The $66M is the amount that PDS has listed as expenses for the MMP licensing program. In short it includes all costs related to licensing, litigating/prosecuting the patents in court and at the USPTO, and also costs for TPL to lobby on patent reform issues.

TPL/DL's legal costs for his battles with us, Moore, etc., should NOT be part of that but based on the weak effort of Gloria Felcyn, Carlton Johnson and Cliff Flowers in overseeing expenses charged to PDS as was exposed in the lawsuit against TPL, it wouldn't surprise me if DL snuck some of those costs in there with or without their knowledge / tacit acceptance.

All of the other items you list are either PTSC or TPL company expenses, not PDS/MMP licensing expenses, so no, they shouldn't be included in that number. PTSC expenses should be covered by the $2M number I listed that I believe opty allotted for in his original assessment. TPL's expenses have no bearing on the analysis.

Also, the discussion is on a foward looking basis, so including the Swartz divy expenses and such into this analysis is misguided and inappropriate.