COMPUTATION OF DAMAGES
: Plaintiff recently commenced discovery in this case and, therefore, is
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.
