You are mistaken about the ITC. A win at the ITC provides massive leverage at the negotiations table because the accused companies would not be able to import their products to sell in yhe United States. If said companies cannot sell their products, they will as a whole lose out on possibly billions of dollars in revenue, hence the ITC in many respects is more important than the NDoC, especially given there are more companies at the ITC. Finally, after speaking with Cliff last week, he in fact said the ITC can be more important. A company like PTSC is not dependent upon a jury to determine damages. The "damage" at the ITC is that they can't import products = more powerful. Hopefully this post will put that misunderstanding to bed. Lastly, I'm assuming our last ditch effort to reopen fact discovery to allow our opposition to the MSD is important to our position. Or, we are trying to hammer home a point to allow us to beat the MSD so we can present the information during trial. We need to beat this MSD. If we lose It won't be the end of the 336 IMO, but it makes future options more difficult.