`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
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`
`
`
`
`
`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
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`documents proposed for sealing. No party objects to the request to seal any of the
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`listed documents. In the document description field, any confidentiality
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`designation under the Protective Orders in this case (ECF Nos. 125, 126) is also
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`noted. Additionally, the parties to this action, along with third-parties, have an
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`interest in maintaining the documents under seal, as detailed in the chart below.
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`
`
`Brief
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`Document Description
`Defendants’ Opposition to
`Plaintiff’s Motion to Strike or
`Exclude Certain Portions of the
`Testimony of Defendants’ Experts
`[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. 268-1, PageID.29340 Filed 07/18/24 Page 2 of 2
`
`
`Exhibit 2
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`Exhibit 4
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`Exhibit 5
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`Exhibit 6
`
`Document Description
`Excerpts of Expert Report of Harry
`V. Bims, Ph.D., dated Mar. 28, 2024
`[designated Highly Confidential-
`Attorneys’ Eyes Only]
`Excerpts from Bonnie Harvey
`Expert Report, dated Mar. 28, 2024
`[designated Highly Confidential-
`Attorneys’ Eyes Only]
`Excerpts of Deposition Transcript of
`Bonnie Harvey, dated May 21, 2024
`[designated Highly Confidential-
`Attorneys’ Eyes Only]
`Excerpts of Deposition Transcript of
`Nigel Andrew Jones, dated May 3,
`2024 [designated Confidential -
`Subject to QualComm Supplemental
`Protective Order]
`Excerpts of Deposition Transcript of
`Andrew John Mayo, Ph.D., dated
`May 14, 2024 [designated Highly
`Confidential-Attorneys’ Eyes Only]
`Excerpts of Deposition Transcript of
`Nancy J. Linck, Ph.D., dated May
`21, 2024 [designated Highly
`Confidential-Attorneys’ Eyes Only]
`Exhibit 11 White Paper,
`ATT_NEO_P1_008909-008928
`[designated Confidential-Attorneys’
`Eyes Only]
`
`Exhibit 7
`
`Exhibit 10
`
`
`
`Privacy Interests
`Defendants’ interests related
`to technical arguments and
`information
`
`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’s and third parties’
`interests related technical
`information and source code
`
`Plaintiff’s and third parties’
`interests related technical
`information and source code
`
`Plaintiff’s and third parties’
`interests related business and
`technical information
`
`Third party’s interests related
`business and technical
`information
`
`
`
`2
`
`
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