Exhibit 4 to the Complaint.

1

U.S. Patent No. 9,300,723 v. Sirius XM Radio, Inc.

Claims 1, 3, 5, 6, 8, 9.

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 1 of 48 PageID #: 132
Exhibit 4 to the Complaint.

2

1. Claim Chart

Claim Analysis

[1.P] A media 

system, 

comprising

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

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

For example, Company provides SiriusXM for Business (“media system”) 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.

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

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 2 of 48 PageID #: 133
Exhibit 4 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 1-4 Filed 12/12/23 Page 3 of 48 PageID #: 134
Exhibit 4 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 1-4 Filed 12/12/23 Page 4 of 48 PageID #: 135
Exhibit 4 to the Complaint.

5

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

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 5 of 48 PageID #: 136
Exhibit 4 to the Complaint.

6

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 1-4 Filed 12/12/23 Page 6 of 48 PageID #: 137
Exhibit 4 to the Complaint.

7

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.

[1.1] at least 

one media 

terminal 

disposed in 

an accessible 

rela

tion 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. 

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 7 of 48 PageID #: 138
Exhibit 4 to the Complaint.

8

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 

terminal

media terminal

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 8 of 48 PageID #: 139
Exhibit 4 to the Complaint.

9

(annotated)

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

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 9 of 48 PageID #: 140
Exhibit 4 to the Complaint.

10

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 1-4 Filed 12/12/23 Page 10 of 48 PageID #: 141
Exhibit 4 to the Complaint.

11

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.

[1.2] 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 1-4 Filed 12/12/23 Page 11 of 48 PageID #: 142
Exhibit 4 to the Complaint.

12

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 1-4 Filed 12/12/23 Page 12 of 48 PageID #: 143
Exhibit 4 to the Complaint.

13

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 1-4 Filed 12/12/23 Page 13 of 48 PageID #: 144
Exhibit 4 to the Complaint.

14

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.

[1.3] at least 

one media 

node 

disposable 

within said 

wireless

range, 

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.

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

interactive 

computer 

network

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 14 of 48 PageID #: 145
Exhibit 4 to the Complaint.

15

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 1-4 Filed 12/12/23 Page 15 of 48 PageID #: 146
Exhibit 4 to the Complaint.

16

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 

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 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.

media terminal

media terminal

media terminal transmits 

a streaming request to 

the media node

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 16 of 48 PageID #: 147
Exhibit 4 to the Complaint.

17

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 struc

tured to 

detect said 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 disposed within the wireless range.

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

Source: 

media terminal

media node

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 17 of 48 PageID #: 148
Exhibit 4 to the Complaint.

18

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://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 1-4 Filed 12/12/23 Page 18 of 48 PageID #: 149
Exhibit 4 to the Complaint.

19

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

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

digital media file

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 19 of 48 PageID #: 150
Exhibit 4 to the Complaint.

20

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 1-4 Filed 12/12/23 Page 20 of 48 PageID #: 151
Exhibit 4 to the Complaint.

21

(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 1-4 Filed 12/12/23 Page 21 of 48 PageID #: 152
Exhibit 4 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 (annotated)

media terminal

media terminal

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 22 of 48 PageID #: 153
Exhibit 4 to the Complaint.

23

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.

[1.6] 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 1-4 Filed 12/12/23 Page 23 of 48 PageID #: 154
Exhibit 4 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 1-4 Filed 12/12/23 Page 24 of 48 PageID #: 155
Exhibit 4 to the Complaint.

25

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 1-4 Filed 12/12/23 Page 25 of 48 PageID #: 156
Exhibit 4 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 1-4 Filed 12/12/23 Page 26 of 48 PageID #: 157
Exhibit 4 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

on

Company makes, uses, sells and/or offers to sell 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

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 27 of 48 PageID #: 158
Exhibit 4 to the Complaint.

28

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)

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 1-4 Filed 12/12/23 Page 28 of 48 PageID #: 159
Exhibit 4 to the Complaint.

