Neo Wireless, LLC v. FCA US, LLC

I'll research this case thoroughly across the sources you mentioned.

Let me dig deeper into the parties, the patent, and the latest procedural developments.

Let me check the latest developments, including the MDL outcome, IPR results, and whether FCA's case settled.

Case Overview & Background — Neo Wireless, LLC v. FCA US, LLC, No. 2:22-cv-11770-TGB (E.D. Mich.)

The parties. Plaintiff Neo Wireless, LLC is a Delaware corporation with its principal place of business in Wayne, Pennsylvania (Compl. ¶1, N.D. Ohio 3:22-cv-01252, Dkt. 1, docketalarm link). It does not make or sell products; it is a non-practicing patent-assertion entity whose portfolio traces to Neocific, Inc. (Bellevue, WA), a wireless start-up whose inventors — Xiaodong Li, Titus Lo, Kemin Li, and Haiming Huang — filed the underlying 2004–2007-era OFDMA applications. The asserted patents moved through a chain of title from the inventors → Waltical Solutions, Inc. → Neocific, Inc. → CFIP NCF LLC (Nov. 22, 2019) → Neo Wireless LLC (Jan. 23, 2020) (Compl. ¶¶16, 22, 25; see also RPX Insight, June 15, 2024). Funding/ownership is a point of contention: RPX describes Neo as a Fortress Investment Group LLC plaintiff, while Unified Patents' Patroll bounty page for the '512 patent calls Neo "a Softbank entity" (Unified Patents Patroll, US-10965512-B2) — not contradictory in substance (SoftBank acquired Fortress in 2017), but I could not confirm the exact upstream ownership from a primary filing beyond Neo's own corporate disclosure statement identifying CFIP NCF Holdings LLC as its corporate parent (N.D. Ohio Dkt. 3). Defendant FCA US LLC is the Auburn Hills, Michigan-based Stellantis North America automaker; in its answer it admitted operating the Toledo Assembly Complex (3.64M sq. ft. over 312 acres) and assembling vehicles there (FCA First Amended Answer, MDL Dkt. 107, link).

The accused technology. Neo's theory is standard-based, not product-based: FCA's vehicles are accused because they implement 3GPP 4G/LTE and/or 5G/NR functionality (Releases 8–17), and Neo contends that practicing the mandatory/covered portions of those standards necessarily practices the claims. The accused instrumentalities are connected-car telematics and infotainment features — remote lock/unlock, remote start, parked-vehicle location, remote fuel-level checks, automatic collision notification, roadside assistance, and Wi-Fi hotspot (JPML Transfer Order, MDL No. 3034, link). The complaint asserted six patents, each a different slice of early OFDMA/LTE physical- and MAC-layer design: the '366 patent (U.S. 8,467,366, "Random Access in Multi-Carrier Communication Systems" — ranging/random-access signaling); the '908 patent (U.S. 10,833,908, "Channel Probing Signal for a Broadband Communication System" — a spread-spectrum probing signal overlaid on OFDM data); the '941 patent (U.S. 10,075,941, "Multi-Carrier Communications With Adaptive Transmission and Feedback" — link adaptation); the '450 patent (U.S. 10,447,450, "Multi-Carrier Packet Communication with Reduced Overhead" — grouping traffic into time-frequency "zones" to cut control overhead); the '302 patent (U.S. 10,771,302 — a sibling channel-probing patent); and the '512 patent (U.S. 10,965,512, "Using Cell-Specific and Common Pilot Subcarriers in Multi-Carrier, Multi-Cell Wireless Communication Networks" — a dual pilot structure where cell-specific pilots carry cell-unique information and common pilots carry network-wide information) (Compl. ¶¶15–30; Ex Parte complaint analysis). Note and flag: the case metadata for this matter lists only the '512 patent as "at issue," whereas the operative complaint pleaded all six. I could not locate an order formally narrowing the FCA case to the '512, and the defendants' later joint summary-judgment motion targeted four other patents ('941, '450, '302, '908) — so the metadata and the docket do not fully line up, and this discrepancy should be verified against the live docket before being relied on.

