Neo Wireless, LLC v. Volkswagen Group of America, Inc. et al.

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

Let me dig deeper into the MDL, the patents, and the IPR linkage.

Let me verify patent titles and the VW-specific accused technology.

Case Overview and Background

The parties. Plaintiff Neo Wireless, LLC is a patent-assertion entity (NPE/PAE) that acquired its wireless portfolio in November 2019 from Neocific, Inc. (the acquisition was made under Neo's prior name, CFIP NCF LLC), part of a larger portfolio that also included European and Asian assets (RPX). Neocific was founded by Drs. Alex Li and Titus Lo, veterans of prior wireless systems including Wi-Max development, who began filing in the 2004–2005 timeframe on OFDMA-based systems; the portfolio Neo now holds comprises roughly 14 U.S. families, 66 U.S. patents, and 17 pending applications, and Neo states it has licensed it to multiple handset manufacturers for approximately $65 million (Neo's license letter, MDL 2:22-md-03034 ECF 79-1). Neo Wireless is widely reported as backed by Fortress Investment Group (a SoftBank-owned asset manager), which multiple trackers label the funder behind the campaign (IPWatchdog patent filings roundup; Unified Patents). Defendants are Volkswagen Group of America, Inc. and VW Group of America Chattanooga Operations, LLC — VW's U.S. sales/operating entity and the operator of its Chattanooga, Tennessee assembly plant. Both are operating companies, not patent holders.

The accused technology and patents. Neo's theory is that the defendants' cellular-connected vehicles infringe merely by implementing the LTE/4G and 5G/New Radio standards, through which the vehicles deliver telematics functions such as remote lock/unlock, remote start, parked-vehicle location, remote fuel-level checks, automatic collision notification, roadside assistance, and Wi-Fi hotspot service (JPML transfer order, MDL No. 3034). Secondary coverage reports the accused branded platforms as VW Car-Net, Audi Connect, Porsche Connect, and My Bentley, though I could not independently confirm those brand names from a court filing (PatSnap summary). The operative complaints asserted six Neo patents: U.S. 10,965,512, 8,467,366, 10,775,941, 10,447,450, 10,771,302, and 10,833,908 (the case metadata for this docket captures the '512 patent, which the complaint designated with representative claim 15). In one-line technical terms: the '512 patent (App. 17/012813) claims multi-cell networks in which base stations transmit cell-specific and common pilot subcarriers so receivers can perform different system functions; the '366 covers random-access/ranging signals configured for reliable uplink detection; the '941 concerns multi-carrier subchannel configuration (its disputed claim term addressed a mobile-specific parameter indicating distributed vs. localized subcarriers); the '450 patent covers multi-carrier packet communication with reduced control overhead using time-frequency resources (priority back to a Sept. 28, 2005 provisional); the '302 and '908 patents relate to overlaying multi-carrier/OFDM and direct-sequence spread-spectrum signals in time and/or frequency. (Patent sketches are drawn from the complaints' exhibits, PTAB papers, and Unified Patents' prior-art contests; titles beyond '450/'512 are stated at a high level where I could not fully verify them.)

Procedural posture and why it matters. Neo filed against VW in the Eastern District of Tennessee, Chattanooga Division (1:22-cv-00076, before District Judge Thomas A. Varlan and Magistrate Judge Susan K. Lee) on March 29, 2022 (Complaint, E.D. Tenn.). The Judicial Panel on Multidistrict Litigation centralized Neo's eight automotive suits — against Ford, Honda, VW, Nissan, Toyota, GM, Tesla, and later Mercedes-Benz and FCA/Stellantis — into MDL No. 3034, rejecting both Neo's request for the Eastern District of Texas and the defendants' preference and sending the cases to the Eastern District of Michigan before Judge Terrence G. Berg, noting Detroit's convenience and the benefit of a single judge construing the patents consistently (JPML transfer order). VW's case became 2:22-cv-11404-TGB and was dismissed with prejudice on January 11, 2024 on a joint Rule 41(a)(2) motion, each side bearing its own costs — matching the settlement-driven pattern that resolved other MDL defendants. The case is notable on several fronts: it exemplifies a Fortress-backed NPE pivoting a 4G/5G portfolio from handsets to connected-vehicle telematics, asserting standard-compliance as infringement across an entire OEM industry; it is tightly coupled to a wave of parallel IPRs (VW itself filed IPR2022-01537 on the '941, IPR2022-01539 on the '512, IPR2022-01567 on the '450, and IPR2023-00426 on the '366), several of which were terminated by settlement alongside the district-court dismissal (PTAB termination decision, IPR2022-01539); and the MDL also generated precedent-adjacent disputes — including General Plastic "significant relationship" denials that tied later-filing codefendants to VW's earlier IPR, and a European side-track in which Neo's UPC opt-out was invalidated, letting a Toyota revocation action proceed (RPX). Notably, the '450 patent survived PTAB review in a series of final written decisions (November 1, 2024 and September 3, 2025), underscoring that the patents' validity battles outlasted this particular settled docket (Lexology/PTAB analysis).

