InterDigital Inc (IDCC)

[sjratty]

Nokia's arguments:

The entire substantive portion of Nokia's memo is filed under seal. All that is publicly available are the headings to the sections, the cases cited and the conclusion. The headings say that the panel

exceeded their authority in rewriting the major competitors clause

exceeded their authority in rewriting the sequential tender provisions

exeeded their authority in rewriting the rate setting clause

impermissibly punished Nokia for exercising its right to arbitration; and

exceeded their authority by removing the implied covenant of good faith and fair dealing and the Most Favored Licensee clause from the PLA.

It also says that the award contains "other errors" that increase Nokia's royalty obligations and should be vacated.