Procedural posture and why this venue matters. Neo filed against FCA on July 15, 2022 in the N.D. Ohio (Western Division at Toledo), No. 3:22-cv-01252, before Judge Jack Zouhary (N.D. Ohio docket). On August 1, 2022, the JPML issued Conditional Transfer Order 1 in In re Neo Wireless, LLC, Patent Litigation, MDL No. 3034, and the case was opened in the Eastern District of Michigan on August 2, 2022 as 2:22-cv-11770-TGB, assigned to Judge Terrence G. Berg (reported as Chief Judge) in the Detroit/Southern Division. The JPML chose E.D. Mich. over Neo's requested E.D. Tex. because two automaker defendants are headquartered there and Detroit is convenient — over Neo's forum-shopping objection (MDL 3034 Transfer Order/download-documents?artifactId=nJ8Hl084L-

I'll research this case systematically, starting with the core docket and MDL context.

Let me dig into the MDL-wide rulings and the FCA-specific track, plus the IPR proceedings.

Now let me find the FCA-specific disposition, the inequitable conduct proceedings, the summary judgment ruling, and current status.

I hit my research step limit, so the following synthesis is based on the sources I retrieved (primarily PACER/docket-alarm reproductions of the MDL filings, PTAB filings, Law360 docket summaries, and the Justia dockets for the Ohio original case). I flag below where the record is thin and where I could not confirm an FCA-specific fact.

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Neo Wireless, LLC v. FCA US, LLC — Key Legal Developments

Important framing caveat

FCA's case is not litigated as a standalone action. It was swept into In re Neo Wireless, LLC Patent Litigation, MDL No. 3034, No. 2:22-md-03034-TGB (E.D. Mich.), before Judge Terrence G. Berg. Nearly every substantive development — claim construction, the stay motion, summary judgment, the '512 dismissal — is an MDL-wide order that "relates to all cases," including 2:22-cv-11770-TGB. FCA is expressly named as a party in those MDL filings (e.g., the stay motion and the MSJ list FCA US LLC among the co-movants). Also note: the case metadata lists only U.S. Pat. No. 10,965,512 as "the patent at issue," but the complaint in fact asserted six patents ('366, '908, '941, '450, '512, '302), and the '512 patent was dismissed with prejudice early in 2024. That discrepancy matters for the disposition analysis below.

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1. Filing & initial pleadings

The MDL transfer order (JPML, MDL 3034) records that Neo sought centralization in E.D. Texas but the Panel chose E.D. Michigan (two defendants headquartered there; Detroit convenient), and expressly reasoned that a single judge construing the shared patents would promote consistency. This is the origin of the FCA case's venue.

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2. Pre-trial motions of substance

a) Motion to transfer / stay (MDL-wide)

There was no separate FCA motion to dismiss. The key threshold motion was the Defendants' Joint Motion to Stay Pending IPR (MDL ECF No. 145), filed ~May 2023.

• 2023-06-07 — Neo's opposition (ECF No. 148).
• 2023-06-13 — Defendants' reply (ECF No. 149).
• 2024-02-20 — Opinion and Order DENYING the joint motion to stay (Judge Berg). The court held: (1) the advanced stage (fact discovery complete or near-complete; claim construction done; expert reports due 2024-03-11) disfavored a stay; (2) a stay would unduly prejudice Neo, characterizing Defendants' staggered IPR/reexam filings as a tactical bid for maximum delay; and (3) a stay would not simplify the issues. In re Neo Wireless, LLC Patent Litig., No. 2:22-md-03034-TGB (E.D. Mich. Feb. 20, 2024); Law360, "Auto Giants Can't Pause Neo Tech Patent MDL" (Feb. 21, 2024).

b) Summary judgment (MDL-wide, FCA is a co-movant)

