

music channel streaming. This process establishes a communication channel between the SXBR3 player and the 

SiriusXM server for streaming music channels. It is apparent to a person of ordinary skill in the art that this 

communication channel comprises a structured communication link, facilitating a communicative relationship between at 

least one media terminal and at least one media node via at least one interactive computer.

media terminal

digital media file

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 52 of 102 PageID #: 81
Exhibit 3 to the Complaint.

53

computer 

network,

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

Source:https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+se

rvers

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 53 of 102 PageID #: 82
Exhibit 3 to the Complaint.

54

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

media terminal

interactive computer 

network

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 54 of 102 PageID #: 83
Exhibit 3 to the Complaint.

55

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 4:44 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

media terminal

media 

terminal

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 55 of 102 PageID #: 84
Exhibit 3 to the Complaint.

56

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[17.4] said 

communicati

on link being 

initiated by 

said at least 

one

media 

terminal,

Company makes, uses, sells and/or offers to sell said communication link being initiated by said at least one media 

terminal. 

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player scans multiple wireless network connections, and the user selects one network to enter 

the password for the chosen wireless internet connection. After entering the password, the SXBR3 player connects to the 

internet. Following this connection, the user enters the username and password for their SiriusXM subscription to enable 

music channel streaming. This process establishes a communication channel (“communication link”) between the 

SXBR3 player and the SiriusXM server for streaming music channels. Therefore, a communication link is initiated by 

the SXBR3 player (“media terminal”).

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 56 of 102 PageID #: 85
Exhibit 3 to the Complaint.

57

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 57 of 102 PageID #: 86
Exhibit 3 to the Complaint.

58

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

media 

terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 58 of 102 PageID #: 87
Exhibit 3 to the Complaint.

59

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 4:44 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

media terminal

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 59 of 102 PageID #: 88
Exhibit 3 to the Complaint.

60

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[17.5] said at 

least one 

media node 

and said at 

least one 

media

terminal 

structured to 

transmit said 

at least one 

digital media 

file 

therebetween 

via said 

communicati

on link,

wherein

Company makes, uses, sells and/or offers to sell said at least one media node and said at least one media terminal 

structured to transmit said at least one digital media file therebetween via said communication link.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player utilizes the established communication channel for streaming music channel from the 

SiriusXM server.

media terminal

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 60 of 102 PageID #: 89
Exhibit 3 to the Complaint.

61

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

media node

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 61 of 102 PageID #: 90
Exhibit 3 to the Complaint.

62

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

transmit digital media 

file to media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 62 of 102 PageID #: 91
Exhibit 3 to the Complaint.

63

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 4:44 

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 63 of 102 PageID #: 92
Exhibit 3 to the Complaint.

64

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[17.6] said 

communicati

on link is 

structured to 

bypass at 

least one

media 

terminal 

security 

measure.

Company makes, uses, sells and/or offers to sell said communication link is structured to bypass at least one media 

terminal security measure. 

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player and the SiriusXM server do not require users to input a username and a password 

("security measure") every time they communicate. Instead, the username and password input are necessary during the 

initial connection process, and thereafter, the devices automatically exchange data without requiring users to re-enter the 

username and password ("bypass at least one media terminal security measure"). Therefore, upon information and belief, 

the communication link is structured to bypass at least one media terminal security measure.

transmit 

digital media 

file

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 64 of 102 PageID #: 93
Exhibit 3 to the Complaint.

65

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 65 of 102 PageID #: 94
Exhibit 3 to the Complaint.

66

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 66 of 102 PageID #: 95
Exhibit 3 to the Complaint.

67

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 4:44 

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 67 of 102 PageID #: 96
Exhibit 3 to the Complaint.

68

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to the production of such source code by Company.

[18] The 

digital media 

communicati

on protocol 

recited in 

claim 17 

further 

comprising a 

wireless 

range 

structured to 

permit 

authorized 

access to said 

at least one 

interactive 

computer 

Company makes, uses, sells and/or offers to sell a wireless range structured to permit authorized access to said at least 

one interactive computer network. 

