[sheet: Final Invoice]
| Field | Detail |
| Firm | Calderwood & Harkness LLP |
| Firm Address | One Fountain Square, 11th Floor, Detroit, MI 48226 |
| Invoice Date | June 25, 2025 |
| Invoice Number | INV-1007-00003-006 |
| Matter Number | 1007-00003 |
| Matter Description | Pinnacle Innovations LLC v. Vantage Mobility Systems Corp., No. 2:24-cv-00187-JRG (E.D. Tex.) — Patent Infringement Defense |
| Client | Vantage Mobility Systems Corp. |
| Client Address | 4200 Innovation Drive, Auburn Hills, MI 48326 |
| Attn | Rachel Nguyen, VP & Associate General Counsel |
| Billing Partner | Catherine Bloom |
| Responsible Partner | Marcus Delgado |
| Billing Period | June 1, 2025 – June 25, 2025 |
— TIME ENTRIES —
| Date | Timekeeper | Description | Hours | Standard Rate | Blended Cap Rate |
| 06/02/2025 | Marcus Delgado | Review and finalize Settlement Agreement and Mutual Release; conference with R. Nguyen regarding execution logistics | 2.5 | $895 | $625 |
| 06/03/2025 | Omar Siddiqui | Coordinate settlement payment instructions with Northbridge Specialty Insurance Co.; prepare payment confirmation letter | 1.8 | $575 | $575 |
| 06/04/2025 | Marcus Delgado | Supervise execution of Settlement Agreement; correspondence with N. Whitfield (Whitfield & Gaines) re: exchange of executed counterparts | 1.2 | $895 | $625 |
| 06/05/2025 | Christy Bauer | Prepare draft Joint Stipulation of Dismissal with Prejudice for filing in E.D. Tex. | 2.0 | $425 | $425 |
| 06/06/2025 | Omar Siddiqui | Review and revise Joint Stipulation of Dismissal; coordinate with S. Caldwell (Caldwell Barrow LLP) re: local filing requirements | 1.5 | $575 | $575 |
| 06/09/2025 | Marcus Delgado | Final review of Joint Stipulation; authorize filing | 0.8 | $895 | $625 |
| 06/10/2025 | Christy Bauer | Prepare matter closing letter to client; compile file-closing checklist and document retention summary | 3.0 | $425 | $425 |
| 06/12/2025 | Omar Siddiqui | Review closing letter; verify payment confirmation from Northbridge; confirm stipulation entered by Court | 1.2 | $575 | $575 |
| 06/16/2025 | Christy Bauer | Prepare privilege log status memorandum and document retention/destruction protocol memo | 2.5 | $425 | $425 |
| 06/18/2025 | Marcus Delgado | Review and approve closing letter and privilege log memo; final correspondence to R. Nguyen | 1.0 | $895 | $625 |
| 06/20/2025 | Christy Bauer | Archive matter files in firm DMS; coordinate off-site storage of physical files | 1.5 | $425 | $425 |
| 06/23/2025 | Catherine Bloom | Review final invoice; approve cumulative fee/cost summary; authorize retainer credit application | 1.0 | $850 | $625 |
— JUNE 2025 FEE SUMMARY —
| Total Hours (June 2025) | 20.0 |
| Fees at Standard Rates | $12,385.00 |
| Fees at Blended Cap Rates (applied monthly per engagement terms) | $10,825.00 |
| Blended Cap discount | ($1,560.00) |
— DISBURSEMENTS (JUNE 2025) —
| Courier/filing services | $125.00 |
| Westmark Data Systems/legal research | $340.00 |
| Total Disbursements (June 2025) | $465.00 |
— CURRENT CHARGES —
| Professional Fees (June 2025, after blended cap) | $10,825.00 |
| Disbursements (June 2025) | $465.00 |
| Total Current Charges | $11,290.00 |
— RETAINER CREDIT & BALANCE DUE —
| Evergreen Retainer on Deposit | $50,000.00 |
| Less: Retainer Credit Applied to Final Invoice | ($11,290.00) |
| Retainer Credit Applied to Prior Outstanding Balance | ($38,710.00) |
| Balance Due from Client | $0.00 |
