In re Neo Wireless, LLC, Patent Litigation

I'll research this case thoroughly before writing the overview.

Let me dig into the current posture, IPR outcomes, and Neo Wireless's corporate background.

Let me verify the current 2026 posture and the status of the '512 patent specifically.

Case Overview and Background

Parties. The plaintiff, Neo Wireless, LLC, is a non-practicing patent-holding/licensing entity, not an operating company, university, or manufacturer. Its patents were acquired in November 2019 (under its then-name, CFIP NCF LLC) from Neocific IP, a portfolio of wireless-communications assets developed by Neocific, Inc.; RPX reports that Neo Wireless is a Fortress Investment Group plaintiff, and Stanford's NPE Litigation Database classifies it as an "acquired patents" asserter (RPX Insight, June 15, 2024; Stanford NPE Database, '908). Before the automotive wave, Neo sued Apple, Dell, and LG Electronics in W.D. Tex. in early 2021; the nine automotive suits here were filed March 29, 2022 and July 15, 2022. The defendants are automaker groups: Volkswagen Group of America, Ford Motor Co., General Motors Co./GM LLC, Nissan North America/Nissan Motor Acceptance, Tesla, Inc., Toyota Motor Corp. and affiliates, American Honda Motor Co./Honda Development & Manufacturing of America, Mercedes-Benz USA, and FCA US (Stellantis). Neo's lead counsel is Caldwell Cassady & Curry (Jason D. Cassady, Christopher S. Stewart) with Young Garcia & Quadrozzi (Jaye Quadrozzi); defense teams include Fish & Richardson (Ford, Nissan), Jenner & Block (FCA), Bush Seyferth (VW, FCA), and Sterne Kessler (VW) (Law360 via Sterne Kessler, Dec. 18, 2023).

Accused technology. The accused instrumentalities are the defendants' connected-car telematics systems and the telematics control units (TCUs) inside their vehicles — for example, GM's OnStar-equipped models (Blazer, Bolt, Equinox, Sierra, Cadillac XT5, Encore) — and the infuriating features they enable: remote lock/unlock, remote start, parked-vehicle location, remote fuel-level checks, automatic collision notification, roadside assistance, stolen-vehicle tracking, in-vehicle Wi-Fi hotspots, and companion mobile apps. The core theory is standard-compliance infringement: because the patents allegedly read on fundamental aspects of the 3GPP LTE/4G and 5G/New Radio standards (Releases 8–17), any vehicle implementing those standards over compliant chipsets/modules infringes (JPML Transfer Order, MDL No. 3034, June 14, 2022; Ex Parte complaint analysis, 2:22-cv-11407). That is essentially an SEP-style damages theory, although the JPML and press describe the patents as standard-relevant rather than formally FRAND-encumbered — I did not find authoritative sourcing that Neo declared these patents essential to any standards body, so treat "SEP" characterization with caution.

Patents asserted. Six patents from the Neocific families were asserted across the MDL: U.S. 8,467,366 (multi-cell OFDMA systems; asserted claim involves transmitting a ranging signal over a ranging subchannel for random access); U.S. 10,075,941 (multicarrier systems with adaptive transmission and feedback / control signaling); U.S. 10,447,450 (reducing control signaling overhead, e.g., grouping similar traffic such as VoIP into designated time-frequency "zones"); U.S. 10,965,512 (using cell-specific and common pilot subcarriers in multi-carrier, multi-cell networks so a receiver can do channel estimation and frequency synchronization even amid neighbor-cell signals); and U.S. 10,771,302 and U.S. 10,833,908 (channel-probing signals overlaid on an OFDM data signal, enabling channel measurement/bandwidth allocation for mobiles with changing channel conditions). The patent flagged in this case's metadata, the '512 patent, was asserted on March 29, 2022

I'll research this MDL and its member cases, focusing on U.S. Patent No. 10,965,512 and the overall procedural history.

Let me dig into the specific patents (including the '512), the Markman ruling, trial, and settlements.

Good progress. Now let me find the summary judgment ruling, trial status, and remaining dispositions.

Key Legal Developments — In re Neo Wireless, LLC, Patent Litigation, No. 2:22-md-03034-TGB (E.D. Mich.)

Scope note: This chronology covers the MDL as a whole and tracks the '512 patent specifically where the record supports it. A few items you asked about (the disposition of the 2024 summary-judgment motion and any trial/verdict) were not confirmed by the public sources I could reach, and I flag them below rather than guess.

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1. Filing and initial pleadings (2022)

Neo's counsel of record includes Caldwell Cassady & Curry (Jason Cassady, Christopher Stewart), Latham & Watkins (Matthew Moore, Michael David, Benjamin Smith), Hogan Lovells (Celine Crowson, Joseph Raffetto, Damon Lewis, Scott Hughes), and Jaye Quadrozzi. Dickinson Wright (James Martone) appeared for Mercedes-Benz (2022-10-18).

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2. Claim construction (2023)

• 2023-06-21 — Markman hearing.
• 2023-11-20 — Claim Construction Memorandum and Order (ECF 198), construing fourteen terms/phrases across the six asserted patents. Two rulings were decisive:
  • "random access signal" ('908) and "probing signal" ('302) were construed to require a "direct sequence spread spectrum signal" (DSSS signal) — a narrowing construction defendants later used as the backbone of their non-infringement case.
  • The '366 phrase "low peak-to-average power ratio in the time domain" was held indefinite (a term of degree lacking objective boundaries).
• Early 2024 — Neo's motion for reconsideration of the indefiniteness ruling denied under E.D. Mich. L.R. 7.1(h)(2)(A); the Court held Neo simply re-argued rejected positions and that the examiner's reasoning was only "part of the evidence considered."

