agree. Not even looking at the infringement aspect. Also, I was not tripling the sanctions. I was just putting the sanction potential at $100M (up to Kaplan). NDA disclosure damages at $100M if V can show that it hurts their negotiation position with other potential licensees (V has been requested to lay out the damages by Kaplan). Suspecting it was a willful disclosure of the NDA, then V could get a multiple on the damages. I am guessing triple the damages, $300M, for a total of $400M. Z still need to settle with V on using the essential patents and I put that at $500M+ of the life of the patents. So, I think it could get to $1B especially with all of Z's boo boos with Kaplan.
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