COLLATERAL VALUE AND DEBT STRUCTURE

TPL has listed in its Schedules a value for its assets of $4,429,183.31; this total however excludes claims, rights, and general intangibles whose value is presently impossible to estimate precisely. Assuming that TPL’s various patent portfolios can be fully commercialized through licensing programs for clients and infringement suits against violators over time, TPL contends that its assets are worth well in excess of $100 million.

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22. Without approval to use cash, TPL will lose its general liability insurance and may cause certain patents to expire, causing TPL to be in breach of the agreeements pursuant to which it is entitled to commercialize those patents and would likely cause the termination of those agreements.Additionally US Trustee fees would go unpaid.

p.15 of 16 Declaration of Daniel Leckrone in support of Fourth Motion

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