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Message: To Carl Johnson

According to Leckrone,PDS does not have sufficient information to opine as to whether PDS could terminate Alliacense, find a replacement and increase recoveries to the Creditors Trust from the MMP. Since only you and Leckrone make up the management committee of PDS, I do believe he is directing this at you and you alone.

Let me help you out.

Here is the name of a firm that might replace Alliacense.I have written about this firm on this message board before.I believe this is an Otteson client (re: ITC).

http://www.pragmatus.com/Patent_Enforcement_Alexandria_VA.html

p.76 of 96

The Services Agreement in effect between Alliacense and PDS entitles Alliacense to terminate it for cause and/or convenience, but contains no reciprocal entitlement for PDS. Unilateral termination of the Services Agreement by some future iteration of the PDS board could constitute a breach of contract giving rise to substantial liability on behalf of PDS, including past and future contingent fee entitlements with respect to MMP portfolio licensing and litigation. PDS does not have sufficient information to opine as to whether PDS could terminate Alliacence, find a replacement and increase recoveries to the Creditor Trust Trustee from the MMP Portfolio beyond the damages its breach might generate.

(emphases by me)

http://photos.imageevent.com/banos/tplbkplan21414/DISCLOSURE%20STATEMENT%20RE%20TPL%20PLAN%20OF%20REORGANIZATION%202-14-14.pdf

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