"I estimate more than 75% of the total suits will be tier 1 type. Somewhat easier to prove than the more complicated tier 2."

FWIW....

IMO, they are gathering information and having it detailed for the record through tier 1 issues......ie "phase 1"(technical details) of a 2 phase discovery process.

They will not be starting from scratch with the tier 2 process.

doni