`Case: 1:16-cv-06942 Document #: 20 Filed: 10/20/16 Page 1 of 3 PageID #:247
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`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`T—REX PROPERTY AB,
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`Plaintiff,
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`v.
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`QUALITY SYSTEMS TECHNOLOGY, INC.
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`Defendant.
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`Case No.: 1:16-cv-6942
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`Judge Sara L. Ellis
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`
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`SUPPLEMENTAL DECLARATION OF MATS HYLIN IN SUPPORT OF
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`MEMORANDUM SUPPORTING MOTION FOR ENTRY OF DEFAULT AND
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`DEFAULT JUDGMENT AGAINST DEFENDANT QUALITY SYSTEM
`TECHNOLOGY2 INC.
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`1, Mats Hylin, having duly sworn on oath, state as follows:
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`1.
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`My name is Mats Hylin. 1 am a resident of Sweden and am over the age of eighteen
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`and competent to make this Declaration. This Declaration is based on my personal knowledge and,
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`if called upon to do so, I will testify that the facts stated herein are true and accurate.
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`2.
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`As of September 28, 2016, T-Rex Property AB (“T-Rex”) has entered into more
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`than 20 licenses related to United States Patent Nos. RE39,470 (the “‘470 Patent), 7,382,334 (the
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`“‘334 Patent”), and 6,430,603 (the “‘603 Patent”) or collectively, the “T-Rex Patents.”
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`3.
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`All of the licenses entered into by T-Rex related to the T-Rex Patents are lump sum,
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`fully—paid, non-exclusive licenses that include both a “paid in full to date” license to compensate
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`T-Rex for past infringement, and if applicable, a “going forward” royalty to compensate T-Rex for
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`future use of the technology covered by the claims of the asserted patents.
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`4.
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`For example, T-Rex has entered into three separate lump sum, fully—paid, non-
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`exclusive licenses of approximately $48,000, $130,000, and $190,000. T-Rex entered into such
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`MIA
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`
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`Case: 1:16-cv-06942 Document #: 20 Filed: 10/20/16 Page 2 of 3 PageID #:248
`Case: 1:16-cv-06942 Document #: 20 Filed: 10/20/16 Page 2 of 3 PageID #:248
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`licenses based in part on the amount of sales of the infringing instrumentalities and the
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`understanding that T—Rex could quickly finalize the licensing agreements.
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`5.
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`Based upon information and belief, Defendant was incorporated around August
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`2011 and had $150,000 sales revenue in 2015 according to a LexisNexis Experian Business
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`Report. As such, Defendant Quality Systems Technology, Inc. is believed to have been infringing
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`the T—ReX Patents since around August 2011, and believed to have reported annual sales revenue
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`of $150,000 in 2015 related to the infringement of the T—Rex Patents.
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`6.
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`Based on past licenses and the length of time that Defendant Quality Systems
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`Technology, Inc. is believed to have been infringing the T-Rex Patents, as well as T—Rex’s estimate
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`of the Defendant’s sales revenue, T-Rex would seek a “paid in full to date” license of at least
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`$50,000.00 from Defendant if Defendant was to seek a license at this time. This $50,000.00 would
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`compensate T-Rex for Defendant’s infringement to date.
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`7.
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`With respect to a license for future use of technology covered by the ‘603 Patent,
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`T-Rex seeks a 5% “going forwar ” royalty on revenues from sales transactions falling within the
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`scope of the claims of the ‘603 Patent. T-Rex is entitled to be compensated for Defendant’s
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`infringement of the ‘603 Patent to the extent that Defendant does not
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`immediately cease
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`infringement upon issuance of an injunction by this Court.
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`8.
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`A 5% royalty on revenue from sales transactions falling within the scope of the
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`claims of the ‘603 Patent from the date of this Court’s judgment until Defendant ceases further
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`infringement
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`is reasonable and will adequately compensate T-Rex for Defendant’s future
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`infringement of the ‘603 Patent.
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`Case: 1:16-cv-06942 Document #: 20 Filed: 10/20/16 Page 3 of 3 PageID #:249
`Case: 1:16-cv-06942 Document #: 20 Filed: 10/20/16 Page 3 of 3 PageID #:249
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`I declare under the penalty of perjury under the laws of the United States that the foregoing is true
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`and correct.
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`Executed on October 17, 2016
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`[4/7 7 A/
`Mats Hylin
`CZ /
`/S/
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`La)
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`