`HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
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`STATEMENT OF ISSUES PRESENTED
`1. Whether Defendants’ technical expert reports improperly use the unelected
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`references 802.16e, Koo, or 802.11 to show invalidity.
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`2. Whether the use of Neo-Avanci negotiations to resolve this litigation in
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`Defendants’ damages expert reports is more prejudicial than probative and
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`violates Federal Rules of Evidence 403, 408, and 703.
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`3. Whether portions of Dr. Mayo’s report fail to provide the facts or data
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`considered by Dr. Mayo in forming his opinions in violation of Federal Rules
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`of Civil Procedure 26(b)(2)(B).
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`4. Whether the late disclosure of data in Dr. Mayo’s errata should be excluded
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`under Rule 26(a) and in view of the Howe factors.
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`5. Whether use of inadmissible materials from a separate litigation, reliance on
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`stricken invalidity contentions, and improper factual inference and opinons on
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`intent render Defendants’ technical experts’ unenforceability opinions
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`unreliable, unsupported, and more prejudicial than probative in violation of
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`Rule 402, 403, and 703.
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`CONCURRENCE PURSUANT TO L.R. 7.1(A)
`Pursuant to L.R. 7.1(a), the parties met-and-conferred on June 14, 2024
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`
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`regarding the relief sought in this Motion. Defendants did not concur on any of the
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`relief requested herein.
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`
`
`iii
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