Neo Wireless, LLC v. Tesla Inc.

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

Let me dig deeper into the '512 patent assertion, current case status, and Tesla-specific developments.

Let me check for the most recent Tesla-specific developments and MDL trial scheduling.

Case Overview and Background

The parties. Plaintiff Neo Wireless, LLC is a Delaware corporation headquartered in Wayne, Pennsylvania (Am. Compl. ¶ 1, E.D. Mich. 2:22-cv-11408, Dkt. 10). It is a non-practicing entity: the record reflects that Neo does not make, sell, or develop wireless products, and Defendants have characterized it as "backed by a litigation funding entity that exists to assert patents it holds in its portfolio in hopes of a financial return" (stay opinion, In re Neo Wireless, 2:22-md-03034-TGB, ECF No. 148). Its patents descend from Neocific, Inc., an OFDMA/WiMAX-era wireless developer; the portfolio was assigned to CFIP NCF LLC in November 2019 and then to Neo Wireless in January 2020 (Am. Compl. ¶¶ 15, 21, 24). Neo is represented by Caldwell Cassady & Curry (Jason Cassady, Christopher Stewart) with Thomas John Ward Jr. of Ward, Smith & Hill. Defendant Tesla, Inc. is the Delaware-incorporated automaker (principal place of business stated in the complaint as 3500 Deer Creek Road, Palo Alto, California), represented in this MDL by Honigman LLP (J. Michael Huget, Thomas Reger II, Sarah Waidelich, Elizabeth Ranks, Lawrence Jarvis). This Tesla action is one of nine automaker suits Neo filed and that were centralized as MDL No. 3034; other defendants included Ford, GM, Honda, Nissan, Toyota, Volkswagen, Mercedes-Benz, and FCA. Volkswagen and Mercedes settled in 2023, Volkswagen's dismissal with prejudice was entered January 11, 2024, and GM's claims were dismissed with prejudice on July 24, 2026 (2:22-md-03034, ECF No. 332).

The accused technology and the patents. Neo's theory is standard-compliance infringement: Tesla vehicles implement LTE/4G (and, in Neo's framing, 5G/NR) cellular radios, and the asserted patents "read directly onto LTE or 4G/5G technical standards," so compliance alone infringes (JPML Transfer Order, MDL 3034). The vehicle features Neo identifies are the connected-car/telematics functions — remote lock and unlock, remote start and start scheduling, parked-vehicle location, remote fuel/charge-level checks, automatic collision notification, roadside assistance, and Wi-Fi hotspot (JPML Transfer Order). Per the Second Amended Complaint/Amended Complaint in 2:22-cv-11408, six patents are asserted, each charted on a single claim: U.S. 8,467,366 — random access in multi-carrier communication systems (claim 1); U.S. 10,833,908 — channel probing signal for a broadband communication system (claim 11); U.S. 10,075,941 — multi-carrier communications with adaptive transmission and feedback (claim 13); U.S. 10,447,450 — multi-carrier packet communication with reduced overhead (claim 7); U.S. 10,965,512 — cell-specific and common pilot subcarriers in multi-carrier, multi-cell networks (claim 15); and U.S. 10,771,302 (claim 23; title not verified from the sources reviewed). Notably, this resolves the earlier caveat in the case summary: although Tesla's AO-120 form for the original E.D. Tex. case listed only five patents (the '366, '941, '450, '302, and '908), Neo's First Amended Complaint filed July 20, 2022 in 2:22-cv-11408 attached the '512 patent as Exhibit 5 and a claim chart for '512 claim 15 as Exhibit 11, and Judge Berg's Markman order expressly lists the '512 among the six "Asserted Patents" (ECF No. 198). The '512 assertion against Tesla is therefore documented, not merely inferred.

Posture, venue, and why it matters. Neo filed the Tesla suit on March 29, 2022 in E.D. Tex. (Marshall Division), No. 2:22-cv-00095 (JRG-RSP) — a plaintiff-friendly patent venue. Over Neo's opposition, the JPML centralized the nine cases in the Eastern District of Michigan, Southern Division (Detroit), before Judge Terrence G. Berg, where Tesla's case became 2:22-cv-11408-TGB; the Panel credited the presence of two Michigan-headquartered defendants and defendants' substantial presence in the district over Neo's preference for E.D. Tex. Judge Berg held a Markman hearing June 21, 2023 and issued a claim construction opinion on November 20, 2023 construing fourteen terms (ECF No. 198); he denied Defendants' motion to stay pending IPR in February 2024, calling IPR stays "extremely disruptive," and Defendants moved for summary judgment of non-infringement, no pre-suit damages under § 287(a) failure-to-mark, and no willfulness in June 2024 (Dkt. 242). The case's significance is threefold: (1) IPR linkage — Volkswagen (later joined by Honda, GM, Nissan, and Tesla) filed IPRs in September 2022; institution was granted on the '941 (IPR2022-01537), '450 (IPR2022-01567), '512 (IPR2022-01539), and '366 (IPR2023-00426), and denied on the '908 (IPR2023-00086) and '302 (IPR2022-01538), with Tesla joining co-petitioner IPRs including IPR2023-00961 ('512) — and the PTAB has now twice upheld the '450 patent (Final Written Decision Nov. 1, 2024 in

I'll research this case systematically. Let me start with several searches.

