Neo Wireless, LLC v. Toyota Motor Corporation

I'll research this case across multiple sources to build an accurate overview.

Let me dig deeper into the Toyota case specifics, the '512 patent, and the IPR activity.

Let me verify the Toyota case's current status and Neo Wireless's corporate ownership.

Case Overview: Neo Wireless, LLC v. Toyota Motor Corporation, No. 2:22-cv-11406-TGB

The parties. Plaintiff Neo Wireless, LLC is a non-practicing patent-holding and licensing entity (NPE/PAE): it does not build or sell wireless equipment, but monetizes a portfolio of OFDMA/multi-carrier wireless patents whose chain of title runs back to Neocific, Inc. — the JPML's MDL transfer order notes that Neo pleads the asserted patents "share common inventors and a common assignment history from Neocific, Inc." (JPML Transfer Order, MDL 3034). Third-party trackers describe Neo as a SoftBank/Fortress Investment Group–affiliated vehicle: Unified Patents' Patroll notice labels it "owned by Neo Wireless, LLC, a Softbank entity," and IPWatchdog's filings roundup tags the plaintiff "[Softbank Group, Fortress IP]" (see the July 8, 2022 IPWatchdog Patent Filings Roundup). That beneficial-ownership characterization is well reported but not something I could confirm from a court record in this review — treat it as reported, not judicially established. On the defense side, the docket names the Japanese parent Toyota Motor Corporation plus its U.S. operating, sales, engineering/manufacturing, and captive-finance arms: Toyota Motor North America, Inc., Toyota Motor Sales, U.S.A., Inc., Toyota Motor Engineering & Manufacturing North America, Inc., and Toyota Motor Credit Corporation (UniCourt docket summary; JPML order).

The accused technology and the infringement theory. Neo does not accuse a discrete component; it accuses Toyota vehicles equipped with 4G/LTE and 5G/NR cellular connectivity and the connected-car features that ride on them. The JPML order frames the accused functionality as "remote lock and unlock, remote start and remote start scheduling, parked vehicle location, remote fuel level checks, automatic collision notification, roadside assistance, and Wi-Fi hotspot," and Neo's core theory is standard-compliance infringement: because the patents "read directly onto LTE or 4G/5G technical standards," any automaker "by complying with these standards… allegedly infringes the asserted patents" (JPML Transfer Order, MDL 3034). In Neo's parallel complaint work, it pleaded that the accused vehicles "implement the covered functionality of the 3GPP LTE standard" across Releases 8 through 17 and 5G/NR releases, relying on FCC filings and industry materials to show the vehicles are configured with the covered functionality (see the similarly worded Mercedes-Benz complaint at RPX Insight). Notably, Neo's campaign targets OEMs directly rather than the Tier-1 telematics suppliers or baseband chipset makers, a strategy that sidesteps component-level patent-exhaustion defenses.

The asserted patent and its technical sketch. In this Toyota docket the single patent at issue per the case metadata is U.S. Patent No. 10,965,512 B2 ("Method and apparatus using cell-specific and common pilot subcarriers in multi-carrier, multi cell wireless communication networks," Li et al.), which issued March 30, 2021 from Application No. 17/012,813, with a priority chain reaching a January 2004 provisional (Google Patents; AO 120 forms listing "10,965,512 — 3/30/2021 — Neo Wireless LLC"). Technically, the '512 patent claims an OFDMA-compatible mobile station/method that receives two classes of pilot subcarriers — "first pilots of a first type" that are cell-specific pilots, and "second pilots of a second type" plus data — where cell-specific information is recovered from

I'll research the key legal developments in this case across multiple sources.

Let me dig into the current posture, Toyota-specific developments, and the PTAB proceedings.

I've gathered substantial material. Note that I hit the research-tool limit before I could confirm a few docket-level specifics (Toyota's answer/counterclaims, and whether the '512 remains asserted in the Toyota docket specifically), so I flag those gaps explicitly below.

---

Legal Developments & Outcome — Neo Wireless, LLC v. Toyota Motor Corp., No. 2:22-cv-11406-TGB (E.D. Mich.)

Bottom line: This case is one track of the consolidated MDL No. 3034, In re Neo Wireless, LLC, Patent Litigation (E.D. Mich., Judge Terrence G. Berg). It was not tried. It has been litigated largely through the MDL's common pretrial proceedings (claim construction, a stay motion, and coordinated summary-judgment and inequitable-conduct practice) plus a parallel PTAB campaign. Toyota has not, on the sources I could reach, settled or been dismissed; the case remains pending and unadjudicated on the merits. Several co-defendants, however, have settled out.

