No reason for NeoMedia's attorneys to "guess", it is all part of discovery.
And in your prior post #189254, you say "Under your scenario, Scanbuy gets access to at least part of NeoMedia's IP, but NeoMedia gets no IP from Scanbuy". Actually under jcg's scenario I believe NeoMedia neither would Neither Need, nor Want, IP from ScanBuy. I know, different than your view of things here, as always.