<It is inconceivable to me that TPL/Alliacense/PDS would sue Barco for infringement without having first reverse-engineered the chip(s) in question and knew for certainty that Barco was infringing on the MMP>

You must have missed the post in which I said I agree with that statement.

The question I was posing was whether every bit of reverse engineering/testing was done prior to the initial notification of infringement. And I don't profess to know the answer. My opinion was based on my thinking that it may not be necessary and hence, avoidable. If avoidable, just do it where necessary as part of the subsequent license negotiations.

But as you and others point out, certainly before issuing a summons or immediately after receiving one, all the required tear downs, reverse engineering and testing should be done, to the extent that it can be. I say to the extent it can be, because I don't know if it is possible to know everything w/o getting information from the infringer or the manufacturer.

If we already have all the tear downs, reverse engingeering and testing of HTC's chips, why are we demading we obtain source code and other tech info from them? Are we just trying to be a pain in the ....? Or is it possible that at this late stage, we still can't be certain with respect to HTC's chips?

FWIW,

Opty