Previous "benchmarks" were not met, and I believe that if anything, the Joint Plan "benchmarks" will be even less. As I intuit the Joint Plan, it's success is based more on quantity of licenses and constant cash flow to the system and creditors, than it is on the quality of the recovery effort or how fully/accurately valued the infringment damages recovery is.
Benchmarks didn't seem to help before
Per Gloria Felcyn's own declaration ... "....Leckrone wrote... licensing transactions that appear to be so low that they were outside of the licensing criteria that the parties have agreed upon under the terms of their Commercialization Agreement"