| Retainer Refund Due to Client (if applicable) | $0.00 |
| Payment Terms | Net 30 days from invoice date |
| Remittance Address | Calderwood & Harkness LLP, One Fountain Square, 11th Floor, Detroit, MI 48226 |
[sheet: Cumulative Fee Summary]
| Timekeeper | Title / Role | Office | Standard Hourly Rate | Blended Cap Rate | Total Hours | Fees at Standard Rates | Fees at Blended Cap Rates | Blended Cap discount |
| Marcus Delgado | Responsible Partner, IP | Detroit | $895 | $625 | 148.0 | $132,460.00 | $92,500.00 | ($39,960.00) |
| Catherine Bloom | Billing Partner, IP | Detroit | $850 | $625 | 42.0 | $35,700.00 | $26,250.00 | ($9,450.00) |
| Omar Siddiqui | Lead Associate, IP | Houston | $575 | $575 | 312.0 | $179,400.00 | $179,400.00 | $0.00 |
| Christy Bauer | Working Associate, IP | Detroit | $425 | $425 | 269.4 | $114,495.00 | $114,450.00 | ($45.00) |
| TOTALS | 771.4 | $462,055.00 | $412,600.00 | ($49,455.00) |
[sheet: Cumulative Cost Summary]
Category
— DEFENSE COSTS (C&H ENGAGEMENT PERIOD: JAN 15, 2025 – JUN 2025) —
| Legal Fees — Lead Counsel | Calderwood & Harkness LLP | Hourly fees (blended cap $625/hr); Engagement No. 1007-00003 | $412,600.00 | Jan 15, 2025 – Jun 25, 2025; 4 timekeepers |
| Legal Fees — Local Counsel | Caldwell Barrow LLP | Local counsel fees, E.D. Tex.; $475/hr; lead attorney Sandra Caldwell | $18,200.00 | Local-rule compliance, courtesy copies, in-court appearances |
| Expert / Consulting Fees | Greystone Technical Consulting LLC | Technical expert — Dr. Franklin Yeoh; $650/hr; invalidity/non-infringement analysis, claim charts | $47,750.00 | Opinion not formally filed due to settlement |
| E-discovery | Meridian Document Solutions LLC | Document processing, hosting, and production | $31,400.00 | 7600 Leesburg Pike, Suite 410, Falls Church, VA 22043 |
| Court Costs & Filing Fees | U.S. District Court, E.D. Tex. | Filing fees, service costs, and court expenses | $2,850.00 | Case No. 2:24-cv-00187-JRG |
| TOTAL DEFENSE COSTS | $512,800.00 | Sum of all defense cost categories above |
— SETTLEMENT PAYMENT —
| Settlement Payment (Total) | Pinnacle Innovations LLC | Lump-sum nuisance-value settlement; covenant not to sue; no license; no admission | $385,000.00 | Per Settlement Agreement dated June 4, 2025; payable within 30 days of execution |
| — VMS Self-Insured Retention (SIR) | Vantage Mobility Systems Corp. | SIR under Northbridge Policy No. NSI-CGL-2024-08821 | $75,000.00 | Funded by VMS |
| — Northbridge Indemnity Portion | Northbridge Specialty Insurance Co. | Indemnity payment under CGL IP Infringement Defense sublimit ($500K per occurrence / $1M aggregate) | $310,000.00 | = $385,000 − $75,000 SIR; coverage confirmed Feb 12, 2025 |
— GRAND TOTAL —
GRAND TOTAL LITIGATION SPEND (C&H PERIOD)
— VMS OUT-OF-POCKET —
| Defense Costs (borne by VMS) | All defense costs paid by VMS outside insurance policy sublimit | $512,800.00 | Northbridge coverage limited to indemnity; defense costs not covered |
| VMS SIR Portion of Settlement | Self-insured retention | $75,000.00 | Per Policy No. NSI-CGL-2024-08821 |
| VMS TOTAL OUT-OF-POCKET | $587,800.00 | = $512,800 + $75,000 |
— RETAINER —
| Retainer Deposited at Engagement Opening | Vantage Mobility Systems Corp. | Evergreen retainer per engagement letter | $50,000.00 | Deposited Jan 15, 2025 |
| Retainer Credit Applied | Applied against final invoice and outstanding balance | ($50,000.00) | Fully credited; see Final Invoice tab | |