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3. Stays, claim reduction, and the '512 patent's exit (2023–2024)

• 2023-05 — Defendants move to stay the entire MDL pending the parallel IPRs (ECF 145). Neo opposes (ECF 148), accusing defendants of a "bizarre patchwork of IPR filings"; defendants reply (ECF 149, 2023-06-13).
• 2023-06-06 — Mercedes-Benz files a joint notice of settlement and request to stay (ECF 147). (Neo and MBUSA's dispute was resolved while MBUSA's own '512 IPR — IPR2023-00079 — was pending.)
• 2023-12-18 — Volkswagen agrees to settle (Law360), while continuing its PTAB validity challenges.
• 2024-01-11 — VW dismissal with prejudice (2:22-cv-11404) — all claims and counterclaims, each side bearing its own fees (Rule 41(a)(2)).
• 2024-01-22 — Joint Motion to Dismiss U.S. Patent No. 10,965,512 (ECF 219). Under the accompanying stipulation:
  • Neo dismissed the '512 patent with prejudice; defendants dropped their '512 counterclaims;
  • Neo granted a covenant not to sue (including specified foreign counterparts) on the '512 patent;
  • GM, Ford, Nissan, Tesla and Honda agreed to terminate their '512 IPRs within 7 days and never again challenge the '512 patent's validity;
  • The dismissal and stipulation could not be introduced at trial.
  • Net effect: six asserted patents → five; and the entire '512 PTAB cluster (VW's IPR2022-01539, MBUSA's IPR2023-00079, Ford's IPR2023-00764, GM's IPR2023-00961) was extinguished.
• 2024-02-20 — Judge Berg denies the motion to stay pending IPR (Law360 2024-02-21). The Court reasoned the case was past an "efficient stopping point" (claim construction done, fact discovery complete, expert reports due 2024-03-11); that a second stay would delay remand; that defendants tactically staged IPRs and ex parte reexaminations to maximize delay (including timing reexam requests after the '908 and '302 IPR institution denials); and that IPR outcomes would not simplify the remaining defenses (inequitable conduct, § 101, estoppel). The Court also noted two settlements already achieved (MBUSA 2023-06-06; another defendant 2024-01-11).
• ~2024-04 — Memorandum Opinion and Order granting Neo's motion to strike defendants' untimely prior-art elections (ECF 209) — striking the late-added "Project Angel" invalidity theory, on the grounds that defendants identified but did not chart Project Angel in their initial contentions and sprang it after the claim-reduction deadlines.

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4. Summary judgment, inequitable conduct, and expert discovery (2024–2025)

• 2024-03-11 — Expert reports begin to be exchanged.
• Mid-2024 (ECF 247) — Defendants' Motion for Summary Judgment seeking: (1) no infringement of the '941, '450, '302 and '908 patents; (2) no pre-suit damages for failure to mark under 35 U.S.C. § 287(a); and (3) no willful infringement.
• 2024-07-18 — Neo's opposition (ECF 265), arguing among other things that its LTE random access preamble meets "random access signal" and LTE SRS meets "probing signal" either literally or under the doctrine of equivalents, and that under a "rule of reason" analysis it was unreasonable to expect Neo

Caveat on sourcing

I could not query PACER directly (paywalled); the below is built from docket mirrors (Docket Alarm, UniCourt, Law360 dockets), filed documents/transcripts in the MDL, the JPML/Law360 coverage, and firm websites. Where a role or current status is not directly evidenced, I say so. The MDL docket has 300+ entries and several Neo filings are filed under seal or in redacted form (e.g., ECF 253 "REDACTED"), but counsel identifications themselves appear on the public signature blocks.

Plaintiff's counsel of record — Neo Wireless, LLC (2:22-md-03034-TGB)

Lead trial counsel — Caldwell Cassady & Curry P.C. (Dallas, TX)

Address on filings: 2121 N. Pearl St., Suite 1200, Dallas, TX 75201.

Local counsel (E.D. Mich.) — Varnum LLP, Birmingham, MI

• Jaye Quadrozzi (Mich. Bar No. P71646), Partner, Varnum LLP, 480 Pierce St., Suite 300, Birmingham, MI 48009, (248) 567-7800 — local counsel of record for Neo. She entered her appearance for Neo early in the MDL (appearance docketed at ECF 16 in the source-member case) and is the Michigan counsel named alongside Caldwell Cassady on Neo's 2024 briefs (ECF 253, 258). Firm change noted: her earlier appearances in this MDL are in the name of Young, Garcia & Quadrozzi, PC (2775 Stansbury Blvd., Suite 125, Farmington Hills, MI) — she is now at Varnum, and the later filings carry the Varnum address. Varnum's site describes her as a trial lawyer with an IP/patent focus and Federal Circuit bar admission; Crain's Detroit "Notable Litigators & Trial Attorneys" (2025).

PTAB / reexamination / appellate counsel (not district-court counsel of record)

• Kenneth J. Weatherwax and Parham Hendifar, Lowenstein & Weatherwax LLP — Neo's Patent Owner counsel in the parallel PTAB and reex

I'll research the docket and counsel appearances for this MDL.

I have substantial data. Let me fill gaps per defendant and check more recent appearances.

Let me pull the joint claim construction statement (which maps many counsel to defendants) and Nissan/Mercedes specifics.