This is the only information we have about TPL's arguement to the stay, taken from Judge Fogels ruling. Where is the complete response from TPL?

Wolfpackvolt - Did you ever find the complete TPL response document on Pacer??

TPL argues that this Court should not stay the instant proceedings because in fact it would suffer prejudice, primarily because its main revenue source is the licensing of its patents. TPL claims that staying the proceedings for several years to allow all of the reexaminations to be concluded would impact adversely its negotiations with potential licensees, causing it irreparable monetary and reputational harm. TPL also suggests that Plaintiffs are using the instant motion and reexamination proceedings as a delay tactic and an opportunity to “hedge their bets” by making the same arguments in litigation and during reexamination.