| Retainer Balance | $0.00 | No refund due |
[sheet: Monthly Billing Detail]
| Billing Month | Invoice Number | Total Hours | Fees at Standard Rates | Fees at Blended Cap Rate | Monthly discount | Disbursements | Total Monthly Charges | Cumulative Fees | Cumulative Total |
| January 2025 (Jan 15–31) | INV-1007-00003-001 | 85.0 | $52,125.00 | $46,300.00 | ($5,825.00) | $1,240.00 | $47,540.00 | $46,300.00 | $47,540.00 |
| February 2025 | INV-1007-00003-002 | 152.0 | $90,850.00 | $84,200.00 | ($6,650.00) | $2,680.00 | $86,880.00 | $130,500.00 | $134,420.00 |
| March 2025 | INV-1007-00003-003 | 198.0 | $118,300.00 | $108,500.00 | ($9,800.00) | $3,450.00 | $111,950.00 | $239,000.00 | $246,370.00 |
| April 2025 | INV-1007-00003-004 | 176.0 | $104,200.00 | $96,275.00 | ($7,925.00) | $2,100.00 | $98,375.00 | $335,275.00 | $344,745.00 |
| May 2025 | INV-1007-00003-005 | 140.4 | $84,195.00 | $66,500.00 | ($17,695.00) | $1,975.00 | $68,475.00 | $401,775.00 | $413,220.00 |
| June 2025 | INV-1007-00003-006 | 20.0 | $12,385.00 | $10,825.00 | ($1,560.00) | $465.00 | $11,290.00 | $412,600.00 | $424,510.00 |
| TOTALS | 771.4 | $462,055.00 | $412,600.00 | ($49,455.00) | $11,910.00 | $424,510.00 |
[sheet: Settlement Payment Summary]
| Item | Detail | Amount | Notes |
| Settlement Agreement Date | June 4, 2025 | Execution version — Settlement Agreement and Mutual Release | |
| Case | Pinnacle Innovations LLC v. Vantage Mobility Systems Corp. | No. 2:24-cv-00187-JRG (E.D. Tex.) | |
| Asserted Patent | U.S. Patent No. 9,847,312 B2 | Claims 1, 7, and 14 | |
| Plaintiff | Pinnacle Innovations LLC | NPE; managing member Grayson Holt | |
| Plaintiff's Counsel | Whitfield & Gaines PLLC (Nolan Whitfield) | Contingency: 35% of recovery | |
| Defendant | Vantage Mobility Systems Corp. | ||
| Defense Counsel | Calderwood & Harkness LLP (Marcus Delgado) | Engagement No. 1007-00003 | |
| Total Settlement Amount | $385,000.00 | Lump sum; non-refundable | |
| Payment Deadline | 30 calendar days after full execution | Due by July 4, 2025 | |
| Structure | Covenant not to sue (not a license) | Preferred by VMS for accounting/disclosure reasons | |
| Scope of Covenant | VMS, affiliates, successors, customers, end users | Covers '312 Patent and all Pinnacle portfolio patents as of effective date | |
| Releases | Mutual general releases of all claims arising from the litigation | ||
| Admission | No admission of liability, infringement, or validity | ||
| Confidentiality | Settlement amount and terms confidential; existence of settlement may be disclosed | ||
| Dismissal | Joint stipulation of dismissal with prejudice | Within 14 days of payment confirmation | |
| Attorneys' Fees | Each party bears its own |
— INSURANCE COVERAGE —
| Insurer | Northbridge Specialty Insurance Company | 200 Harbor Boulevard, Stamford, CT 06902 |
| Policy Number | NSI-CGL-2024-08821 | Commercial General Liability — IP Infringement Defense sublimit |
| IP Sublimit (Per Occurrence) | $500,000.00 | |
| IP Sublimit (Aggregate) | $1,000,000.00 | No prior claims against aggregate |
| Self-Insured Retention (SIR) | $75,000.00 | Per policy terms |
| Coverage Confirmation Date | February 12, 2025 | Subject to SIR and reservation of rights |
| Claims Adjuster | Tanya Whitcomb | Northbridge Specialty Insurance Co. |
— FUNDING ALLOCATION —
| VMS SIR Portion | Funded by Vantage Mobility Systems Corp. | $75,000.00 | |
