P. 56 of 88 see Disclosure Statement

http://photos.imageevent.com/banos/tplbk/Disclosure%20Statement%20Re%20Joint%20Plan%20of%20Reorganization%20by%20Official%20Committee%20of%20Unsecured%20Creditors%20and%20Debtor%20Filed%20by%20Debtor%20TPL%209-17-14.pdf

Patriot contends that any controversies arising out of the PDS-Alliacense Agreement must be resolved prior to and as a condition of confirmation, and That certain controversies still exist arising out of obligations under the PDS-Alliacense Agreement, including the following: (1) obtaining TPL’s approval of a second MMP licensing company as appointed by PDS, and (2) appointment of a third PDS Manager. Patriot also contends that upon accomplishment of the former obligation, the PDS-Alliacense Agreement provides that Alliacense is obligated to deliver the lists of prospective licensees to be considered (and associated work product) to PDS