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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
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`In Re: Neo Wireless, LLC,
`Patent Litigation
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`Case No. 2:22-md-03034-TGB
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` Hon. Terrence G. Berg
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`DECLARATION OF CHRISTOPHER S. STEWART
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`I, Christopher S. Stewart, declare as follows:
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`1.
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`I am an attorney at the law firm of Caldwell Cassady Curry P.C. in
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`Dallas, Texas. I am admitted to practice in the State of Texas and this Court. I
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`submit this declaration based on personal knowledge and following a reasonable
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`investigation. If called upon as a witness, I could and would competently testify to
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`the truth of each statement herein.
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`2.
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`Attached hereto as Exhibit A is a true and correct copy of Email
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`communications between Neo and Defendants regarding MDL-wide Discovery
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`Issues sent between October 4, 2023 and October 6, 2023.
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`3.
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`Attached hereto as Exhibit B is a true and correct copy of Plaintiff
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`Neo Wireless LLC’s Third Supplemental Responses and Objections to Defendants’
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`First Set of Common Interrogatories (No 2), dated September 27, 2023.
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`4.
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`Attached hereto as Exhibit C is a true and correct copy of Avanci
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`White Paper entitled “Accelerating IoT Connectivity”.
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`1
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`Case 2:22-md-03034-TGB ECF No. 188-4, PageID.11339 Filed 10/11/23 Page 2 of 2
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`I declare under penalty of perjury under the laws of the United States of
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`America that the foregoing is true and correct to the best of my knowledge.
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`Executed in Dallas, TX, on this 11th day of October, 2023.
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`/s/ Christopher S. Stewart
`Christopher S. Stewart
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`2
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