29

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 1-4 Filed 12/12/23 Page 29 of 48 PageID #: 160
Exhibit 4 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 1-4 Filed 12/12/23 Page 30 of 48 PageID #: 161
Exhibit 4 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 for a 

limited 

permis

sible use of 

the 

communicati

on link by the 

media node to 

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 ("bypass at least one media terminal security measure"). The SiriusXM server utilizes that 

communication channel exclusively for transmitting the selected music channel to the SXBR3 player (“bypass at least 

one media terminal security measure for a limited permissible use of the communication link by the media node”). The 

SXBR3 player displays the requested music channel. Therefore, upon information and belief, the wireless channel 

created between SXBR3 player and the SiriusXM server bypasses at least one media terminal security measure for a 

limited permissible use of the communication link.

transmit 

digital media 

file

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 31 of 48 PageID #: 162
Exhibit 4 to the Complaint.

32

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.

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 1-4 Filed 12/12/23 Page 32 of 48 PageID #: 163
Exhibit 4 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 1-4 Filed 12/12/23 Page 33 of 48 PageID #: 164
Exhibit 4 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 1-4 Filed 12/12/23 Page 34 of 48 PageID #: 165
Exhibit 4 to the Complaint.

35

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.

[3] The 

method of 

claim 1, 

wherein the 

transmission 

of the media 

file from the 

at least one 

media node to 

the at least 

one media 

terminal 

completely 

bypasses the 

security 

measure.

Company makes, uses, sells and/or offers to sell the transmission of the media file from the at least one media node to the 

at least one media terminal completely bypasses the 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 (bypassing the security measure). Therefore, upon information and belief, the wireless channel 

created between SXBR3 player and the SiriusXM server completely bypasses at least one media terminal security 

measure.

transfer and 

display digital 

media file 

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 35 of 48 PageID #: 166
Exhibit 4 to the Complaint.

36

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 1-4 Filed 12/12/23 Page 36 of 48 PageID #: 167
Exhibit 4 to the Complaint.

37

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

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 37 of 48 PageID #: 168
Exhibit 4 to the Complaint.

38

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 1-4 Filed 12/12/23 Page 38 of 48 PageID #: 169
Exhibit 4 to the Complaint.

39

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.

[5] The 

method of 

claim 1, 

wherein the at 

least one 

media

terminal is an 

audio system.

Company makes, uses, sells and/or offers to sell at least one media terminal is an audio system.

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

For example, the SXBR3 player is an audio system to stream multiple music channels.

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

transmission of 

the media file

media terminal

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 39 of 48 PageID #: 170
Exhibit 4 to the Complaint.

40

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

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.

[6] The Company makes, uses, sells and/or offers to sell the communication link is at least one of a peer-to-peer connection, 

audio system

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 40 of 48 PageID #: 171
Exhibit 4 to the Complaint.

41

system of 

claim 1, 

wherein the 

communicati

on link

is at least one 

of a peer-topeer 

connection, 

bluetooth 

connec

tion, and a 

WiFi 

connection.

bluetooth connection, and a WiFi connection.

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

For example, the SXBR3 player uses the WiFi connection to receive the music channel from the SiriusXM server.

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 1-4 Filed 12/12/23 Page 41 of 48 PageID #: 172
Exhibit 4 to the Complaint.

42

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 1-4 Filed 12/12/23 Page 42 of 48 PageID #: 173
Exhibit 4 to the Complaint.

43

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

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 43 of 48 PageID #: 174
Exhibit 4 to the Complaint.

44

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

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.

[8] The 

system of 

claim 1, 

further 

Company makes, uses, sells and/or offers to sell presenting the at least one digital media file on a display.

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

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 44 of 48 PageID #: 175
Exhibit 4 to the Complaint.

45

comprising 

presenting the

at least one 

digital media 

file on a 

display.

For example, the SXBR3 player displays the selected music channel (“digital media file”) for streaming.

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 5:49 (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.

[9] The 

system of 

claim 1, 

wherein the at 

least one 

digital media 

file is 

Company makes, uses, sells and/or offers to sell at least one digital media file is provided by the at least one media node.

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

For example, the SiriusXM server transmits the selected music channel to the SXBR3 player.

presenting the 

digital media file 

on a display

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 45 of 48 PageID #: 176
Exhibit 4 to the Complaint.

46

provided by 

the at least 

one media 

node.

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

media node

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 46 of 48 PageID #: 177
Exhibit 4 to the Complaint.

47

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.

digital media file 

Case 2:23-cv-00591-JRG-RSP Document 1-4 Filed 12/12/23 Page 47 of 48 PageID #: 178
Exhibit 4 to the Complaint.

48

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 1-4 Filed 12/12/23 Page 48 of 48 PageID #: 179