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player scans multiple wireless network connections, and a user selects one wireless network 

within its wireless range to enter a password for the chosen wireless internet connection. After entering the selected 

wireless internet connection password, the SXBR3 player is connected to the internet, enabling it to receive music 

channels from the SiriusXM server. It would be apparent to a person of ordinary skill in the art that the digital media 

communication protocol comprises a wireless range structured to permit authorized access to said at least one interactive 

computer network. 

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 68 of 102 PageID #: 97
Exhibit 3 to the Complaint.

69

network.

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 69 of 102 PageID #: 98
Exhibit 3 to the Complaint.

70

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 8 of 42 

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 70 of 102 PageID #: 99
Exhibit 3 to the Complaint.

71

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to the production of such source code by Company.

[19] The 

digital media 

communicati

on protocol 

recited in

claim 18 

wherein

Company makes, uses, sells and/or offers to sell said at least one media node is disposable within said wireless range and 

detectable by said at least one media terminal. 

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player receives multiple music channels from the SiriusXM server through internet connection. 

The user selects one music channel from the list of multiple music channels on the SXBR3 player. The SXBR3 player 

interactive 

computer 

network

interactive 

computer 

network

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 71 of 102 PageID #: 100
Exhibit 3 to the Complaint.

72

said at least 

one media 

node is 

disposable 

within said

wireless 

range and 

detectable by 

said at least 

one media

terminal.

transmits a streaming request for the selected music channel to the SiriusXM server. It would be apparent to a person of 

ordinary skill in the art that at least one media node is disposable within said wireless range and detectable by said at 

least one media terminal.

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

media terminal

media node

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 72 of 102 PageID #: 101
Exhibit 3 to the Complaint.

73

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 (annotated)

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 73 of 102 PageID #: 102
Exhibit 3 to the Complaint.

74

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to the production of such source code by Company.

[23.P] A 

digital media 

Sirius XM Radio, Inc. (“Company”) makes, uses, sells and/or offers to sell a digital media communication protocol.

media terminal

media terminal 

transmits a streaming 

request to the media 

node

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 74 of 102 PageID #: 103
Exhibit 3 to the Complaint.

75

communicati

on protocol, 

comprising:

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, Company provides SiriusXM for Business which is an internet-based radio service. It includes a SXBR3, 

streaming player which is designed for streaming music channels. This device receives music channels from a SiriusXM 

server through a wireless internet connection, facilitating the streaming of music channels. The wireless internet 

connection is used by the SiriusXM for Business to deliver music ("digital media communication protocol").

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 75 of 102 PageID #: 104
Exhibit 3 to the Complaint.

76

Source: https://www.siriusxm.com/business

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 5

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 76 of 102 PageID #: 105
Exhibit 3 to the Complaint.

77

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 77 of 102 PageID #: 106
Exhibit 3 to the Complaint.

78

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[23.1] at least 

one media 

terminal 

disposed in

an accessible 

relation to at 

least one 

interactive 

computer 

network,

Company makes, uses, sells and/or offers to sell at least one media terminal disposed in an accessible relation to at least 

one interactive computer network.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player ("media terminal") receives music channels from the SiriusXM server through a wireless 

internet connection ("interactive computer network") to stream music channels. The SXBR3 player scans multiple 

wireless network connections, allowing the user to choose one. Once a wireless network is selected, the user enters the 

password for the chosen connection. After successfully entering the password, the SXBR3 player establishes a 

connection to the internet, enabling it (“accessible relation “) to receive music channels from the SiriusXM server. 

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 78 of 102 PageID #: 107
Exhibit 3 to the Complaint.

79

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

media 

terminal

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 79 of 102 PageID #: 108
Exhibit 3 to the Complaint.

80

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 (annotated)

media terminal

interactive 

computer 

network

interactive 

computer 

network

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 80 of 102 PageID #: 109
Exhibit 3 to the Complaint.

81

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[23.2] a 

wireless 

range 

structured to 

Company makes, uses, sells and/or offers to sell a wireless range structured to permit authorized access to said at least 

one interactive computer network.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

media 

terminal

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 81 of 102 PageID #: 110
Exhibit 3 to the Complaint.