Sourcing caveat: Party structure, portfolio history, MDL facts, the IPR list, and the dismissal are well documented in the sources cited. The specific accused brand names, the exact model coverage, and some patent titles/technical summaries rely on secondary trackers (PatSnap, Unified/RPX) rather than a directly reviewed court filing, and Neo's $65M licensing figure and Fortress/SoftBank ownership are as Neo and third parties describe them — I found no judicial finding adopting those characterizations.

I'll research this case across multiple sources to build a chronological picture.

Let me dig into the specific docket events, PTAB proceedings, and the MDL's claim construction activity.

I've gathered substantial sourcing. Note that I hit a research step limit, so a few items below are flagged as not fully verified. Here is the chronological development of Neo Wireless v. Volkswagen (E.D. Tenn. 1:22‑cv‑00076 → E.D. Mich. 2:22‑cv‑11404‑TGB, part of MDL No. 3034).

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1. Filing and initial pleadings

• 2022‑03‑29 — Complaint filed (E.D. Tenn., Chattanooga Div.). Neo Wireless sued Volkswagen Group of America, Inc. and VW Group of America Chattanooga Operations, LLC, Case No. 1:22‑cv‑00076‑TAV‑SKL (Judge Thomas A. Varlan; Mag. J. Susan K. Lee). The complaint asserted six patents — U.S. 8,467,366; 10,075,941; 10,447,450; 10,771,302; 10,833,908; and 10,965,512 — all in the 4G/LTE and 5G/NR cellular space, accused against VW vehicles' embedded connectivity (e.g., Car‑Net features). The § 290 patent notice and the JPML record confirm the six‑patent set and the accused conduct (compliance with 3GPP LTE/5G standards). (JPML Transfer Order, MDL 3034; E.D. Tenn. docket)
• 2022‑04‑04 — Service on both VW entities (served 3/31/2022).
• 2022‑04‑18/19 — Defense appearance and first extension. Patterson IP Law (Ryan D. Levy, Seth R. Ogden, Mark A. Kilgore) appeared for VW; the court granted an unopposed extension to answer/move, setting a June 20, 2022 response deadline. Sterne Kessler (Anna Phillips, Daniel Yonan, Deirdre Wells, William Milliken) and Bush Seyferth (Susan McKeever, Justin Weiner) also entered the VW defense team.
• 2022‑07‑20 — Amended Complaint (Dkt. 4) filed in the transferee court, re‑pleading the six patents against both VW entities (no new parties). (E.D. Mich. docket excerpt)
• Answer / counterclaims. VW's operative answer and counterclaims (likely including declaratory‑judgment invalidity and non‑infringement counts, plus equitable defenses such as inequitable conduct) were filed in this window. The record confirms an affirmative motion to dismiss (below) and later references to VW's invalidity positions, but I did not retrieve the literal answer/counterclaim docket entry — treat the specific counterclaim counts as not independently verified here.

2. MDL transfer (forum change)

• 2022‑06‑16 (entered; docketed 6/28/2022) — JPML transfer. The case was centralized into In re Neo Wireless, LLC Patent Litigation, MDL No. 3034, before Judge Terrence G. Berg in the E.D. Mich., and reassigned as 2:22‑cv‑11404‑TGB. The Panel rejected VW/Nissan/Honda/Ford's opposition and Neo's E.D. Tex. venue request, finding common factual questions across seven automaker actions sharing the same six patents. (JPML Transfer Order, MDL 3034)

