Phil, in the first complaint TMMI charged that an engineer named Jeff allegedly stole a copy of the code from DFI and gave it to Panik. In the amended complaint TMMI dropped that. Evidently they realized that this was just another fabrication from Simpson.
The Iterated lawyer's letter to TMMI happened in 1996. It will be in the defendant's evidence. I believe I remeber it as in the first response. There are so many defense documents that it may be in both responses.