82

permit 

authorized 

access to

said at least 

one 

interactive 

computer 

network,

For example, The SXBR3 player scans multiple wireless network connections, allowing the user to choose one. Once a 

wireless network is selected, the user enters the password for the chosen connection. After successfully entering the 

password (“permit authorized access”), the SXBR3 player establishes a connection to the internet, enabling it to receive 

music channels from the SiriusXM server. It would be apparent to a person of ordinary skill in the art that wireless range 

is structured to permit authorized access to at least one interactive computer network.

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 82 of 102 PageID #: 111
Exhibit 3 to the Complaint.

83

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 8 of 42 

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 83 of 102 PageID #: 112
Exhibit 3 to the Complaint.

84

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR3_UserGuide.pdf, Page 9 of 42 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[23.3] at least 

one media 

node 

disposed 

within said 

wireless

range, 

Company makes, uses, sells and/or offers to sell at least one media node disposed within said wireless range, wherein 

said at least one media node is detectable by said at least one media terminal.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player receives multiple music channels from the SiriusXM server (“media node”) through the 

selected wireless internet connection. Utilizing this connection, the SXBR3 player communicates with the SiriusXM 

interactive 

computer 

network

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 84 of 102 PageID #: 113
Exhibit 3 to the Complaint.

85

wherein said 

at least one 

media node is 

detectable

by said at 

least one 

media 

terminal,

server regarding the available music channels. The user then selects a music channel from the list presented on the 

SXBR3 player. Following the user's selection, the SXBR3 player sends a streaming request for the chosen music channel 

to the SiriusXM server, initiating the streaming process. It would be apparent to a person of ordinary skill in the art that 

at least one media node is disposable within the wireless range, wherein at least one media node is detectable by at least 

one media terminal.

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

media node

media node

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 85 of 102 PageID #: 114
Exhibit 3 to the Complaint.

86

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[23.4] at least 

one digital 

media file 

disposed on 

Company makes, uses, sells and/or offers to sell at least one digital media file disposed on said at least one media node, 

said at least one media terminal being structured to detect said at least one media node.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

media terminal

media terminal

media terminal transmits 

a streaming request to 

the media node

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 86 of 102 PageID #: 115
Exhibit 3 to the Complaint.

87

said at least 

one

media node, 

said at least 

one media 

terminal 

being struc

tured to 

detect said at 

least one 

media node,

For example, the SXBR3 player receives multiple music channels from the SiriusXM server (“media node”) through the 

selected wireless internet connection. Utilizing this connection, the SXBR3 player communicates with the SiriusXM 

server regarding the available music channels. The user then selects a music channel (“digital media file”) from the list 

presented on the SXBR3 player. Following the user's selection, the SXBR3 player sends a streaming request for the 

chosen music channel to the SiriusXM server, initiating the streaming process. It would be apparent for a person having 

ordinary skills in the art that digital media file is initially disposed on a media node (SiriusXM server) and at least one 

media terminal (SXBR3 player) is structured to detect at least one media node located within the wireless range.

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

media terminal

media node

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 87 of 102 PageID #: 116
Exhibit 3 to the Complaint.

88

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

media node

media terminal transmits 

a streaming request to 

the media node

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 88 of 102 PageID #: 117
Exhibit 3 to the Complaint.

89

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[23.5] a 

communicati

on link 

structured to 

dispose said 

at least one

media 

terminal and 

said at least 

one media 

node in a

communicati

ve relation 

with one 

another via 

said at least

one 

Company makes, uses, sells and/or offers to sell a communication link structured to dispose said at least one media 

terminal and said at least one media node in a communicative relation with one another via said at least one interactive 

computer network.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player streams music channels from the SiriusXM servers through internet connection 

(“communication link”). Therefore, it would be apparent to a person of ordinary skill in the art that communication link 

structured to dispose said at least one media terminal and said at least one media node in a communicative relation with 

one another via said at least one interactive computer network.

media 

terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 89 of 102 PageID #: 118
Exhibit 3 to the Complaint.

