unable to fully identify and/or compute its damages at this time, as much of the information

necessary to compute damages is in the sole possession of the Defendants. Plaintiff currently

estimates that it is entitled to no less than a royalty in an amount sufficient to compensate

Plaintiff for its damages suffered as a result of the Defendants’ infringement of the ‘774 Patent

and the ‘737 Patent and a recovery of its attorneys’ fees and costs.

e