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Neo Wireless LLC v. Tesla Inc.

Docket 2:22-cv-11408, Michigan Eastern District Court (June 28, 2022)
District Judge Terrence G. Berg, presiding
Patent
DivisionDetroit
Cause35:271 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 Tesla Inc.
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No. 15 NOTICE of Appearance by Sarika Patel on behalf of Tesla Inc

Document Neo Wireless LLC v. Tesla Inc., 2:22-cv-11408, No. 15 (E.D.Mich. Oct. 5, 2023)
PLEASE TAKE NOTICE that Sarika N. Patel of the law firm of Fish & Richardson P.C. hereby enters her appearance as counsel on behalf of Defendant Tesla Inc. in the above-entitled matter.
Dated: October 5, 2023 Respectfully submitted, By:
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No. 14 AMENDED ANSWER to Complaint with Affirmative Defenses by Tesla Inc

Document Neo Wireless LLC v. Tesla Inc., 2:22-cv-11408, No. 14 (E.D.Mich. Dec. 16, 2022)
Answer
Upon information and belief, the named inventors of the Asserted Patents (Xiaodong Li, Titus Lo, Ruifeng Wang, Kemin Li, and Haiming Huang) were formerly employed by AT&T (or a subsidiary of AT&T) and/or Broadstorm Telecommunications, Inc. (“Broadstorm”).
In the mid to late 1990s, AT&T further developed Project Angel—a wireless system incorporating orthogonal frequency-division multiple access (“OFDMA”) technology that used a base station and remote units to communicate data through
Upon information and belief, Xiaodong Li “proposed to strategically hire key Project Angel engineers from AT&T.” See Order Denying Summary Judgment, Adaptix, Inc. v. Apple, Inc. et al, Civ.
Upon information and belief, Plaintiff Neo Wireless has previously operated under several names and/or identifiers, including without limitation Walbell Technologies, Inc. (“Walbell”), Waltical Solutions, Inc. (“Waltical”), CFIP NCF Holdings LLC (“CFIP), and Neocific, Inc. (“Neocific”).
Members that breach their duty to disclose “have impliedly waived [their] right to assert infringement claims against standard-compliant products.” Hynix Semiconductor Inc. v. Rambus Inc., 645 F.3d 1336, 1347-48 (Fed. Cir. 2011) (citing Qualcomm Inc. v. Broadcom Corp. (“Qualcomm II”), 548 F.3d 1004, 1022-24 (Fed. Cir. 2008)).
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No. 11 ANSWER to Amended Complaint with Affirmative Defenses with Jury Demand by Tesla Inc

Document Neo Wireless LLC v. Tesla Inc., 2:22-cv-11408, No. 11 (E.D.Mich. Aug. 24, 2022)
Answer
Tesla lacks knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 1 of the Amended Complaint, and on that basis denies them.
For example, a judicial panel in In Re Neo Wireless, LLC Patent Litigation (MDL No. 3034) ordered that this case be transferred to the Eastern District of Michigan.
Tesla admits that the face of United States Patent No. 10,833,908 (“the ’908 patent”) lists the title as “Channel Probing Signal for a Broadband Case 2:22-cv-11408-TGB ECF No. 11, PageID.354 Filed 08/24/22 Page 6 of 34
Tesla lacks knowledge or information sufficient to form a belief as to the truth of the Case 2:22-cv-11408-TGB ECF No. 11, PageID.355 Filed 08/24/22 Page 7 of 34
On information and belief, if Plaintiff is not the current or sole owner of the Asserted Patents, Plaintiff’s claims and requested relief are barred by Plaintiff’s lack of standing.
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No. 10 AMENDED COMPLAINT with Jury Demand filed by Neo Wireless, LLC against Tesla Inc

Document Neo Wireless LLC v. Tesla Inc., 2:22-cv-11408, No. 10 (E.D.Mich. Jul. 20, 2022)
Complaint
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.
Additionally, the communications between Tesla’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 Tesla’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 wireless conditions.
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 Case 2:22-cv-11408-TGB ECF No. 10, PageID.38 Filed 07/20/22 Page 21 of 38
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.
Finally, on information and belief, due to the features Tesla advertises as enabled by the 4G/LTE functionality, including but not limited to remote connectivity and Wi-Fi internet access, Tesla’s Accused Case 2:22-cv-11408-TGB ECF No. 10, PageID.50 Filed 07/20/22 Page 33 of 38
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No. 13 DISCOVERY plan jointly filed pursuant to Federal Rules of Civil Procedure 26(f) (Cassady, Jason) ...

Document Neo Wireless LLC v. Tesla Inc., 2:22-cv-11408, No. 13 (E.D.Mich. Sep. 23, 2022)
Use of narrowing search criteria (e.g., “and,” “but not,” “w/x”) is encouraged Case 2:22-cv-11408-TGB ECF No. 13, PageID.398 Filed 09/23/22 Page 13 of 32 to limit the production and shall be considered when determining whether to shift costs for disproportionate discovery.
The patentee must file and serve disclosures of and an initial document production that identifies, as specifically as possible, the following information by September 28, 2022: a. Each patent claim that is allegedly infringed by each opposing party.
Prior art under pre-AIA 35 U.S.C. § 102(g) shall be identified by providing the identities of the person(s) or entities involved in and the circumstances Case 2:22-cv-11408-TGB ECF No. 13, PageID.404 Filed 09/23/22 Page 19 of 32 surrounding the making of the invention before the patent applicant(s).
Source code, specifications, schematics, flow charts, artwork, formulas, or other documentation sufficient to show or allow third-party discovery into the operation of any aspects or elements of an Accused Instrumentality identified by the patent claimant in its infringement contentions;
Any amendment to a party’s infringement or validity contentions must be timely made Case 2:22-cv-11408-TGB ECF No. 13, PageID.406 Filed 09/23/22 Page 21 of 32 but in no event later than one month after the Court’s claim construction ruling.
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No. 12 STATEMENT of DISCLOSURE of CORPORATE AFFILIATIONS and FINANCIAL INTEREST by Tesla Inc

Document Neo Wireless LLC v. Tesla Inc., 2:22-cv-11408, No. 12 (E.D.Mich. Aug. 24, 2022)
Pursuant to Federal Rule of Civil Procedure 7.1, the undersigned counsel of record for Tesla, Inc. (“Tesla”) submits the following Corporate Disclosure Statement: Tesla states that it has no parent corporation and no publicly traded company holds 10% or more of its stock.
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No. 9

Document Neo Wireless LLC v. Tesla Inc., 2:22-cv-11408, No. 9 (E.D.Mich. Jul. 14, 2022)

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