90

interactive 

computer 

network,

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

media node

media node

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 90 of 102 PageID #: 119
Exhibit 3 to the Complaint.

91

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

media terminal

interactive 

computer 

network

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 91 of 102 PageID #: 120
Exhibit 3 to the Complaint.

92

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 4:44 (annotated)

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

media terminal

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 92 of 102 PageID #: 121
Exhibit 3 to the Complaint.

93

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

[23.6] said 

communicati

on link being 

initiated by 

said at least 

one

media 

terminal and 

structured to 

bypass at 

least one

media 

terminal 

security 

measure,

Company makes, uses, sells and/or offers to sell said communication link being initiated by said at least one media 

terminal and structured to bypass at least one media terminal security measure.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SXBR3 player (“media terminal”) enables the user to input the username and password associated with 

their SiriusXM subscription, facilitating music channel streaming from SiriusXM server (media node) via the selected 

wireless internet connection. Following this, the SXBR3 player grants the user the option to select a music channel from 

the available list. It would be apparent to a person having ordinary skill in the art that the communication link is initiated 

by at least one media terminal. Further, the SXBR3 player and the SiriusXM server do not require users to input a 

username and a password ("security measure") every time they communicate. Instead, the username and password input 

are necessary during the initial connection process, and thereafter, the devices automatically exchange data without 

requiring users to re-enter the username and password (bypassing the security measure). Therefore, upon information and 

belief, the wireless channel created between SXBR3 player and the SiriusXM server bypasses at least one media terminal 

security measure.

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 93 of 102 PageID #: 122
Exhibit 3 to the Complaint.

94

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 94 of 102 PageID #: 123
Exhibit 3 to the Complaint.

95

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 95 of 102 PageID #: 124
Exhibit 3 to the Complaint.

96

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 4:44 

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43 (annotated)

media 

terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 96 of 102 PageID #: 125
Exhibit 3 to the Complaint.

97

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to the production of such source code by Company.

[23.7] said 

media node 

structured to 

transmit said 

at least one

digital media 

file to said 

media 

terminal via 

said 

communicati

on link.

Company makes, uses, sells and/or offers to sell said media node structured to transmit said at least one digital media file 

to said media terminal via said communication link.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the SiriusXM server (“media node”) transmits (“structured to transmit”) the selected music channel 

(“digital media file”) to SXBR3 player (“media terminal”). 

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/ (annotated)

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 97 of 102 PageID #: 126
Exhibit 3 to the Complaint.

98

Source: 

https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers

(annotated)

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3

media node

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 98 of 102 PageID #: 127
Exhibit 3 to the Complaint.

99

Source: https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, Page 1 of 3 

(annotated)

transmit digital media 

file to media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 99 of 102 PageID #: 128
Exhibit 3 to the Complaint.

100

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 4:44 

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:43

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 100 of 102 PageID #:

129
Exhibit 3 to the Complaint.

101

Source: https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, at 5:49 (annotated)

Further, to the extent this element is performed at least in part by Defendant’s software source code, Plaintiff shall 

supplement these contentions pursuant to production of such source code by the Defendant.

transmit 

digital media 

file

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 101 of 102 PageID #:

130
Exhibit 3 to the Complaint.

102

2. List of References

1. https://sxmbusiness.com/help-center-siriusxm-music-for-business/siriusxm-sxbr3/, last accessed on November 17, 2023. 

2. https://help.dynamicmediamusic.com/assets/SiriusXM/SXBR2_SXBR3_NetworkRequirements.pdf, last accessed on November 

17, 2023.

3. https://sxmbusiness.com/, last accessed on November 17, 2023.

4. https://sxmbusiness.com/?post_type=faq&df_post_type_search=faq&s=connect+to+the+SiriusXM+streaming+servers, last 

accessed on November 17, 2023.

Case 2:23-cv-00591-JRG-RSP Document 1-3 Filed 12/12/23 Page 102 of 102 PageID #:

131