| Northbridge Indemnity Portion | Funded by Northbridge Specialty Insurance Co. | $310,000.00 | = $385,000 − $75,000 |
| Total Settlement Payment | $385,000.00 | = $75,000 + $310,000 |
— REMAINING INSURANCE CAPACITY —
| Remaining IP Sublimit (Per Occurrence) | $190,000.00 | = $500,000 − $310,000 |
| Remaining IP Sublimit (Aggregate) | $690,000.00 | = $1,000,000 − $310,000 |
— RIDGELINE APPROVAL —
| Approval Required Under | VMS Operating Agreement § 7.04(c) | Ridgeline board-designee approval for settlements > $250,000 |
| Approval Obtained | May 22, 2025 | Written consent signed by David Mercer, Ridgeline Capital Partners Fund IV, LP |
| Approving Party | Ridgeline Capital Management, LLC | 600 Lexington Avenue, 32nd Floor, New York, NY 10022 |
[sheet: Matter Summary]
Item
— MATTER INFORMATION —
| Matter Number | 1007-00003 |
| Matter Description | Defense of NPE Patent Infringement Action — Telematics Patents |
| Case Caption | Pinnacle Innovations LLC v. Vantage Mobility Systems Corp. |
| Case Number | No. 2:24-cv-00187-JRG (E.D. Tex.) |
| Court | United States District Court, Eastern District of Texas |
| Judge | Hon. J. Rodney Gilstrap |
| Asserted Patent | U.S. Patent No. 9,847,312 B2 — 'System and Method for Aggregated Vehicle Telemetry Data Transmission Over Cellular Networks' |
| Patent Issue Date | March 6, 2018 |
| Patent Expiration Date | September 12, 2035 |
| Named Inventor | Dr. Alan Prescott (former CTO, DataStream Automotive, Inc.) |
| Asserted Claims | Independent Claims 1, 7, and 14 |
| Accused Products | VMS DriveLink™ 4.0 (telematics control unit); VMS FleetPulse™ (cloud platform) |
— CLIENT —
| Client | Vantage Mobility Systems Corp. |
| Client Address | 4200 Innovation Drive, Auburn Hills, MI 48326 |
| Key Contact | Rachel Nguyen, VP & Associate General Counsel |
| PE Sponsor | Ridgeline Capital Partners Fund IV, LP |
| VMS FY 2024 Revenue | ~$218,000,000 |
— ENGAGEMENT TIMELINE —
| Complaint Filed | February 28, 2024 |
| Prior Counsel (Hargrove Dunn LLP) Fees | ~$624,000 (out of scope) |
| C&H Engagement Opened | January 15, 2025 |
| Markman Hearing | November 14, 2024 (pre-C&H; Claim Construction Order entered December 19, 2024) |
| Fact discovery Closed | March 28, 2025 |
| Settlement Agreement Executed | June 4, 2025 |
| Dismissal Filed/Entered | June 2025 |
| Original Trial Date (Vacated) | October 6, 2025 |
— FINANCIAL SUMMARY —
| C&H Legal Fees | $412,600 |
| Caldwell Barrow LLP (Local Counsel) | $18,200 |
| Greystone Technical Consulting (Expert) | $47,750 |
| Meridian Document Solutions (E-discovery) | $31,400 |
| Court Costs & Filing Fees | $2,850 |
| Total Defense Costs (C&H Period) | $512,800 |
| Settlement Payment | $385,000 |
| Grand Total Litigation Spend (C&H Period) | $897,800 |
| VMS SIR | $75,000 |
| Northbridge Indemnity | $310,000 |
| VMS Total Out-of-Pocket | $587,800 |
| C&H Retainer Deposited / Credited | $50,000 |
— COST-SAVINGS ANALYSIS —
| Estimated Cost-to-Trial (Additional) | $2,800,000 – $3,400,000 |
| Actual Settlement + Defense Costs | $897,800 |
| Estimated Savings vs. Trial (Low End) | $1,902,200 |
| Estimated Savings vs. Trial (High End) | $2,502,200 |
| Invalidity Probability (Greystone Assessment) | 65–70% (at least one independent claim) |
| Non-Infringement Probability (Post-Markman) | 55–60% |
| Settlement Characterization | Nuisance-value settlement; economically rational given cost-to-trial |