Case 2:22-md-03034-TGB ECF No. 248-1, PageID.13645 Filed 06/20/24 Page 1 of 4
`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
`
`
`
`
`
`
`
`IN RE: NEO WIRELESS, LLC,
`PATENT LITIGATION
`
`
`
`
`
`
`
`
`
`Case No. 2:22-MD-03034-TGB
`HON. TERRENCE G. BERG
`
`JURY TRIAL DEMANDED
`
`
`INDEX OF DOCUMENTS PROPOSED FOR SEALING
`
`Pursuant to L.R. 5.3(b)(3)(A)(i), Defendants provide the following index of
`
`documents proposed for sealing. No party objects to the request to seal any of the
`
`listed documents. In the document description field, any confidentiality
`
`designation under the Protective Orders in this case (D.I.s 125, 126, 210) is also
`
`noted. Additionally, the parties to this action, along with third-parties, have an
`
`interest in maintaining the documents under seal, as detailed in the chart below.
`
`
`Brief
`
`Document Description
`Defendants’ Brief in Support of Its
`Motion to Exclude the Opinions of
`Neo’s Damages Expert, Ms. Harvey,
`and Certain Opinions of Neo’s
`Technical Experts, Dr. Mahon and
`Mr. Jones
`[contains citations to documents
`listed below, which are all
`designated under the Protective
`Order in this case]
`
`Privacy Interests
`Plaintiff’s and third parties’
`interests related to business
`decisions and licensing
`practices; third parties related
`to technical information and
`source code
`
`
`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
`
`
`
`
`
`
`
`IN RE: NEO WIRELESS, LLC,
`PATENT LITIGATION
`
`
`
`
`
`
`
`
`
`Case No. 2:22-MD-03034-TGB
`HON. TERRENCE G. BERG
`
`JURY TRIAL DEMANDED
`
`
`INDEX OF DOCUMENTS PROPOSED FOR SEALING
`
`Pursuant to L.R. 5.3(b)(3)(A)(i), Defendants provide the following index of
`
`documents proposed for sealing. No party objects to the request to seal any of the
`
`listed documents. In the document description field, any confidentiality
`
`designation under the Protective Orders in this case (D.I.s 125, 126, 210) is also
`
`noted. Additionally, the parties to this action, along with third-parties, have an
`
`interest in maintaining the documents under seal, as detailed in the chart below.
`
`
`Brief
`
`Document Description
`Defendants’ Brief in Support of Its
`Motion to Exclude the Opinions of
`Neo’s Damages Expert, Ms. Harvey,
`and Certain Opinions of Neo’s
`Technical Experts, Dr. Mahon and
`Mr. Jones
`[contains citations to documents
`listed below, which are all
`designated under the Protective
`Order in this case]
`
`Privacy Interests
`Plaintiff’s and third parties’
`interests related to business
`decisions and licensing
`practices; third parties related
`to technical information and
`source code
`
`
`
`Case 2:22-md-03034-TGB ECF No. 248-1, PageID.13646 Filed 06/20/24 Page 2 of 4
`
`Document Description
`
`Exhibit A Settlement Agreement, produced as
`NEO-AUTO_0113775
`[designated Confidential]
`
`Exhibit B Settlement and License Agreement,
`produced as NEO-AUTO_0092635
`[designated Highly Confidential-
`Attorneys’ Eyes Only]
`Exhibit C Excerpts of Elizabeth Dean Rebuttal
`Report, dated Apr. 25, 2024
`[designated Highly Confidential-
`Attorneys’ Eyes Only]
`Exhibit D Patent License and Settlement
`Agreement, produced as NEO-
`AUTO 0093055
`[designated Highly Confidential-
`Attorneys’ Eyes Only]
`Exhibit E Patent License and Settlement
`Agreement, produced as NEO-
`AUTO_0094028
`[designated Highly Confidential-
`Attorneys’ Eyes Only]
`Exhibit F Patent License and Settlement
`Agreement, produced as NEO-
`AUTO_0104908
`[designated Highly Confidential-
`Attorneys’ Eyes Only]
`Exhibit G Bonnie Harvey Expert Report, dated
`Mar. 28, 2024
`[designated Highly Confidential-
`Attorneys’ Eyes Only]
`Exhibit H Excerpts of Deposition Transcript of
`Bonnie Harvey, dated May 21, 2024
`[designated Highly Confidential-
`Attorneys’ Eyes Only]
`
`Privacy Interests
`Plaintiff and third party’s
`interest related to business
`decisions and licensing
`practices
`Plaintiff and third party’s
`interest related to business
`decisions and licensing
`practices
`Plaintiff and third parties’
`interest related to business
