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