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Neo Wireless, LLC v. American Honda Motor Co., Inc. et al

Docket 2:22-cv-11403, Michigan Eastern District Court (June 27, 2022)
District Judge Terrence G. Berg, presiding
Patent
DivisionDetroit
Cause15:1126 Patent Infringement
Case Type830 Patent
Tags830 Patent, 830 Patent
Patent10075941; 10447450; 10771302; 10833908; 10965512; 8467366, 10075941, 10447450, 10771302, 10833908, 10965512, 8467366
Plaintiff Neo Wireless, LLC
Defendant American Honda Motor Co Inc
Defendant Honda Development & Manufacturing of America, LLC
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No. 4 AMENDED COMPLAINT with Jury Demand filed by Neo Wireless, LLC against American Honda Motor ...

Document Neo Wireless, LLC v. American Honda Motor Co., Inc. et al, 2:22-cv-11403, No. 4 (E.D.Mich. Jul. 20, 2022)
Complaint
Additionally, the communications between Honda’s Accused Products and the serving base station include a multitude of signals back and forth in normal operation, such as when establishing connections, sending and receiving control information, sending and receiving reference signaling, communicating data in the uplink and downlink, obtaining network parameters, etc. And Honda’s Accused Products do this across a potentially large range of time and locations, including across a variety of base station equipment and configurations and/or Case 2:22-cv-11403-TGB ECF No. 4, PageID.20 Filed 07/20/22 Page 14 of 39 wireless conditions.
Each Honda entity, directly or by controlling the activities of its subsidiaries, makes, sells, offers for sale, uses, and imports the Accused Products Case 2:22-cv-11403-TGB ECF No. 4, PageID.22 Filed 07/20/22 Page 16 of 39 in the United States.
Further, industry experts consulted by Neo have confirmed that, based on their experience with and knowledge of the 3GPP standards and their implementation, the Accused Products Case 2:22-cv-11403-TGB ECF No. 4, PageID.28 Filed 07/20/22 Page 22 of 39 are configured to practice the covered functionality when they provide LTE connectivity.
Further, industry experts consulted by Neo have confirmed that, based on their experience with and knowledge of the 3GPP standards and their implementation, the Accused Products are configured to practice the covered functionality when they provide LTE connectivity.
Further, industry experts consulted by Neo have confirmed that, based on their experience with and knowledge of the 3GPP standards and their implementation, the Accused Products are configured to practice the covered functionality when they provide LTE connectivity.
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No. 1 TRANSFERRED COMPLAINT with JURY DEMAND against American Honda Motor Co., Inc., Honda Development ...

Document Neo Wireless, LLC v. American Honda Motor Co., Inc. et al, 2:22-cv-11403, No. 1 (E.D.Mich. Mar. 29, 2022)
Case 2:22-cv-11403-TGB ECF No. 1, PageID.2 Filed 03/29/22 Page 2 of 16 registered agent, Corporation Service Company, 50 West Broad Street, Suite 1330, Columbus, Ohio 43215.
Defendants, both directly and through their subsidiaries or intermediaries (including distributors, retailers, and others), have purposefully and voluntarily placed one or more infringing products and/or services, as described below, into the stream of commerce with the
These infringing products and/or services have been and continue to be made, used, sold, offered for sale, purchased, and/or imported by customers and/or consumers in the Southern District of Ohio.
The inventors saw an opportunity to create a new wireless communication system meant to address those flaws while incorporating cutting-edge Orthogonal Frequency-Division Multiple Access (OFDMA) based technologies, and, starting in the 2004-2005 timeframe, they filed patents on the work.
Similarly, Honda’s advertising, sales, design, development, and/or technical materials related to the 3GPP LTE/4G and/or 5G/NR standards associated with the Accused Products contained and continue to contain instructions, directions, suggestions, and/or invitations Case 2:22-cv-11403-TGB ECF No. 1, PageID.11 Filed 03/29/22 Page 11 of 16 that invite, entice, lead on, influence, encourage, prevail on, move by persuasion, and/or cause its subsidiaries, distributors, retailers, dealerships, customers, and the public to directly infringe at least one claim of each of the Patents-in-Suit, either literally or under the doctrine of equivalents.
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No. 1-7

Document Neo Wireless, LLC v. American Honda Motor Co., Inc. et al, 2:22-cv-11403, No. 1-7 (E.D.Mich. Mar. 29, 2022)

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No. 1-9

Document Neo Wireless, LLC v. American Honda Motor Co., Inc. et al, 2:22-cv-11403, No. 1-9 (E.D.Mich. Mar. 29, 2022)

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No. 1-12

Document Neo Wireless, LLC v. American Honda Motor Co., Inc. et al, 2:22-cv-11403, No. 1-12 (E.D.Mich. Mar. 29, 2022)

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No. 1-11

Document Neo Wireless, LLC v. American Honda Motor Co., Inc. et al, 2:22-cv-11403, No. 1-11 (E.D.Mich. Mar. 29, 2022)

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No. 1-10

Document Neo Wireless, LLC v. American Honda Motor Co., Inc. et al, 2:22-cv-11403, No. 1-10 (E.D.Mich. Mar. 29, 2022)

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