The income from Patent settlements is shown in the Income Statement as Patent License Revenue.

The amount going to DM (their 40% share plus expenses) is shown under Cost of Revenue as Patent Expense.

The net amount is shown as Gross Profit.

I see no reason to establish a divison for tax purposes. The company loss over the years, whcih would receive tax benefits is with e.Digital, the Corporation.

Divisions are rarely set up for tax benefits, if so then they would have to be a legal entity such as a subsuduary. Normally they are established to separate product lines, or other operational characteristics.

I suggest you review the Quarterly and Annual reports, the Balance Sheets and Income statements, and many of the written documentation in the reports.