`decisions and licensing
`practices
`Plaintiff and third party’s
`interest related to business
`decisions and licensing
`practices
`
`Plaintiff and third party’s
`interest related to business
`decisions and licensing
`practices
`
`Plaintiff and third party’s
`interest related to business
`decisions and licensing
`practices
`
`Plaintiff and third parties’
`interest related to business
`decisions and licensing
`practices
`Plaintiff and third parties’
`interest related to business
`decisions and licensing
`practices
`
`
`
`2
`
`
`
`Case 2:22-md-03034-TGB ECF No. 248-1, PageID.13647 Filed 06/20/24 Page 3 of 4
`
`Privacy Interests
`Defendant GM and third
`party’s interest related to
`business decisions and
`licensing practices
`
`Plaintiff’s interest related to
`business decisions and
`licensing practices
`
`Plaintiff’s, Defendants’, and
`third parties’ interest related
`to commercial practices,
`business decisions, and
`licensing practices
`
`Defendants’ and third parties’
`interests related to technical
`information and source code
`
`Defendants’ and third parties’
`interests related to technical
`information and source code
`
`Defendants’ and third parties’
`interests related to technical
`information and source code
`
`Document Description
`
`Exhibit J Excerpts of Avanci 2G, 3G & 4G
`SEP Landscape, produced as
`AVANCI_INRENEO000097
`[designated Highly Confidential-
`Attorneys’ Eyes Only]
`Exhibit L Neo Wireless Licensing
`Presentation, produced as NEO-
`AUTO_0104883
`[designated Highly Confidential-
`Attorneys’ Eyes Only]
`Exhibit N Excerpts of Bonnie Harvey Expert
`Report Automaker Appendices
`N.1 – FCA Appendix
`N.2 – GM Appendix
`N.3 – Honda Appendix
`N.4 – Nissan Appendix
`N.5 – Tesla Appendix
`N.6 – Toyota Appendix
`[all designated Highly Confidential-
`Attorneys’ Eyes Only]
`Exhibit P Mark Mahon Opening Expert
`Report, Appendix I: Source Code
`[designated Highly Confidential-
`Attorneys’ Eyes Only; designated
`Outside Attorneys’ Eyes Only –
`Source Code]
`Exhibit Q Excerpts of Deposition Transcript of
`Mark Mahon, dated May 16-17,
`2024
`[designated Confidential-Attorneys’
`Eyes Only]
`Exhibit R Nigel Jones Expert Report,
`Appendix A
`[designated Highly Confidential-
`Attorneys’ Eyes Only; designated
`Outside Attorneys’ Eyes Only –
`Source Code]
`
`
`
`3
`
`
`
`Case 2:22-md-03034-TGB ECF No. 248-1, PageID.13648 Filed 06/20/24 Page 4 of 4
`
`Privacy Interests
`Defendants’ and third parties’
`interests related to technical
`information and source code
`
`Defendants’ and third parties’
`interests related to technical
`information and source code
`
`Defendant Tesla and third
`parties’ interests related to
`technical information and
`source code
`
`Defendants’ and third parties’
`interests related to technical
`information and source code
`
`Defendants’ and third parties’
`interests related to technical
`information and source code
`
`Document Description
`
`Exhibit S Mark Mahon Opening Expert
`Report, Appendix F: LTE Vehicles,
`Components, and Source Code, and
`Excerpts of Appendix 1, 2, and 3
`[designated Highly Confidential-
`Attorneys’ Eyes Only; designated
`Outside Attorneys’ Eyes Only –
`Source Code]
`Exhibit T Mark Mahon Opening Expert
`Report, Appendix E: Accused
`Products
`[designated Restricted – Attorneys’
`Eyes Only]
`Exhibit U Nigel Jones Expert Report, Tesla
`Supplement
`[designated Highly Confidential-
`Attorneys’ Eyes Only; designated
`Outside Counsel Restricted – Source
`Code]
`Exhibit V Excerpts of Deposition Transcript of
`Nigel Jones, dated May 3, 2024
`[designated Highly Confidential-
`Attorneys’ Eyes Only; designated
`Outside Attorneys’ Eyes Only –
`Source Code]
`Exhibit X Mark Mahon Opening Expert
`Report, Tesla Appendix I: Source
`Code
`[designated Highly Confidential-
`Attorneys’ Eyes Only; designated
`Outside Attorneys’ Eyes Only –
`Source Code; designated Outside
`Counsel Restricted – Source Code]
`
`
`
`
`
`4
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`
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