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`Exhibit I
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`
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`Case 2:22-md-03034-TGB ECF No. 267-10, PageID.29242 Filed 07/18/24 Page 2 of 2
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`NEO-FORD_0000013
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`BROOKS
`KUSHMAN
`
`
`
`
`
`
`Brooks Kushman P.C.
`1000 Town Center, Twenty-Second Floor
`Southfield, Michigan 48075-1238 USA
`Tel (248) 358-4400 ● Fax (248) 358-3351
`
`www.BrooksKushman.com
`
`
`
`
`Ernie L. Brooks
`1942-2007
`
`February 10, 2022
`
`Via E-Mail: bmarino@neo-wireless.com
`dloo@neo-wireless.com
`
`
`Mr. Bill Marino
`Neo Wireless, LLC
`123 West Wayne Avenue, 1st Floor
`Wayne, PA 19087
`
`
`
`
`Dear Mr. Marino:
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`
`
`Re: Neo Wireless Patent Portfolio
`Our File No. FMCL0301SEP
`
`
`I am writing in response to your November 29, 2021 letter regarding Neo Wireless’
`patent portfolio. You assert that the portfolio covers specific technology areas associated with
`the LTE, LTE-5G and 5G cellular standards. As you may know, Ford Motor Company
`purchases communication modules from its Tier 1 suppliers, who in turn purchase standard-
`compliant baseband modem chipsets from Qualcomm located at 5775 Morehouse Drive in San
`Diego, CA 92121.
`
`Ford respects the valid intellectual property rights of others. But Ford, as the automotive
`OEM, neither designs nor manufactures the standard-compliant modem technology addressed in
`your letter. Ford is thus not in a position to determine the technical relevance or value of Neo
`Wireless’ patent portfolio. I encourage you to direct your licensing offer to Qualcomm, the
`entity who designed and manufactures the cellular modems included as supplied components on
`Ford vehicles.
`
`If you have any questions, please do not hesitate to contact me.
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`JSL/can
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`Very truly yours,
`
`BROOKS KUSHMAN P.C.
`
`John S. LeRoy
`
`
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