Forsakringsaktiebolaget Avanza Pension Reports 3.90% Holding in Neonode

Rhea-AI Filing Summary

Forsakringsaktiebolaget Avanza Pension, a Swedish insurance company, reported beneficial ownership of 654,902 shares of Neonode Inc. common stock, representing 3.90% of the class. The filing notes 3,280 cash-settled instruments also held. The shares are reported as sole voting power of 654,902 and shared dispositive power for 654,902, with no sole dispositive power. The Schedule 13G/A lists the issuer address in Stockholm and confirms the stake was acquired and held in the ordinary course of business without intent to influence control.

Insights

Financial Analyst

TL;DR: A 3.90% passive stake disclosed; below 5% threshold, so generally non-material to valuation or control.

The filing documents a passive, non-control position by a regulated Swedish insurance company. At 654,902 shares and 3.90% ownership, this disclosure is important for transparency but falls under the non-activist Schedule 13G regime. No changes to capital structure, board composition, or major transactions are indicated. The mention of 3,280 cash-settled instruments marginally increases economic exposure but does not change the reporting percentage provided. Impact on investors is limited absent further accumulation or strategic actions.

Corporate Governance Expert

TL;DR: Reporting meets disclosure standards; position is passive and not indicative of governance influence.

The filer certified holdings are ordinary-course and not aimed at influencing control, aligning with Schedule 13G treatment. Sole voting power is reported, but shared dispositive power indicates custody or collective management arrangements. No group affiliation or parent-subsidiary acquisition is reported. For governance, this holding does not trigger additional governance obligations or activist engagement signals.

SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

SCHEDULE 13G

UNDER THE SECURITIES EXCHANGE ACT OF 1934

(Amendment No. 16)

Neonode Inc.

(Name of Issuer)

COMMON STOCK, PAR VALUE $0.001 PER SHARE

(Title of Class of Securities)

64051M709

(CUSIP Number)

09/04/2025

(Date of Event Which Requires Filing of this Statement)

Check the appropriate box to designate the rule pursuant to which this Schedule is filed:

Rule 13d-1(b)

Rule 13d-1(c)

Rule 13d-1(d)

SCHEDULE 13G

CUSIP No. 64051M709

1

Names of Reporting Persons

Forsakringsaktiebolaget Avanza Pension

2

Check the appropriate box if a member of a Group (see instructions)

(a)
(b)

3

Sec Use Only

4

Citizenship or Place of Organization

SWEDEN

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 654,902.00
6	Shared Voting Power 0.00
7	Sole Dispositive Power 0.00
8	Shared Dispositive Power 654,902.00

9

Aggregate Amount Beneficially Owned by Each Reporting Person

654,902.00

10

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

11

Percent of class represented by amount in row (9)

3.90 %

12

Type of Reporting Person (See Instructions)

FI

Comment for Type of Reporting Person: Forsakringsaktiebolaget Avanza Pension also own 3,280 Cash settled instruments in Neonode Inc.

SCHEDULE 13G

Item 1.
(a)	Name of issuer: Neonode Inc.
(b)	Address of issuer's principal executive offices: Karlavagen 100STOCKHOLM, 115 26SWEDEN Stockholm, SE
Item 2.
(a)	Name of person filing: Forsakringsaktiebolaget Avanza Pension
(b)	Address or principal business office or, if none, residence: Box 1399 STOCKHOLM, 11139 SWEDEN
(c)	Citizenship: Forsakringsaktiebolaget Avanza Pension is a company organized under the laws of Sweden
(d)	Title of class of securities: COMMON STOCK, PAR VALUE $0.001 PER SHARE
(e)	CUSIP No.: 64051M709
Item 3.	If this statement is filed pursuant to §§ 240.13d-1(b) or 240.13d-2(b) or (c), check whether the person filing is a:
(a)	Broker or dealer registered under section 15 of the Act (15 U.S.C. 78o);
(b)	Bank as defined in section 3(a)(6) of the Act (15 U.S.C. 78c);
(c)	Insurance company as defined in section 3(a)(19) of the Act (15 U.S.C. 78c);
(d)	Investment company registered under section 8 of the Investment Company Act of 1940 (15 U.S.C. 80a-8);
(e)	An investment adviser in accordance with § 240.13d-1(b)(1)(ii)(E);
(f)	An employee benefit plan or endowment fund in accordance with § 240.13d-1(b)(1)(ii)(F);
(g)	A parent holding company or control person in accordance with § 240.13d-1(b)(1)(ii)(G);
(h)	A savings associations as defined in Section 3(b) of the Federal Deposit Insurance Act (12 U.S.C. 1813);
(i)	A church plan that is excluded from the definition of an investment company under section 3(c)(14) of the Investment Company Act of 1940 (15 U.S.C. 80a-3);
(j)	A non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J). If filing as a non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J), please specify the type of institution:
(k)	Group, in accordance with Rule 240.13d-1(b)(1)(ii)(K).
	Insurance company
Item 4.	Ownership
(a)	Amount beneficially owned: 654,902
(b)	Percent of class: 3.90 %
(c)	Number of shares as to which the person has:
	(i) Sole power to vote or to direct the vote: 654,902
	(ii) Shared power to vote or to direct the vote: None
	(iii) Sole power to dispose or to direct the disposition of: None
	(iv) Shared power to dispose or to direct the disposition of: 654,902
Item 5.	Ownership of 5 Percent or Less of a Class.
Item 6.	Ownership of more than 5 Percent on Behalf of Another Person.
	Not Applicable
Item 7.	Identification and Classification of the Subsidiary Which Acquired the Security Being Reported on by the Parent Holding Company or Control Person.
	Not Applicable
Item 8.	Identification and Classification of Members of the Group.
	Not Applicable
Item 9.	Notice of Dissolution of Group.
	Not Applicable

Item 10.

Certifications:

By signing below I certify that, to the best of my knowledge and belief, the securities referred to above were acquired and are held in the ordinary course of business and were not acquired and are not held for the purpose of or with the effect of changing or influencing the control of the issuer of the securities and were not acquired and are not held in connection with or as a participant in any transaction having that purpose or effect, other than activities solely in connection with a nomination under ?? 240.14a-11. By signing below I certify that, to the best of my knowledge and belief, the foreign regulatory scheme applicable to an insurance company is substantially comparable to the regulatory scheme applicable to the functionally equivalent U.S. institution(s). I also undertake to furnish to the Commission staff, upon request, information that would otherwise be disclosed in a Schedule 13D.

SIGNATURE

After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this statement is true, complete and correct.

Forsakringsaktiebolaget Avanza Pension

Signature:	/s/ Joakim Lomell
Name/Title:	Joakim Lomell / Middle Office
Date:	09/08/2025

FAQ

How many Neonode (NEON) shares does Forsakringsaktiebolaget Avanza Pension own?

The filer reports owning 654,902 shares of Neonode Inc., representing 3.90% of the outstanding common stock.

Does Forsakringsaktiebolaget Avanza Pension intend to influence control of Neonode (NEON)?

No. The filing certifies the shares were acquired and are held in the ordinary course of business and not for the purpose of changing or influencing control.

Are there derivative or other instrument exposures disclosed in the filing for NEON?

Yes. The filer notes ownership of 3,280 cash-settled instruments in Neonode Inc.

What filing form was used to disclose the stake in Neonode (NEON)?

The stake was disclosed on a Schedule 13G/A, filed under the Securities Exchange Act of 1934 as an amendment.

When was the Schedule 13G/A signed for the Neonode (NEON) disclosure?

The signature on the filing is dated 09/08/2025, and the event date requiring the filing is listed as 09/04/2025.