3. Pre‑trial motions of substance

• Aug. 2022 — VW's Rule 12(b)(6) motion to dismiss (with a reply filed Sept. 2022), cited in later briefing as "Defendants Volkswagen Group of America, Inc. and Volkswagen Group of America Chattanooga Operations, LLC's Motion to Dismiss Pursuant to Federal Rule of Civil Procedure 12(b)(6), Civil Action No. 2:22‑cv‑11404‑TGB." The outcome of that motion is not confirmed in the sources I retrieved — do not assume it was granted or denied.
• 2023 — Defendants' joint motion to stay the entire MDL pending IPR (Dkt. 145), with reply at Dkt. 149 (filed 2023‑06‑13). Defendants argued the § 315(a)–(c) factors weighed strongly in favor of a stay and rebutted Neo's "gamesmanship" accusations. ([Dkt. 149](https://www.docketalarm.com/cases/Mich

I'll research the counsel of record for Neo Wireless in this MDL case.

Let me get the actual docket sheet for the VW case specifically.

Let me verify the full plaintiff-side roster and check for any additional appearances (e.g., Lowenstein & Weatherwax, Latham, local counsel) on the VW docket.

Plaintiff-side counsel of record — Neo Wireless, LLC

Short answer: Three attorneys appeared for Neo Wireless on the 2:22-cv-11404 docket — two from the Dallas IP boutique Caldwell Cassady & Curry P.C. (Jason D. Cassady and Christopher S. Stewart) and one Michigan attorney acting as local counsel, Jaye Quadrozzi of Young, Garcia & Quadrozzi, PC. No in-house counsel entered an appearance. Neo Wireless's PTAB/IPR team (Lowenstein & Weatherwax LLP) appeared for it before the PTAB, not on this district-court docket.

Counsel table

Practitioners frequently associated with plaintiff-side Neo Wireless work (not docketed as of the last public docket sheet I can verify)

• Bailey A. Blaies (Caldwell Cassady & Curry) — her name appears in plaintiff-side signature blocks on MDL 3034 / related filing bundles (Tex. Bar No. 24109297), but I could not confirm a discrete notice of appearance on the 2:22-cv-11404 docket. Treat as "worked the matter," not confirmed of record.
• Hamad M. Hamad (Caldwell Cassady & Curry) — listed as back-up counsel for Neo Wireless in PTAB service lists and on other Neo Wireless district filings; no confirmed 11404 appearance found.
• Lowenstein & Weatherwax LLP (Kenneth J. Weatherwax, Nathan Lowenstein, Parham Hendifar, Nick Yakoobian, Edward Hsieh) — Neo Wireless's PTAB/IPR counsel of record (e.g., IPR2022-01537, IPR2023-00086, -00791), designated "Counsel for Patent Owner." They appear on the PTAB dockets, not the 11404 district docket in the docket sheet I reviewed.

Caveats / sourcing

• The attorney roster above is drawn from the EDMI docket sheet for 2:22-cv-11404-TGB (reproduced as Exhibit 1025 to the Petition in IPR2023-00426, filed 1/20/2023), which lists only Stewart, Quadrozzi, and Cassady for the plaintiff, plus ECF Nos. 5 and 16 (notices of appearance for Stewart and Quadrozzi). See also MDL 3034 Dkt. 153 (06/16/2023), signed by Stewart/Cassady/Quadrozzi.
• That docket sheet is a January 2023 snapshot. Any attorney who entered an appearance after that date would not appear in it; I could not pull a live PACER docket, so later appearances (if any) cannot be ruled out.
• No plaintiff attorney carried a "LEAD ATTORNEY" designation on the docket — only defendant-side counsel (Ryan D. Levy, Patterson Intellectual Property Law) was so flagged. Caldwell Cassady & Curry functioned as lead trial counsel in substance.
• I found no evidence of sealed or in-house plaintiff counsel. The only sealing-adjacent items in this dispute relate to the parties' confidential settlement agreement in the parallel IPR, not to counsel identity.
• Note the 1/11/2024 dismissal was by joint FRCP 41(a)(2) stipulation after settlement, so no counsel roles changed at the close beyond withdrawal by dismissal.

If you want, I can try to pull the later ECF entries (post-January 2023) and the signatures on the stipulation of dismissal to confirm whether Blaies or any additional counsel formally appeared.

I'll research the counsel of record for the defendants in this case. Let me run several searches.

Let me gather more detail on the specific firms and attorneys, and check the original E.D. Tenn. docket.

