A motion to dismiss is a reasonable suggestion but I still believe that court etiquette would dictate that it be the same as the motion to stay, joint. A dismissal with prejudice means that one side lost and it difficult to see either side agreeing to this, if as you suggest, the Defendants want to save face, without TPL/PTSC losing the case.

Obviously, for this to be the ultimate positve result for TPL/PTSC, the license fees have to be significant enough to validate the process and deter others from holding out (I think $50M per defendant MINIMUM and preferably at least $75M).

As there has been a settlement in excess of $30M, I'm not convinced that either of your suggested minimums will be "significant enough to validate the process and deter others from holding out". Both your figures indicate an early mover discount, in my humble opinion,and take no account of the potential triple damages that could be awarded at trial. To meet your criteria, I would expect not less than $300M, with $150M being PTSC's share. Perhaps the figures you give are the net receivables to PSTC?

Be well