if so, maybe that is why he has a seat on PDS in lieu of Leckrone. If not in lieu of Leckrone, then perhaps there will be a cancellation of arbitration if Swamy is the 3rd member.

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2. Venkidu.

Mr. Venkidu, TPL and other parties entered into a security agreement in April 2006 (the “Venkidu Security Agreement”), which related to a multi-party transaction including TPL and resulted in TPL obtaining certain rights with respect to a group of patents known variously as the

"CORE Flash Portfolio" or the MCM Patent Portfolio .

Under the Venkidu Security Agreement, Mr. Venkidu was granted a security interest in the CORE Flash Portfolio. Mr. Venkidu recorded UCC-1 financing statements with the California Secretary of State of California and claims thereby to have perfected his security interests in the CORE Flash Portfolio and proceeds therefrom. Financing Statements were recorded in 2006 and, following expiration, again on April 12, 2012. During the Bankruptcy Case, the Court approved the granting of a security interest in the MMP Portfolio as additional adequate protection of his prepetition security interest.

As of the date of commencement of this case, the debt claimed owing to Mr. Venkidu was approximately $5.2 million. The Committee believes that no security interest attached to any asset of the Debtor given that no consideration was given by TPL in exchange for the grant of a security interest. Further, the Committee believes that the obligation is that of Mr. Leckrone, as primary obligor under the OnSpec Merger Agreement, and that TPL is only the guarantor of Mr. Venkidu’s

claim against Mr. Leckrone. The Committee believes that these facts, among others, may constitute grounds on which to challenge the validity, priority and amount of this security interest.

Disclosure statement of Creditors Committee 12-17-13 p. 15