• 2024-06-14 — Rule 7.1(a) meet-and-confer; Neo did not concur.
• ~2024-06/07 — Defendants' Motion for Summary Judgment brought by Ford, GM, Tesla, Nissan, FCA, Toyota, and Honda, on three grounds: (1) no infringement of the '941, '450, '302, and '908 patents (LTE standard lacks limitations as construed, including the "DSSS" and "assigned by" limitations); (2) no pre-suit damages for failure to mark under 35 U.S.C. §287(a); and (3) no willful infringement. (Reproduced as Exhibit 2033 in IPR2023-00763.)
• 2024-07-18 — Neo's opposition filed under seal (MDL ECF No. 265-1), arguing infringement literally and under the doctrine of equivalents and disputing the marking/willfulness theories.

I did not retrieve the court's ruling on the MSJ. Given the later 2025 activity (inequitable-conduct proceedings and PTAB final decisions), the MSJ was apparently still pending or resolved without a public dispositive opinion during the window I could access. Treat the MSJ outcome as unconfirmed.

c) Discovery

• Fact discovery deadline was 2024-02-12; expert reports were due to be exchanged beginning 2024-03-11 (Jan. 25, 2024 Text Order granting ECF No. 220-1). The stay opinion describes fact discovery as complete or near-complete. Third-party discovery (prior-art authors/assignees) was contemplated. These are the only discovery milestones with strategic significance that I could confirm.

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3. Claim construction (Markman)

This is the most significant substantive ruling in the MDL and applies to FCA's case.

I'll research Neo Wireless's counsel of record across the MDL and this member case.

Let me pin down the actual appearances in the FCA case and the identity of the local/Ohio counsel.

Let me verify the specific E.D. Mich. appearances for Neo Wireless and check for any later counsel changes.

Plaintiff's Counsel of Record — Neo Wireless, LLC

Sourcing caveat up front: I could not pull the live PACER docket for 2:22-cv-11770-TGB directly. The names below are taken from (a) the MDL master docket sheet for 2:22-md-03034-TGB and Neo's own signature blocks on MDL filings, (b) the N.D. Ohio originating docket for 3:22-cv-01252, (c) the Nov. 27, 2023 status-conference transcript, and (d) firm websites. Individual counsel listings can lag; entries sealed or filed under a party's name only would not appear in these sources.

Core team — Caldwell Cassady & Curry P.C. (Dallas, TX) — lead counsel

These four are listed as "ATTORNEY TO BE NOTICED" on the Neo Wireless docket entry in the MDL master docket sheet (2:22-md-03034-TGB) and sign Neo's substantive filings in the MDL, including the Jan. 18, 2023 Joint Claim Construction Statement:

Caldwell Cassady's own case description confirms the engagement: "Caldwell Cassady & Curry represents Neo Wireless in multidistrict litigation pending before the U.S. District Court for the Eastern District of Michigan… infringement claims against automakers Tesla, General Motors, Toyota, Ford, Honda, Fiat Chrysler, Volkswagen, Mercedes Benz, and Nissan" (caldwellcc.com). Chambers USA likewise records that the firm "acted as lead trial counsel for Neo Wireless in the company's consolidated patent infringement lawsuit against several car manufacturers."

Local counsel — Young, Garcia & Quadrozzi, P.C. (Farmington Hills, MI)

• Jaye Quadrozzi (Mich. Bar No. P71646) — local counsel (E.D. Mich.). Young, Garcia & Quadrozzi, PC, 2775 Stansbury Blvd., Suite 125, Farmington Hills, MI 48334; quadrozzi@youngpc.com. She entered a Notice of Appearance in the MDL on Neo's behalf (docket entry #16 in the consolidated docket) and appears on Neo's signature block as Michigan counsel. Stewart identified her on the record as "our local counsel" at the Nov. 27, 2023 status conference.

