is... buying more shares
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Your posts make little sense to me. Comparing a proven entity such as IPNav/MARA to lottery plays like WDDD and BCYP speaks volumes as to where you are coming from.
Good luck with your specs.
That's a rather simplistic view, IMHO.
MARA is a ultra microcap, developmental stage company that has just recently transitioned to an IP asset management play. One can not simply judge a new entity in the patent asset class using the same metrics one would use to evaluate an established industrial equity.
For a new business to jump out of the gates successfully with actual sustainable revenue -- that's big. Any analyst worth a dime will be able to see that this success can be replicated over and over again. This leads to geometric growth, which leads to higher valuations.
But like all things in the market, everyone is free to draw their own conclusions and apply their own aversions.
Alphi: << MSFT is now a mobile phone manufacturer... presumably they will also need a license for VRNGS nokia patents >>
That's not correct. This MSFT/NOK deal should not change anything with respect to VRNG. We should presume nothing of the sort. First, the VRNG/MSFT settlement is related ONLY to the internet search & advertising and the Lang/Kosak patents from the Lycos days. It does not involve mobile technology.
More importantly, Nokia still owns the NSN infrastructure and networking manufacturing business.
And finally, according to the actual NOK/VRNG patent agreement, Nokia has a worldwide, lifetime fully paid-up license to use the patents sold to VRNG. This license is transferred to MSFT with respect to the Nokia phone business. See below:
To me it's facts vs hype. The fact is that MSFT and VRNG agreed to a limitation on Microsoft's total liability.
You can't be half pregnant. You can't have a limitation if there is no cap or ceiling.
Enjoy your labor day.
Peace. Out.
It's correct. Look at the stock price.
Again, there is no such thing a limitation on total liability if such limitation goes away. LOL.
Law360.com article: Vringo Wants Google Sanctioned Over AdWords Docs
Vringo Wants Google Sanctioned Over AdWords Docs
By Ryan Davis
Law360, New York (August 30, 2013, 5:24 PM ET) -- Vringo Inc. told a judge Thursday that Google Inc. should be sanctioned for failing to comply with a court order requiring it to turn over documents on how it has redesigned its AdWords program to avoid infringing Vringo's search engine advertisement patents.
A jury found last year that Google had infringed the patents and U.S. District Judge Raymond Jackson is now considering what Google owes as an ongoing royalty. Google claims it has redesigned AdWords so that it no longer infringes and therefore shouldn't have to pay a royalty in the future.
When he ruled in August that Google owed an ongoing royalty, he ordered Google to turn over documents detailing the redesign by Aug. 25, but Vringo subsidiary I/P Engine Inc. says the "mere 17 documents" that Google produced fall far short of what the court required.
"Google is in willful contempt of this court's order. That contempt should be sanctioned because it thwarts this court's schedule and and requires I/P Engine to seek this relief," I/P Engine's motion said.
In addition to the handful of documents, Google turned over "boundless" source code that would be unreasonably burdensome to review, I/P Engine says. Google allegedly didn't produce any internal emails among engineers regarding the redesign, which I/P Engine says would be highly relevant.
"It is implausible that the alleged redesign for a multibillion-dollar system would have been engineered, tested, analyzed, approved and implemented on the basis of such scant documentation and no relevant custodial documents, such as emails discussing the changes," it said.
Google's failure to turn over the relevant documents will disrupt the briefing schedule for the case, which requires I/P Engine to produce an expert report by the end of September, according to the motion.
"Google’s stall tactic has already prejudiced I/P Engin," it said. "Simply stated, this court’s schedule allows no time for gameplay. I/P Engine must produce an expert witness report in just four weeks."
I/P Engine asked the judge to require Google to show cause why it should not be sanctioned.
After finding that they infringed, the jury ordered Google and the other defendants — AOL Inc., IAC Search & Media Inc., Gannett Co. Inc. and Target Corp. — to pay a total of $30 million in damages. Of the total, Google was ordered to pay $15.8 million.
The patents-in-suit are U.S. Patent Numbers 6,314,420 and 6,775,664.
Vringo and I/P Engine are represented by Donald C. Schultz, W. Ryan Snow and Steven Stancliff of Crenshaw Ware & Martin PLC and Jeffrey K. Sherwood, Kenneth W. Brothers, Dawn Albert and Frank Cimino Jr. of Dickstein Shapiro LLP.
