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`Exhibit B
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`Case 2:22-md-03034-TGB ECF No. 188-6, PageID.11347 Filed 10/11/23 Page 2 of 9
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`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
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`IN THE UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
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`In Re: Neo Wireless, LLC
`Patent Litigation
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` No. 2:22-md-03034-TGB
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` Hon. Terrence G. Berg
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` JURY TRIAL DEMANDED
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`PLAINTIFF NEO WIRELESS LLC’S THIRD SUPPLEMENTAL
`RESPONSES AND OBJECTIONS TO DEFENDANTS’ FIRST SET OF
`COMMON INTERROGATORIES (NO. 2)
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`Pursuant to Rules 26 & 34 of the Federal Rules of Civil Procedure and the
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`Local Rules of the United States District Court for the Eastern District of Michigan,
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`Plaintiff Neo Wireless LLC serves the following third supplemental responses and
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`objections to Defendants Volkswagen Group of America Inc., Volkswagen Group
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`of America Chattanooga Operations, LLC, Nissan North America Inc., Nissan
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`Motor Acceptance Corporation, American Honda Motor Co., Inc., Honda
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`Development & Manufacturing of America, LLC, Ford Motor Company, Toyota
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`Motor North America, Inc., Toyota Motor Sales USA, Inc., Toyota Motor
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`Engineering & Manufacturing North America, Inc., Tesla, Inc., Mercedes-Benz
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`USA, LLC, and General Motors (collectively “Defendants”)’ First Set of Common
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`Interrogatories (Nos. 1–7) dated August 10, 2022.
`1
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`Case 2:22-md-03034-TGB ECF No. 188-6, PageID.11348 Filed 10/11/23 Page 3 of 9
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`THIRD SUPPLEMENTAL RESPONSE:
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`Subject to and without waiving the foregoing specific and general objections,
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`and subject to the non-waiver agreements set forth in the Discovery/Protective
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`Orders in the case and the Parties’ August 23rd and September 8th email exchanges,
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`Plaintiff provides the following Third Supplemental Response:
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`For further detail on
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`which will be produced when Defendants follow the required ESI procedures set
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`forth in the Parties’ agreed Discovery Plan.
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`As previously stated,
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`Case 2:22-md-03034-TGB ECF No. 188-6, PageID.11349 Filed 10/11/23 Page 4 of 9
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`Case 2:22-md-03034-TGB ECF No. 188-6, PageID.11350 Filed 10/11/23 Page 5 of 9
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`Case 2:22-md-03034-TGB ECF No. 188-6, PageID.11351 Filed 10/11/23 Page 6 of 9
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`The above estimates did not
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`The draft
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`Case 2:22-md-03034-TGB ECF No. 188-6, PageID.11352 Filed 10/11/23 Page 7 of 9
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`Nonetheless, given the early stage of this litigation, the limited resources
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`expended to that point and the potential cost savings going forward, the potential for
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`significant additional value in the form of litigation expense reimbursements, and
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`the fact that
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`approval.
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`Case 2:22-md-03034-TGB ECF No. 188-6, PageID.11353 Filed 10/11/23 Page 8 of 9
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`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
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`DATED: September 27, 2023
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`Respectfully submitted,
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`/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
`Daniel R. Pearson
`Texas State Bar No. 24070398
`Email: dpearson@caldwellcc.com
`Bailey A. Blaies
`Texas State Bar No. 24109297
`Email: bblaies@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)
`Email: quadrozzi@youngpc.com
`YOUNG, GARCIA &
`QUADROZZI, PC
`2775 Stansbury Blvd., Suite 125
`Farmington Hills, Michigan 48334
`Telephone: (248) 353-8620
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`ATTORNEYS FOR PLAINTIFF
`NEO WIRELESS LLC
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`Case 2:22-md-03034-TGB ECF No. 188-6, PageID.11354 Filed 10/11/23 Page 9 of 9
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`CERTIFICATE OF SERVICE
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`I certify that counsel of record is being served with a copy of the foregoing
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`document via electronic mail on September 27, 2023.
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`/s/ Jason D. Cassady
`Jason D. Cassady
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