Take good note of each of the 12 items in the list to see how assets were moved out of TPL. Why would they seek release and exhoneration from these items, and take the time to describe each one, unless they felt a serious risk of legal action?

NOTE: there is differentiation between Owner of the Intellectual Property (i.e. the patents) and Owner of the Licensing Rights. Right now I must admit I am not sure actually owns the MMP IP. I thought it was PTSC and Chuck Moore, 50/50, with TPL having (originally) full licensing rights. Then PDS was created to combine the licensing rights.

I wish I knew how to get the final versions of all these documents...

ORDER CONFIRMING JOINT PLAN OF REORGANIZATION BY OFFICIAL COMMITTEE OF UNSECURED CREDITORS AND DEBTOR

(DATED JANUARY 8, 2015)

In the Joint Plan of Reorganization:

" “IP Owners” means the owners of the MMP Portfolio, CORE Flash Portfolio, Fast Logic Portfolio and Chipscale Portfolio licensed by TPL to Licensees, including without limitation PDS, Patriot, Charles H. Moore, and MCM Portfolio LLC."

Note: TPL is not identified as an IP Owner, but PDS is, as well as PTSC and Chuck Moore.

In the Disclosure Statement of January 8. 2015:

EXHIBIT F

Under the Joint Plan, Daniel Leckrone, his family members, his business associates and the entities that he owns (including Alliacense) will be released and exonerated as of the Effective Date of the Joint Plan from any and all liability in connection with each and all of the following bases for possible claim (such release and exoneration to be final and unconditional except in the event of subsequent conversion this case to Chapter 7, in which event any release or exoneration shall be withdrawn and deemed void, with a tolling of any applicable statute of limitations from the date of filing of this bankruptcy case to and through the date of such Chapter 7 conversion):

Note: The final, approved, Disclosure Statement is modified to delete the introductory paragraph, presumably just leaving the following list and referring to it from elsewhere..

1. Mr. Leckrone’s submission of the $4 million Leckrone Secured Claim for funds he allegedly loaned to Debtor TPL (such claim being allowed and subordinated under the Joint Plan and not subject to challenge)

2. The Leckrone family members’ submission of multi-million dollar Employee Compensation claims based upon oral contracts with Debtor TPL (such claims being allowed and paid under the Joint Plan).

3. The 2012 transfer of licensing rights to the MMP portfolio from Debtor TPL to Alliacense, a company owned by Mr. Leckrone, with no compensation or consideration provided to TPL, and with Alliacense gaining entitlement to 20% of gross MMP licensing revenues and to payment for "litigation support" services in TPL-funded litigation.

4. The transfer of the "OnSpec" portfolio patents from Debtor TPL to a Leckrone entity, with no compensation or consideration provided to TPL, and with TPL funding the Leckrone entity’s acquisition of the patents.

5. The transfer of the "Fast Logic" portfolio of patents from Debtor TPL to a Leckrone entity, with no compensation or consideration provided to TPL, including with limitation any and all liability for

• (1) a TPL guarantee of a Leckrone entity payment for the patents, and payment of TPL funds to the seller when the Leckrone entity did not or could not make such payments;
• (2) TPL-funded Fast Logic litigation in which the Leckrone entity is receiving a portion of settlement proceeds without payment of litigation expenses;
• (3) retention of the Leckrone entity Alliacense for litigation support in that litigation;
• (4) exposure of Debtor TPL, in the event of loss at trial of claims not settled in that litigation, to a prevailing party attorney’s fee award.

6. The transfer of the "Chipscale" portfolio of patents from Debtor TPL to Mr. Leckrone, with no compensation or consideration provided to TPL, although TPL is liable for the purchase price and litigation settlement costs resulting from such transaction.

7. The transfer of the "Array Portfolio" patents from Debtor TPL to a Leckrone entity, with no compensation or consideration provided to TPL.

8. Debtor TPL’s transfer of $15 million, more or less, from TPL to Mr. Leckrone’s company Alliacense, in the absence of invoice or explanation for the purpose of such payment, at or about the time of Mr. Leckrone’s $4 million loan to TPL, providing the basis for the Leckrone Secured Claim.

9. Debtor TPL’s other payments to and reimbursements of Alliacense for litigation support and other purposes.

10. Any use of TPL funds or assets toward the purchase of the "Sandhurst" property outside of London, England, which property has been the home of former TPL employee Janet Neal and which property is being sold without provision for payment of any funds to Debtor TPL.

11. Post-petition payments to Alliacense or to Mr. Leckrone of substantial portions of revenues realized from non-MMP licensing, under claim of commission, expense reimbursement or other rationale for such payments.

12. Any accounting of TPL expenditures (over $60 milllion) on the failed IntellaSys venture.