Google, Target,, IAC and Gannett are represented by Stephen E. Noona of Kaufman & Canoles PC and David Bilsker and David A. Perlson of Quinn Emanuel Urquhart & Sullivan LLP. AOL is represented by Robert L. Burns and Cortney S. Alexander of Finnegan Henderson Farabow Garrett & Dunner LLP and Stephen E. Noona of Kaufman & Canoles PC.
The case is I/P Engine Inc. v. AOL Inc. et al., case number 2:11-cv-00512, in the U.S. District Court of the Eastern District of Virginia.
--Editing by Elizabeth Bowen.
SOURCE: http://www.law360.com/ip/articles/469126
The patents may not be worth much now, but they very could well be worth a lot later.
In particular, take note of the '983 patent. Here is what I wrote three months ago on the subject:
I just drew a map of the forest for you in my previous post. I recommend people read it carefully. Hopefully that will help some of you from continually running into trees.
Not to crush your dreams, but there are some facts everyone should consider before blindly accepting that the 6 patents from MSFT are significant:
(1) the patents are not currently earning any revenue
(2) the patents are not currently the subject of any enforcement action or litigation
(3) patents usually take years to monetize
(4) these patents were never monetized while owned by MSFT, thus opening the door to certain specific defenses to anyone VRNG litigates against
and... the biggie...
(5) The Hart-Scott Rodino Antitrust Improvements Act of 1976 (“HSR”) and related rules require that all acquisitions of voting securities or assets exceeding a threshold amount be reported to the Federal Trade Commission (“FTC”), as well as the Antitrust Division of the Department of Justice. The current threshold is $68.2 million.
Although the statute and rules are silent on the subject, the FTC staff has consistently taken the position that a sale or assignment of a patent is an asset sale subject to reporting if the dollar threshold is exceeded. Likewise, an exclusive license that conveys all significant rights under the patent also is reportable... LINK
I ask you, have you seen anything to indicate that either VRNG or MSFT have filed reports to the FTC or the DOJ? Neither have I.
Not exactly. The provision in the agreement clearly states there is a limitation on Microsoft’s total liability.
(1) MSFT has paid VRNG $1 million and transferred 6 patents. This will never change. It is done.
(2) MSFT also have agreed to pay VRNG five percent (5%) of any amounts Google pays for use of the patents. But the 5% is capped at a certain undisclosed threshold.
Based on the wording of the 8K (LINK), we can assume it somewhere higher than the jury's award.
<< The parties also agreed to a limitation on Microsoft's total liability, which would not impact the Company {Vringo} unless the amounts received from Google substantially exceed the judgment previously awarded. >>
MSFT will pay 5% of what GOOG pays up until a certain amount when MSFT will have reached it's maximum liability. That maximum number could be $40 million, $100 million, we don't know.
What we do know is the cap is not good for VRNG. What we also know is that the cap won't mysteriously disappear like some pumpers have previously said. The cap exists and VRNG agreed to it.
This conversation is backwards. It's also wishful thinking.
"The parties also agreed to a limitation on Microsoft’s total liability, which would not impact the Company unless the amounts received from Google substantially exceed the judgment previously awarded."
The Company in bold above is VRNG. The cap, or maximum amount MSFT will have to pay does not change. It is a fixed, finite limit.
The wording "would not impact the company" means the cap is set at a level so as not to become an issue unless VRNG somehow collects a lot more than $30 million. In that case, VRNG is impacted because it will not collect 5% from MSFT for anything above the agreed upon level.
Some of you folks are extremely biased by your options positions and it impacts your thinking. This is patent licensing 101. Maximum thresholds and liability limitations are not going to change.
Ask yourself one basic question: What would be the point of putting in a royalty cap in the first place if it was just going to be adjusted upward? LOL. This board is comedy.
today's updated filings are all online
#981: docs.justia.com/cases/federal/district-courts/virginia/vaedce/2:2011cv00512/271949/981/
#980: docs.justia.com/cases/federal/district-courts/virginia/vaedce/2:2011cv00512/271949/980/
#979: docs.justia.com/cases/federal/district-courts/virginia/vaedce/2:2011cv00512/271949/979/
#978: docs.justia.com/cases/federal/district-courts/virginia/vaedce/2:2011cv00512/271949/978/
You can follow the entire case here: http://dockets.justia.com/docket/virginia/vaedce/2:2011cv00512/271949/
BookMark it.