Let me resolve a conflict about the original E.D. Tenn. counsel and get bios of the defense attorneys.

Counsel of Record — Defendants Volkswagen Group of America, Inc. & VW Group of America Chattanooga Operations, LLC

Case: Neo Wireless, LLC v. Volkswagen Group of America, Inc. et al., No. 2:22-cv-11404-TGB (E.D. Mich.) (MDL No. 3034), transferred from No. 1:22-cv-00076 (E.D. Tenn.), terminated Jan. 11, 2024.

Per the E.D. Mich. docket sheet (reproduced in IPR Exhibit 1025), the defendants are represented by a three-firm team — a Nashville lead, a Washington, D.C. IP boutique, and a Michigan local-counsel firm. All are listed as "ATTORNEY TO BE NOTICED" for both Volkswagen entities.

Lead counsel (docketed as "LEAD ATTORNEY")

National / IP counsel — Sterne, Kessler, Goldstein & Fox PLLC (Washington, D.C.)

Firm address of record: 1101 K Street NW, 10th Floor, Washington, DC 20005 (notice of address change filed Aug. 4, 2023, MDL D.E. 167; formerly 1100 New York Ave. NW).

Sterne Kessler is one of the country's leading IP boutiques and served as VW's PTAB counsel in the parallel Volkswagen v. Neo Wireless IPRs (IPR2022-01537, -01538, -01539, -01567; IPR2023-00086), where Richard M. Bemben (lead) and Michael D. Specht were the designated PTAB counsel along with Yonan and Richardson. (VW Updated Mandatory Notices, IPR2023-00086)

Local counsel — Bush Seyferth PLLC (Troy, Mich.)

Firm address of record: 100 W. Big Beaver Road, Suite 400, Troy, MI 48084.

Original E.D. Tenn. counsel (pre-transfer)

In the predecessor case (1:22-cv-00076), a Notice of Appearance for Defendants was filed April 18, 2022 by Sims Funk, PLC, 3322 West End Ave., Suite 200, Nashville, TN — Samuel P. Funk, Mark W. Lenihan, and Evan S. Rothey (E.D. Tenn. D.E. 14). This Nashville team appears not to have carried over to the E.D. Mich. docket, where Ryan Levy (also Nashville) is docketed as lead.

⚠️ Source caveat: The transferred E.D. Tenn. complaint is logged on the docket with "Lenihan, Mark" as the filing attorney, which conflicts with the Sims Funk appearance noted above for the defendants. I could not fully reconcile that ECF filer attribution from the available records, so treat the exact captioning of the Lenihan/Sims Funk entry with caution.

Notes on scope and completeness

• No in-house counsel appeared of record on the district-court docket in the records available; only the outside firms above are listed.
• The Law360 coverage of the VW–Neo settlement (Dec. 18, 2023) lists VW's counsel as "Susan M. McKeever and Justin B. Weiner of Bush Seyferth PLLC and Daniel E. Yonan, Deirdre M. Wells, Ryan C. Richardson, William H. Milliken and Anna G. Phillips of Sterne Kessler Goldstein & Fox PLLC" — it does not name Ryan Levy, even though the docket sheet designates him lead attorney. This is likely because Law360 listed the trial/appearance team of record; the docket remains the authoritative source that Levy was docketed as lead. (Law360 reprint via Sterne Kessler)
• Because the case was dismissed with prejudice on Jan. 11, 2024 by joint Rule 41(a)(2) motion after settlement, and the related IPRs were terminated by settlement, some later notices of withdrawal/substitution (if any) may not be reflected in the last publicly indexed docket snapshot. The list above reflects the counsel of record as last shown on the docket (appearances in mid-2022; Sterne Kessler address change Aug. 2023).
• One additional name, Patrick G. Seyferth (Bush Seyferth, Mich. bar P47575), appears alongside McKeever in certain MDL/PTAB filings for the VW defendants; I could not confirm a district-court notice of appearance for him in 2:22-cv-11404 specifically, so I do not list him as counsel of record here.

Bottom line: the defense team was Ryan D. Levy (Patterson IP Law, Nashville — lead); Daniel E. Yonan, Deirdre M. Wells, Ryan C. Richardson, William H. Milliken, and Anna G. Phillips (Sterne Kessler, Washington, D.C.); and Susan M. McKeever and Justin B. Weiner (Bush Seyferth, Troy, Mich. — local counsel).