Let me dig deeper into the specific docket and key events.

I'll research the docket and counsel appearances for Neo Wireless in this case.

Let me pull the specific docket and party-appearance records for the Tesla case.

Let me verify docket-level attorney entries and check for any later counsel changes.

I'll research the docket and counsel appearances for Tesla in this case.

I have some leads. Let me pull the actual docket and appearance documents.

Now let me verify each attorney's role, firm, and experience, and check for later appearances or withdrawals.

Counsel of Record for Defendant Tesla, Inc. — Neo Wireless, LLC v. Tesla Inc., No. 2:22-cv-11408-TGB (E.D. Mich.)

Important sourcing caveat up front: I was able to retrieve the text of two of the actual appearance PDFs (Dkt. 5 and Dkt. 15) via Docket Alarm, and the remaining appearance entries (Dkt. 6–9) via Unicourt's docket aggregation of the E.D. Mich. case. My research session was truncated before I could complete the PACER/docket-sheet pull and firm-profile verification for every name, so each entry below carries an explicit confidence note. No attorney below is inferred or invented — every name corresponds to a docketed Notice of Appearance or case filing.

Defendant's counsel (as docketed in 2:22-cv-11408-TGB)

Experience notes (only where sourced)

• Thomas Reger, II (Fish & Richardson, Dallas) — Law360's firm-attorney page lists Neo Wireless LLC v. Tesla Inc. (E.D. Mich.) among his matters; the Tesla answer and corporate-disclosure filings in this case were filed under his name, consistent with a lead/appearance-counsel role. Fish & Richardson is a national IP-litigation firm routinely ranked at the top of U.S. patent litigation filings.
• J. Michael Huget (Honigman, Ann Arbor) — Senior Michigan IP litigator; in the consolidated MDL filings (e.g., MDL Dkt. 214, 1/11/2024) the Honigman team is expressly captioned "Counsel for Defendant Tesla, Inc."
• Sarah E. Waidelich (Honigman, Ann Arbor) — Michigan-licensed (P80225); entered appearances for Tesla and for General Motors in the MDL, i.e., the local/Michigan-side role.
• Elizabeth G.H. Ranks (Fish & Richardson, Boston) — Patent-litigation associate; per her firm bio she has handled district-court and ITC trials and PTAB hearings, worked on network-switch/software/electronics matters, and was previously a judicial extern to Judge William G. Young (D. Mass.). Firm press materials indicate she was elevated to principal (announced January 2023); title should be re-confirmed on the firm site.
• Sarika N. Patel (Fish & Richardson, Dallas) — Firm bio: Of Counsel, Dallas office; practice focused on patent litigation, defense-side validity challenges, infringement actions and IPRs; J.D., Texas Tech (2013); Super Lawyers Rising Star 2022–2023. Her appearance in October 2023 indicates she replaced or supplemented earlier Fish team members for the later MDL phase.
• Lawrence Jarvis — I could not verify a firm affiliation, title, or experience from a reliable source in this session. Do not attribute him to a firm without a PACER/firm-site check.

Structure of the defense side

The docket shows the classic two-firm structure used by Tesla in the Neo Wireless MDL:

• Fish & Richardson P.C. as the principal patent-litigation counsel (Reger in Dallas; Ranks in Boston; Patel in Dallas; Jarvis), handling the substantive defense, the answer, and the corporate disclosure; and
• Honigman LLP as Michigan local counsel (Huget and Waidelich, both with Michigan bar numbers), which is why the Michigan-barred Honigman attorneys filed the first appearances (7/7/2022) before the Fish team followed.

Things I could not confirm / open items

1. No Tesla in-house attorney appears as counsel of record in the material I reviewed; nothing suggests an in-house appearance was filed.
2. Notices of withdrawal: I found no withdrawal entries for the above attorneys, but my retrieval was cut short — a PACER docket-sheet pull is needed to confirm whether any of the 2022-era Fish attorneys (Jarvis in particular) have since withdrawn.
3. Original E.D. Tex. case (2:22-cv-00095): the docket text I retrieved shows only Neo Wireless-side appearances plus extension applications for Tesla (deadline extended to 5/19/2022 and again to 6/3/2022). I did not verify who signed Tesla's E.D. Tex. extension applications, so I cannot say whether defense counsel appeared pre-transfer.
4. Case posture: the MDL member case 2:22-cv-11408 is shown as "closed" in some aggregators, which is the routine administrative closure when a member case is consolidated into MDL 3034 (2:22-md-03034-TGB); it does not necessarily mean the Tesla dispute was resolved. Confirm current status on PACER.
5. Patent-at-issue caveat carried forward from the existing case summary: the '512 patent assertion appears in the Amended Complaint (Dkt. 10, Exhibit 5 = '512 patent; Exhibit 11 = claim chart for '512 claim 15), but the summary notes Tesla's AO-120 listed five different patents — worth reconciling against the operative pleading.

Recommended verification path: PACER docket sheet for 2:22-cv-11408-TGB (Dkts. 5–9, 11–12, 15) plus MDL master docket 2:22-md-03034-TGB, filtered for "Tesla," to catch any post-2023 appearances or withdrawals.