<Plaintiff Moore remains ignorant of the licenses issued on his MMP Portfolio, the gross revenues received, the amounts paid to PTSC, the amounts received by TPL and Alliacense and the legitimate expenses that TL and Alliacense may be entitled to deduct in determining the ComAg royalties due to Plaintiff Moore.>

If the above is true of the past, how does Moore determine the future? Wouldn't Moore need to know how many potential licensees are out there? How does he estimate future revenues? He claims not to know what they were in the past, and even if he knew, do we think the average license values will be the same in the future? How does he estimate legit expenses? He claims not to know what they presently are and the future expenses could be substantially different.

At least the past is a fixed number of licenses on which he can make an estimate based on what has been reported. Personally, I think it would be easier to make an estimate based on the past than to estimate the future essentially out of thin air.

Of course, there is the possibility that Moore knows more than he lets on. I'm assuming he would not claim to know nothing and then make an estimate about the future which requires he knows even more than what he discliams knowing. But that is only my opinion.

Opty