`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION
`
`
`Case No. 2:22-md-03034-TGB
`
`In Re: Neo Wireless, LLC,
`Patent Litigation
`
`
`Neo Wireless, LLC, v.
`Ford Motor Company
`Neo Wireless, LLC, v.
`American Honda Motor Co., Inc., et al.
`
`Neo Wireless, LLC, v.
`Volkswagen Group of America, Inc. et
`al.
`
`Neo Wireless, LLC, v.
`Nissan North America Inc. et al.
`
`Neo Wireless, LLC, v.
`Toyota Motor Corporation et al.
`
`Neo Wireless, LLC, v.
`General Motors Company et al.
`
`Neo Wireless, LLC, v.
`Tesla Inc.
`
`Neo Wireless, LLC, v.
`Mercedes-Benz USA, LLC
`
`Neo Wireless, LLC, v.
`FCA US LLC
`
` Hon. Terrence G. Berg
`
`2:22-CV-11402-TGB
`
`2:22-CV-11403-TGB
`
`2:22-CV-11404-TGB
`
`
`
`2:22-CV-11405-TGB
`
`2:22-CV-11406-TGB
`
`2:22-CV-11407-TGB
`
`2:22-CV-11408-TGB
`
`2:22-CV-11769-TGB
`
`2:22-CV-11770-TGB
`
`
`NOTICE OF SUPPLEMENTAL FACTS REGARDING THE STATUS OF
`INTER PARTES REVIEW PROCEEDINGS
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 153, PageID.10748 Filed 06/16/23 Page 2 of 3
`
`
`
`Plaintiff Neo Wireless, LLC writes to notify the Court of supplemental facts
`
`regarding the status of inter partes reviews proceedings that are relevant to
`
`Defendants’ Joint Motion to Stay Pending Inter Partes Review. See Dkt. 145.
`
`This morning, the Patent Trial and Appeal Board (“PTAB”) entered a decision
`
`denying institution of inter partes review against one of the Asserted Patents: U.S.
`
`Pat. No. 10,833,908 (“the ’908 Patent”). See Volkswagen Grp. of Am, Inc. v. Neo
`
`Wireless LLC, IPR2023-00086, Paper 7 (PTAB June 16, 2023). In it, the PTAB
`
`concluded that there was not “a reasonable likelihood that Petitioner would prevail
`
`in any of its challenges to claims 1–30 of the ’908 patent.” Id. at 35. Prior to this
`
`decision, Defendants Ford and Honda had also both filed petitions seeking
`
`cancellation of the same claims on the same grounds and seeking to join IPR2023-
`
`00086. See Ford Motor Co. v. Neo Wireless, LLC, IPR 2023-00765, Paper 3 at 2
`
`(PTAB Mar. 28, 2023); Am. Honda Motor Co. v. Neo Wireless, LLC, IPR2023-
`
`00794, Paper 2 at 1. These proceedings were all a basis of Defendants’ Motion to
`
`Stay. See Dkt. 145 at 2, 9–10, 14. The PTAB’s decision denying institution in
`
`IPR2023-0086 is attached as Exhibit A to this Notice.
`
`
`
`
`
`Case 2:22-md-03034-TGB ECF No. 153, PageID.10749 Filed 06/16/23 Page 3 of 3
`
`DATED: June 16, 2023
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`/s/ Christopher S. Stewart
`Jason D. Cassady
`Texas State Bar No. 24045625
`Email: jcassady@caldwellcc.com
`Christopher S. Stewart
`Texas State Bar No. 24079399
`Email: cstewart@caldwellcc.com
`CALDWELL CASSADY CURRY
`P.C.
`2121 N. Pearl St., Suite 1200
`Dallas, Texas 75201
`Telephone: (214) 888-4848
`Facsimile: (214) 888-4849
`
`Jaye Quadrozzi (P71646)
`YOUNG, GARCIA &
`QUADROZZI, PC
`2775 Stansbury Blvd., Suite 125
`Farmington Hills, MI 48334
`Telephone: (248) 353-8620
`Email: quadrozzi@youngpc.com
`
`ATTORNEYS FOR PLAINTIFF
`NEO WIRELESS, LLC
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on June 16, 2023, the foregoing document was
`
`
`
`
`
`
`filed electronically with the Clerk of Court using the CM/ECF system, which will
`
`send notification of such filing to all attorneys of record.
`
`/s/ Christopher S. Stewart
`Christopher S. Stewart
`
`
`
`
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