Milestone, I am hoping for 3 times those amounts as well, but IMO it is too complicated to calculate. IMO, any #’s thrown out at this time is purely SWAG.  I 100% agree that you do have to factor in the additional products which infringed since the first J's settled, and include the costs incurred plus the penalty of protracting the litigation, but IMO, it is even more complicated than that.

Since settling is all about negotiation, IMO, to come up with an educated SWAG, one would have to be able to perform the following as well.

(1)   Calculate the influence that the pending patent litigation has on the settlement #’s (if any).

(2)   Calculate the influence of the “584 being removed from this case has on the settlement #’s (if any).

(3)   Understand how the Fujitsu, Sony, and NEC #’s were calculated, meaning, what % of their products were identified as infringing on the MMP, and what were the revenue $$$ generated by those products?  

(4)   What was the % discount given to the licensees mentioned above since they were considered “first movers”.

(5)   Understand the products produced by the remaining J’s that infringe, and how much revenue $$$ they account for.

(6)   Lastly, take everything into consideration, including your important points, and calculate a settlement $$$ number.

I am sure I have missed something, but I can’t even complete the above. This is why I have so much appreciation and respect for our boys and girls over at TPL. IMO, they are the reason we are still in this game. Good luck to you, me, us, and all longs.