⚠️ Two cross-reference flags before the chronology:

1. Patent scope mismatch. The case metadata lists a single patent at issue for Toyota — U.S. Pat. No. 10,965,512. The original E.D. Tex. complaint (AO 120) asserted six patents against Toyota: '366, '941, '450, '302, '908, and '512. The MDL-wide MSJ (mid-2024) addresses only '941, '450, '302, and '908 (not '512 or '366), implying the MDL's asserted set was narrowed. Which patents remain live in the Toyota track specifically is something I could not confirm; treat the metadata's single-'512 list as authoritative for this docket per the operating rules, but note it conflicts with the original pleading.
2. Status label. Case metadata says "pending." A tertiary MDL tracker (mdlupdate.com, updated 2026-06-01) reports 7 pending actions of 9 total in MDL 3034 — consistent with Toyota still being in the case (only Mercedes and VW have resolved). That tracker also mislabels the subject matter as "antitrust," so I rely on it only for the gross action count.

---

Chronology

2022 — Filing, MDL centralization, and transfer into E.D. Mich.

• 2022-03-29 — Original complaint filed. Neo sued the Toyota entities in E.D. Tex. (Marshall Div.), No. 2:22-cv-00093, for patent infringement under 35 U.S.C. § 271, asserting the '366, '941, '450, '302, '908 and '512 patents and demanding a jury (UniCourt docket; AO 120 forms at [RPX/Patexia]). Named defendants initially: Toyota Motor North America, Inc., Toyota Motor Sales, U.S.A., Inc., Toyota Motor Engineering & Manufacturing North America, Inc.; summons for the Japanese parent Toyota Motor Corporation and Toyota Motor Credit Corporation issued in June 2022, and a First Amended Complaint added them (per Patexia docket listing).
• 2022-06-14 — JPML transfer order (MDL 3034). The Panel centralized seven actions in E.D. Mich. before Judge Berg, over Ford/Nissan/Honda/Volkswagen opposition, reasoning that the patents "overlap completely" and that standard-compliance infringement theories (LTE/5G) favor centralization (JPML Transfer Order).
• 2022-06-28 — Re-docketed as 2:22-cv-11406-TGB. The E.D. Tex. case was terminated and transferred into the MDL; UniCourt lists status "Closed" for the transferor docket only — the Michigan track is live.
• Answer / counterclaims (gap). I could not retrieve Toyota's answer, invalidity contentions, or any non-infringement/declaratory-judgment counterclaims from a primary source in this review. Given the MDL's coordinated MSJ and inequitable-conduct defenses, Toyota clearly contested validity and infringement, but I cannot cite a specific pleading. Flagging as unverified.

2022–2023 — Pretrial framework, claim construction, and the stay fight

• 2023-01-18 — Joint Claim Construction Statement filed (Exhibit A agreed terms; Exhibit B disputed terms), signed for the Toyota defendants by Fish & Richardson counsel (Joseph A. Herriges, Conrad A. Gosen, James Huguenin-Love) (JCSS).
• 2023-05 — Defendants' Joint Motion to Stay Pending IPR filed (MDL ECF 145). Neo responded (ECF 148, filed 2023-06-07). Neo argued the case was far from an "efficient stopping point" after a year of consolidation and substantial claim-construction work (ECF 148).
• 2023-06-06 — Mercedes-Benz settles and is dropped (ECF 147) — the first MDL settlement.
• 2023-06-16 — PTAB denies institution on the '908 patent (VW's IPR2023-00086, Paper 7); Neo promptly filed a notice of supplemental facts to defeat the stay motion (ECF 153).
• 2023 — Claim Construction Memorandum and Order (MDL ECF 198). After a Markman hearing, Judge Berg construed fourteen terms/phrases across the asserted patents. The most consequential construction: the '908's "random access signal" = "a direct sequence spread spectrum signal used as a random access signal." (Markman Order, ECF 198 at 54–62, quoted in

I'll research the counsel of record for Neo Wireless in this case using web searches against docket sources, firm websites, and legal press.

Let me dig deeper into the specific docket and verify which firms represent Neo Wireless (versus defendants).

I have strong leads. Let me verify the individual attorneys' firms and check for any additional appearances (including the recent docket and possible Hogan Lovells involvement).

I'll research the counsel of record for Toyota in this case.

Let me dig deeper into the specific docket and counsel appearances.

Let me pull the actual documents to confirm which firms represent Toyota.