Yes, it is a system. And with Lang on board (and Kosak just a phone call away) there is no way GOOG can get away with under-delivering... as we have seen with today's reported PACER filings.
Good times.
All these references to the term "source code".
Gotta love it.
Thanks for the updates JJ.
I can't wait to hear GOOG's reply and see how the court handles this.
Great find, JJ. This history, in particular GOOG's refusal to allow Mr. Alferness or anyone else to testify to the multiple (alleged) workarounds, is rather telling.
Let me help you refresh your memory:
PACER 767: DEFENDANTS’ MOTION FOR JUDGMENT AS A MATTER OF LAW OF LACHES
Enjoy!
Thx for the correction. That whispering technique seems to be a winner. I'll try to incorporate that one day in a future post.
Cheers
Black Hills--
Some folks like to vent. LOL. Too bad for some that reality doesn't align with emotional rants.
A+ for rhetoric, F for facts
emotions + investing = fail
We could see a ruling on this (supp. damages, pre-, & post-judgment interest) at any time...
but based on the track record of this particular court, I doubt anyone is seriously "expecting" anything "soon". -;)
Like the jury award(s), VRNG will not instantly receive any supplemental damages and pre- & post-judgement interest from GOOG. These rulings will most likely be challenged and make their way to the Federal Circuit. NOTE: Per docket #932, GOOG is not required to post a supersedeas bond because nobody is worried about its cash position.
"2. The parties have agreed to stay any proceeding to execute or enforce the Judgment against Defendants pending resolution ofthe related pending appeals (Case Nos. 13-1307 and 13-1313), and for thirty (30) days thereafter."
BTW..the patent lawyers have spoken about the lack of documentation this morning. Once again proving that the board can choose to either trust the expert opinions provided free of charge several days earlier (such as when you posted message 41769 last Thursday, clearly stating the possibility of "seeing nothing")... or wait the requisite amount of time to realize the same individuals are consistently correct about nearly everything they post.
__________________________________________________________________________
Adam Gill (former patent litigator): "The Court ordered that documents be 'produced' by August 25. Document productions are NOT filed, and would not show up on PACER. Neither will the expert reports, by the way."
__________________________________________________________________________
Markman Advisors (allegedly a group of USPTO-registered patent attorneys): "Adam Gill is correct. Documents will not show up on Pacer and will be produced directly to Vringo. They will be controlled by the Protective Order. Here is the actual order:
'August 25, 2013 - The parties must produce any documents relevant for determining whether New AdWords is no more than a colorable variation of the adjudicated product. Any additional discovery is limited to three (3) depositions per side, including expert witnesses.'
Deposition notices will not appear on Pacer either."
GOOG's numbers all summarized HERE:
Dr. Ugone's numbers (From #974):
__________________________________________
Apportioning the total revenues for the October 1, 2012 to November 20, 2012 using the 2.8% apportionment factor and applying the 3.5% royalty rate yields total supplemental damages of $2,249,777. Supplemental damages associated with each Defendant are shown in the table below; the details of my calculations are provided in Exhibit 1.
I/P Engine's Supplemental Damages
Google $2,120,939
AOL $42,390
Gannett (USA Today) $18
IAC $84,387
Target $906
AOL Search Marketplace $1,138
---------------------------------------
Total $2,249,777
Prejudgment Interest Calculation - using Prime Rate
Google $278,538
AOL $140,027
Gannett $76
IAC $117,233
Target $1,742
---------------------------------------
Total $537,616
Prejudgment Interest Calculation - U.S. Treasury Rate
September 15, 2011 – November 20, 2012
Google $15,178
AOL $7,630
Gannett $4
IAC $6,388
Target $95
---------------------------------------
Total $29,296
Post-judgment Interest Calculation
Google $22,889.43
AOL $10,200.41
Gannett $5.54
IAC $8,602.34
Target $127.40
AOL Search Marketplace $1.45
---------------------------------------
Total $41,826.58
In reviewing the direct workaround discussion back in April (direct emails back and forth between GOOG's and VRNG's lawyers) I found a nice reference for the exact term "source code". Just something noteworthy considering all the armchair QBs who were challenging the linguistics used to reference the workaround technology. Also it is rather revealing the method the parties use to communicate when dealing with this type of discovery, illustrating why we should not expect an electronic document to be filed every time the parties take steps to be in compliance with the court's workaround-related schedule:
SOURCE for the above: http://docs.justia.com/cases/federal/district-courts/virginia/vaedce/2:2011cv00512/271949/925/
I think the window has passed. It popped up to 3.50+ in the premarket... and has high as 3.40 in the regular session...
before giving back most of those gains and trading in the $3.2X's.