Pre-transfer filing counsel (N.D. Ohio, now likely superseded)

• Howard L. Wernow — the only plaintiff's attorney listed on the originating N.D. Ohio docket for Neo Wireless, LLC v. FCA US, LLC, No. 3:22-cv-01252 (Judge Jack Zouhary). He filed the July 15, 2022 complaint, the Rule 7.1 corporate disclosure statement, the AO-120 report, and the June 19, 2022 return of service, and is the contact of record on that docket (Justia docket). He practices at Sand, Sebolt & Wernow Co., LPA, 4940 Munson St. NW, Aegis Tower Suite 100, Canton, Ohio 44718. Flag: I did not find a Notice of Appearance by Wernow on the E.D. Mich. MDL docket, and the MDL filings are signed by Caldwell Cassady, not by him — so it appears the case was re-teamed to Caldwell Cassady as lead with Young Garcia & Quadrozzi as local counsel after the MDL transfer. Whether Wernow was formally withdrawn in 2:22-cv-11770 should be verified against PACER. (For completeness: Wernow is the subject of a public USPTO OED final order, D2025-08, concerning his firm's handling of an IP Edge/Mavexar-funded client, Mellaconic — unrelated to Neo Wireless, but worth knowing if his status matters to the record. I'd treat that as a separate matter and confirm before relying on it.)

Related Neo Wireless patent counsel (different forum — not counsel in this case)

• Lowenstein & Weatherwax LLP (Kenneth Weatherwax, Parham Hendifar) obtained reexamination confirmations for Neo on U.S. 10,833,908 and 9,948,488 (L&W press release, Feb. 25, 2025). This is USPTO ex parte reexamination work, not an appearance in 2:22-cv-11770.
• Matthew J. Moore / Michael A. David / Benjamin L. Smith (Latham & Watkins), Fish & Richardson, and Honigman LLP appear in the same MDL signature blocks, but they represent defendants (Latham = General Motors; Fish = Ford and Nissan; Honigman = local Michigan counsel for defense parties). Contradiction flag: several AI/OCR-derived document excerpts conflate these names under the heading "Attorneys for Plaintiff NEO WIRELESS, LLC." That is an artifact of two-column OCR merging; the underlying Joint Claim Construction Statement and MDL docket sheet show Latham/Fish/Honigman on the defense side. Do not carry those names forward as plaintiff's counsel.

No in-house counsel identified

Neo Wireless is a non-practicing entity with a small corporate footprint in Wayne, Pennsylvania; I found no corporate/GC attorney appearing on the docket for Neo in this matter.

Bottom line for this case

• Lead: Jason D. Cassady and Christopher S. Stewart, Caldwell Cassady & Curry P.C. (Dallas), with Daniel R. Pearson and Bailey A. Blaies on the team.
• Local (E.D. Mich.): Jaye Quadrozzi, Young, Garcia & Quadrozzi, P.C. (Farmington Hills).
• Originating (N.D. Ohio, 3:22-cv-01252 only): Howard L. Wernow, Sand, Sebolt & Wernow (Canton, Ohio) — confirm current status on PACER.
• Verification gap: the most recent substantive plaintiff-side appearances I could date are from the Jan. 2023 claim-construction statement and the Nov. 2023 status conference. If you need current-through-2026 counsel, run a PACER docket pull on 2:22-cv-11770-TGB and on 2:22-md-03034-TGB for any withdrawals, substitutions, or new Notices of Appearance filed after November 2023.

I'll research the defense counsel of record for FCA US, LLC in this matter.

Let me dig deeper into the FCA-specific filings and signature blocks.

Let me verify the FCA-specific filings and check for any later counsel changes.

I hit my research-step limit mid-verification, so here is what the record I retrieved supports — with the ambiguities flagged rather than smoothed over.

Defense counsel of record — FCA US, LLC

Primary / lead counsel: Venable LLP (Washington, DC)

Venable LLP is the firm that entered the operative appearances for FCA US in this member case. Three separate appearance filings were made on September 12, 2022 — the same day FCA filed its Answer — each expressly reciting representation of "Defendant FCA US LLC" under the caption Case No. 2:22-cv-11770-TGB: