1. Why hasn't Patriots' BoD filed its opposition to the TPL plan

2. Why hasn't Patriots' BoD filed its opposition to the Licensee defenders motion

3. In 2008 Carlton Johnson was aware that settlement consideration paid by TPL was more havily weighted in favor of its other portfolios and away from the MMP. Yet, at that time, his only action was to "ask questions for which he received no answers."

4. Why didn't Carlton Johnson exercise Patriot's right to arbitration in pursing the appointment of the third PDS manager. Again, all Johnson did was to "ask Leckrone to confer with him about appointing a third member." The provisions to appoint were there, Johnson knew what he could do and he chose to do nothing.

5. Since 2008 Patriot has had questions about payments made to TPL and lately Alliacense. Where has the oversight been....what in the heck has our highly paid forensic accountant director been doing all these years

From Johnson Declaration 12-16-13http://photos.imageevent.com/banos/tplbk1216172013/Declaration%20of%20Carlton%20Johnson_%20Jr.%2012-16-13.pdf

12. Beginning in September 2013, several of us at Patriot have had questions and concerns about Alliacense’s billings for certain litigation support matters

13. In addition, in connection with assessing Alliacense’s performance, I have asked Dan Leckrone to abstain. He has declined to respond. I have also asked Dan Leckrone on several occasions to confer with me about appointing a third member of the PDS management committee so that we can have the benefit of a tie-breaker vote because of his conflicts. The PDS Operating Agreement has provisions for that but he has ignored them. This has resulted in the current dynamic where PDS cannot make decisions unless he and I agree on them. I believe that PDS cannot pursue decisions in its best interests unless Dan Leckrone goes along with them, but he consistently places Alliacense’s interests ahead of PDS’s or TPL’s interests in our communications.

14. I was present for the trial HTC v. TPL, et al., in September–October 2013 in this District Court concerning our claims that HTC infringed on the ‘336 patent of the MMP portfolio. I heard Dan Leckrone testify that in the 2010 time frame TPL gave discounts to licensees who would simultaneously license MMP patents with TPL’s other, wholly-owned patent portfolios and that discounts were given because of TPL’s difficult financial condition. Patriot never authorized those actions.

From Johnson Declaration (my notes) from PTSC vs TPL

9. On or about December 17, 2008, I observed that PDS had approved payments to TPL to “reimburse” TPL for payments that (according to Mr. Leckrone) had been made to outside counsel handling the patent infringement litigation at that time, Townsend, Townsend & Crew (“Townsend”).I discovered later that Mr. Leckrone had not paid the Townsend firm the $500,000 as represented and called him on it.Mr. Leckrone eventually paid Townsend the $500,00 that had been wired to the TPL account approximately two months earlier.

In late 2008, I learned of negotiations underway between TPL and a third party leading to settlement of one of the patent infringement litigation matters.In that case the MMP portfolio was the primary focus of the litigation, but that defendant had also sued TPL for declaratory relief that it was not infringing on TPL’s core Flash patent portfolio, in which Patriot has no involvement.The case settled by negotiated terms of MMP and Core Flash patent licenses to the third party.During the course of that negotiation, I observed firsthand that the numbers changed such that the settlement consideration paid by that defendant became more heavily weighted in favor of the Core Flash portfolio and away from the MMP component.I asked questions about this of Mr. Leckrone and never received satisfactory answers.

11. Mr. Leckrone has made a number of representations of the “value” of the MMP portfolio.In general his position is that the MMP is worth $1,000,000,000 (One Billon U.S. Dollars).

12.I am particularly concerned by two licenses written by TPL in the first quarter of 2010 that appear substantially low in relation to the gross sales reported by those companies.The amounts of the licenses appear to be below the licensing criteria that we have agreed to with TPL under the Business Plan of the ComAg.