These kind of short-lived "newsless" uptick moves are unlikely to change most options pricing models so the best way to play it was to sell shares early and buy back 20 cents lower. Or short it outright and cover quickly.
Or in my case, sell at $3.39 near the open and buy back the same shares at a shade under $3.30. Because even though the move seems to be based on misinformation/misunderstanding of this case's specific workaround compliance process... there are other sparks that can appear from the same fire at a moment's notice.
Sab, no doubt about it -- from a risk/return perspective VRNG is looking really good right now (especially when compared to earlier this year).
But investors still have to patiently wait for the workaround vetting process to conclude on its own schedule. Cheers!
That's a terrible headline. It should have read:
Vringo ticks higher because novice traders/investors expected documents to appear regarding Google's alleged workaround even though these type of compliance activities usually do not result in public document filings that can be accessed on PACER
with a follow-up story 30 minutes later:
Vringo gives up previous early gains as savvy market participants take advantage of over-exuberant amateurs
You were right them and you are correct now as well.
If VRNG investors want to know why they get such a bad rap (i.e., they are considered the Walmart shoppers of the patent supermarket world) look no further than this issue.
No, probably nothing will post on Pacer. While it is possible, it is not probable. See my previous post.
A big mountain is being made out of a mole hill. Lack of visibility on compliance, data transfer, and anything else related to the alleged workaround means nothing.
We'll get more info when we get more info. For now, everyone should assume both parties are in compliance with court's schedule. Regardless of PACER documents or lack of them.
Hint: Go research either of the recent cases VHC/AAPL or AAPL/Samsung to see what workaround docs showed up on PACER.
Yes, there is no need to host the PDF files yourself when the good folks at archive.org do it for us!!
Providing the text is a great service, so thanks again for doing that consistently for so long. Some people are anal like me and like to collect and read every docket in PDF.
PACER 971: PDF version
PACER 973: PDF version
That's an important clarification and I agree with your assessment. Past damages are different from ongoing royalties, and supplemental damages are an extension of past damages.
Even if the judge rules against IPE on supplemental (20.9%), which I do not believe he will, the future still looks good with the higher apportionment percentage. Of course, the monkey wrench is the alleged workaround... speaking of which, is your Pacer still firing tonight?
PACER 974: DECLARATION OF KEITH R. UGONE, PH.D. IN SUPPORT OF DEFENDANTS' RESPONSE TO PLAINTIFF I/P ENGINE, INC.'S NOTICE OF CALCULATION OF SUPPLEMENTAL DAMAGES, PREJUDGMENT INTEREST, AND POST-JUDGMENT INTEREST
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
NORFOLK DIVISION
I/P ENGINE, INC.
Plaintiff,
v.
AOL, INC., et al.,
Defendants.
Civil Action No. 2:11-cv-512
DECLARATION OF KEITH R. UGONE, PH.D. IN SUPPORT OF DEFENDANTS'
RESPONSE TO PLAINTIFF I/P ENGINE, INC.'S NOTICE OF CALCULATION OF
SUPPLEMENTAL DAMAGES, PREJUDGMENT INTEREST,
AND POST-JUDGMENT INTEREST
Case 2:11-cv-00512-RAJ-TEM Document 974 Filed 08/26/13 Page 1 of 10 PageID# 23878
1
I, Keith R. Ugone, Ph.D., declare as follows:
1. I submitted an expert report and provided oral testimony at trial in this matter on
behalf of Defendants Google Inc., AOL, Inc., IAC Search & Media, Inc., Gannett Co., Inc., and
Target Corp. ("Defendants"). I described my qualifications in both my trial testimony and expert
report. I have personal knowledge of the facts set forth in this Declaration. If called upon to
testify, I could and would certify competently to these facts.
2. I have been asked to provide certain calculations in support of Defendants'
Response to Plaintiff I/P Engine, Inc.'s Notice of Calculation of Supplemental Damages,
Prejudgment Interest, and Post-Judgment Interest.
