`
`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.
`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-11770-TGB
`
`
`NOTICE OF SUPPLEMENTAL FACTS REGARDING THE STATUS OF
`INTER PARTES REVIEW PROCEEDINGS
`
`
`
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`
`
`Case 2:22-md-03034-TGB ECF No. 179, PageID.11110 Filed 09/27/23 Page 2 of 3
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`Plaintiff Neo Wireless, LLC writes to notify the Court of supplemental facts
`
`regarding the status of inter partes review proceedings that are relevant to
`
`Defendants’ Joint Motion to Stay Pending Inter Partes Review. See Dkt. 145. On
`
`September 26, 2023, 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. 8,467,366 (the “’366 patent). See Volkswagen Group of
`
`America, Inc. v. Neo Wireless LLC, IPR 2023-00426, Paper12 (PTAB Sept. 26,
`
`2023). This was a merits-based decision in which the PTAB concluded that there
`
`was not “a reasonable likelihood of prevailing on [Petitioner’s] challenge that
`
`claims 1-24 of the ’366 patent are unpatentable.” Id. at 30. This proceeding was a
`
`basis of Defendants’ Motion to Stay. See Dkt. 145 at 2, 9-10, 14. The PTAB’s
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`decision denying institution in IPR2023-00426 is attached as Exhibit A to this
`
`Notice.
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`1
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`Case 2:22-md-03034-TGB ECF No. 179, PageID.11111 Filed 09/27/23 Page 3 of 3
`
`DATED: September 27, 2023
`
`
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`
`
`
`
`
`Respectfully submitted,
`/s/ Jason D. Cassady
`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 September 27, 2023, the foregoing
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`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/ Jason D. Cassady
`Jason D. Cassady
`
`
`
`2
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