Supplemental Damages
3. I have been asked to calculate I/P Engine's supplemental damages for the time
period from October 1, 2012 to November 20, 2012 using the 3.5% royalty rate awarded by the
jury and the 2.8% apportionment factor I derived previously based upon the damages awarded by
the jury. My derivation of the 2.8% apportionment factor (based upon the jury's damages award)
is explained in the declaration I submitted on November 29, 2012 and is repeated below for
convenience.
4. In response to an interrogatory, the jury found that the appropriate form of
damages was a running royalty and set the royalty rate at 3.5%. (D.N. 789, 11.) The jury
awarded total damages of $30,496,155, attributed as follows: Google - $15,800,000, AOL-
$7,943,000, IAC - $6,650,000, Target - $98,833, and Gannett - $4,322. (Id.) Plaintiff asserts
that 20.9% of the revenues for the accused products is the appropriate royalty base to which the
Case 2:11-cv-00512-RAJ-TEM Document 974 Filed 08/26/13 Page 2 of 10 PageID# 23879
2
3.5% royalty should be applied (D.N.793, 11), but the amounts the jury awarded do not equate to
a royalty base apportioned at 20.9% of revenue. I was informed that the only information
Plaintiff provided the jury for the relevant damages period was a demonstrative slide (i.e., a "bar
chart") that Dr. Becker discussed in relation to a damages period barred by laches (D.N. 807 ¶ 2
& Ex. B (PDX-441)), and that in closing argument, Plaintiff used the slide to display a royalty
amount in the recoverable period that was derived from its 20.9% apportionment of revenue
multiplied by its 3.5% royalty. I have reviewed PDX-441. Based upon the "bars" presented
from third quarter 2011 through third quarter 2012, the height of each bar appears to reach
between approximately $25 million and $29 million (as determined from a rough comparison to
the scale on the left hand side of the chart). The jury awarded total damages from Google of
$15,800,000. (D.N. 789, 11.) This award was based upon a 3.5% running royalty rate. (Id.)
Using the information from the slide covering the allowable damages period and accounting for
the 3.5% royalty rate yields an apparent apportionment value of approximately 2.8%.
Specifically, the 2.8% estimated apportionment percentage is derived as follows. (I previously
provided the details of my estimation at D.N. 806-2.)
(a) The demonstrative exhibit that Plaintiff displayed for the allowable damages
period (i.e., damages period beginning September 15, 2011) showed a claimed
damages amount of approximately $118 million. (Trial Tr. 2005:13-2008:24;
D.N. 807 at ¶ 2 & Ex. B (PDX-441).)
(b) The jury's award of $15,800,000 is approximately 13.4% of the total royalties
Plaintiff demanded against Google for the allowable damages period (i.e., $15.8
million divided by $118 million).
Case 2:11-cv-00512-RAJ-TEM Document 974 Filed 08/26/13 Page 3 of 10 PageID# 23880
3
(c) Given the relative magnitude of the jury damages award and Plaintiff's claimed
damages, the royalty base apportionment percentage based upon the jury verdict
is 2.8% (i.e., 13.4% multiplied by the 20.9% apportionment percentage demanded
by Plaintiff).
5. Revenue information for the time period from October 1, 2012 to November 20,
2012 has been provided for AdWords, AdSense for Search, AdSense for Mobile Search, and
AOL Search Marketplace. It is my understanding that the total revenues provided for AdSense
for Search include revenues associated with Google's AdSense for Search partners and codefendants
AOL, Gannett / USA Today, IAC, and Target. However, revenue information
specific to each co-defendant also was provided for the time period from October 1, 2012 to
November 30, 2012. In order to calculate I/P Engine's supplemental damages specific to each
co-defendant, it was necessary to prorate the revenue amounts provided for the co-defendants to
reflect the appropriate supplemental damages period (i.e., October 1, 2012 to November 20,
2012). Further, in both my calculation and I/P Engine’s calculation, to avoid double counting
(because Google’s AdSense for Search revenues include revenues associated with the codefendants),
co-defendants’ damages are subtracted from Google’s damages to yield the
damages specific to Google, net of the co-defendants.
6. Apportioning the total revenues for the October 1, 2012 to November 20, 2012
using the 2.8% apportionment factor and applying the 3.5% royalty rate yields total supplemental
damages of $2,249,777. Supplemental damages associated with each Defendant are shown in
the table below; the details of my calculations are provided in Exhibit 1.
Case 2:11-cv-00512-RAJ-TEM Document 974 Filed 08/26/13 Page 4 of 10 PageID# 23881
4
I/P Engine's Supplemental Damages
October 1, 2012 – November 20, 2012
Google $2,120,939
AOL $42,390
Gannett (USA Today) $18
IAC $84,387
Target $906
AOL Search Marketplace $1,138
Total $2,249,777
Prejudgment Interest
7. I have been asked to calculate prejudgment interest in this matter using both the
prime rate and U.S. Treasury rate and compounding quarterly. Throughout the time period from
September 15, 2011 to November 20, 2012, the prime rate was 3.25%.
8. The methodology that I employed in deriving my prejudgment interest calculation
is as follows.
(a) I allocated the jury's royalty damages award to the quarters between September
15, 2011 and September 30, 2012 using the number of days in each quarter
relative to the number of days in the entire time period.
(b) I assumed that these quarterly royalty amounts would have been paid at the end of
each quarter, which would be in line with the likely arrangement of royalty
reporting and payment in a real-world business situation.
9. Using this methodology, I calculated the prejudgment interest that would be due
on the damages awarded by the jury from September 15, 2011 to November 20, 2012 to be
$537,616 using the prime rate compounded quarterly pursuant to the Court's instruction. Using
the U.S. Treasury Rate, the corresponding amount would be $29,296. The results of my
Case 2:11-cv-00512-RAJ-TEM Document 974 Filed 08/26/13 Page 5 of 10 PageID# 23882
5
calculations are presented in the tables below; the details of my calculation are provided in
Exhibit 2.
Prime Rate
Prejudgment Interest Calculation
September 15, 2011 – November 20, 2012
Google $278,538
AOL $140,027
Gannett $76
IAC $117,233
Target $1,742
Total $537,616
U.S. Treasury Rate
Prejudgment Interest Calculation
September 15, 2011 – November 20, 2012
Google $15,178
AOL $7,630
Gannett $4
IAC $6,388
Target $95
Total $29,296
Post-Judgment Interest
10. I have been asked to calculate post-judgment interest in the manner set forth in 28
U.S.C. § 1961(a) ("from the date of the entry of the judgment, at a rate equal to the weekly
average 1-year constant maturity Treasury yield, as published by the Board of Governors of the
Federal Reserve System, for the calendar week preceding the date of the judgment") on the sum
of (a) the damages awarded by the jury, (b) I/P Engine's supplemental damages, and (c) the
prejudgment interest amounts shown above.
Case 2:11-cv-00512-RAJ-TEM Document 974 Filed 08/26/13 Page 6 of 10 PageID# 23883
6
11. The average 1-year constant maturity Treasury yield for the week ending
November 16, 2012 was 0.17%. The results of my calculation of post-judgment interest are
presented in the table below; the details of my calculation are provided in Exhibit 3.
Using Prime Rate for
Prejudgment Interest
Using Treasury Rate for
Prejudgment Interest
Post-Judgment
Interest Per Day
Post-Judgment
Interest Accrued
as of 8/21/2013
Post-Judgment
Interest Per Day
Post-Judgment
Interest Accrued
as of 8/21/2013
Google $84.76 $23,225.52 $83.54 $22,889.43
AOL $37.84 $10,369.37 $37.23 $10,200.41
Gannett $0.02 $5.64 $0.02 $5.54
IAC $31.91 $8,743.79 $31.40 $8,602.34
Target $0.47 $129.51 $0.46 $127.40
AOL Search
Marketplace
$0.01 $1.45 $0.01 $1.45
Total $155.02 $42,475.28 $152.65 $41,826.58
12. I declare under penalty of perjury that the foregoing is true and correct.
____________________
Keith R. Ugone, Ph.D.
Read more: http://vringo.freeforums.net/thread/2243/docket-974-ugones-support-973#ixzz2d8N1QItR
I got the excerpts from recentiy03 who posted 973 & 974 on another MB. I will post 974 so you two won't have to...
They really do appear to be setting themselves up... especially in light of the Court's recent published orders relating to and referencing the 20.9% apportionment base... nevertheless, this (pre+post+supp damages) is the smallest of all the fights so we'll see