EXHIBIT 1 

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GLOBAL SETTLEMENT AND LICENSE AGREEMENT ty' � :r�Y\V ��-'1 l ,J

This Settlement and License Agreement (this "Agreement") is made effective as of A1.1gt1sH-6, 

201/C(the "Effective Date"), by and between, Display Technologies, LLC, a Texas limited 

liaoility company ("Display"), with a principal place of business at 1400 Preston Road, Ste. 400, 

Plano, TX 75093, and Leigh Rothschild ("Inventor") (Display and Inventor, collectively, are 

referred to as "Licensor"), on the one hand, and Valve Corporation ("Licensee"), a corporation, 

with a principal place of business at 10900 NE 4

th St., Ste. 500, Bellevue, WA 98004, on the 

other hand. The term "Parties" shall refer collectively to Display, Inventor, and Licensee and 

each, individually as appropriate, a "Party." 

WHEREAS, Display owns U.S. Patent No. 8,671,195, respectively entitled "Digital Media 

Communication Protocol," and has asserted that Licensee is infringing one or more claims of 

this patent through the sale of Licensee products; 

WHEREAS Display brought suit in the United States District Court for the Eastern District of 

Texas, Marshall Division, Civil Action No. 2:15-cv-999 (the "Pending Litigation"), regarding 

U.S. Patent No. 8,671,195; 

WHEREAS Licensee denies Display' s allegations of infringement; 

WHEREAS the Parties desire to minimize the time and expense of litigation and therefore desire 

to resolve the Pending Litigation on the terms set forth herein; 

WHEREAS Inventor controls Display, as well as a number of other entities that have been 

assigned all necessary rights to license patents on which Inventor is the named inventor; and 

WHEREAS the Parties desire to enter into a license agreement for patents assigned to entities 

controlled by Inventor, listed in Exhibit C attached to this agreement, including but not limited 

to the '195 patent assigned to Display; 

NO\V, THEREFORE, for good and valuable consideration, the receipt and sufficiency of which 

are hereby acknowledged, the Parties agree as follows: 

1. Definitions

The terms set forth below shall have the following meanings in the Agreement: 

1.1. "Affiliate" means, in relation to any Party hereto, any and all "Persons" (as 

hereinafter defined) now, at any time since the filing of the Pending Litigation, or 

in the future "Controlled" (the term "Control" and correlatives thereof shall have 

the meaning more particularly set forth herein) by, Controlling, or under common 

Control with that Party or any parent company of a Patty and any subsidiary 

thereto. 

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1.2 In the event that a Person is not an Affiliate as of the Effective Date of this 

Agreement, but later becomes an Affiliate through an acquisition by Licensee (an 

"Acquired Affiliate"), such Acquired Affiliate shall be deemed to be an Affiliate 

for the purposes of this Agreement upon completion of such transaction or 

transactions, but nothing herein shall limit or impair Licensor's rights to prosecute 

or maintain any claim against any Acquired Affiliate with respect to activities, 

events or transactions occurring prior to the time when such Person became an 

Acquired Affiliate. To the extent Licensee is acquired by or merges with another 

entity or reorganizes organizations in the future in a manner that meet the Control 

requirements herein, this shall be deemed a change in Control subject to Section 

7.1. 

1.3 Furthermore, in the event an Affiliate covered by this Agreement ceases to be an 

Affiliate (a "Departing Afiiliate"), any rights under this Agreement shall continue 

to apply to such Departing Affiliate to the extent of the Departing Affiliate's predeparture Licensed Products as an Affiliate of Licensee, but shall not extend to 

any products of any Third Party that acquires such Departing Affiliate or any 

products of any Third Party acquired by such Departing Affiliate. 

1.4. "Control" (and correlatives thereof) with respect to a Party or Person means (a) 

the legal, beneficial, or equitable ownership, directly or indirectly of fifty percent 

(50%) or more of the securities (or other equity interests) of the Person that 

ordinarily have voting rights in the election of the directors or equivalent 

managers of the Person, or (b) the possession, directly or indirectly, of the power 

to direct or cause the direction of management or policies of the Person, whether 

through the legal, beneficial, or equitable ownership or control of voting 

securities of the Person, appointment of more than fifty percent (50%) of the 

board of directors of the Person, by contract, or otherwise. 

1.5. "Licensed Patents" means the patents identified in Exhibit C and any 

continuations, divisionals, continuations-in-part, extensions, reissues, 

reexaminations, and any other patents or patent applications claiming priority to 

or through the patents identified in Exhibit C, and/or substitution patents andior 

patent applications thereof, as well as any and all foreign counterparts of any of 

the foregoing. In the event that Licensor gains control or ownership of any patent 

listed in Exhibit D, attached to this agreement, "Licensed Patents" shall include 

those patents from Exhibit D which Licensor gains ownership or control over.. 

1.6. "Exploit" means to, in whole or in pait, directly or indirectly: o,:vn, make, have 

made, design, develop, author, write, use, sell, offer to sell, supply, purchase, 

license, offer to license, distribute, lease, import, export, operate, perform, 

provide, display, transmit, or other\lvise transfer, practice, or dispose of, and the 

exercise of all other activities. 

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1. 7, "Licensed Products" means all past, present and future machines, manufactures, 

compositions of matter, methods, processes, apparatuses, devices, hardware, 

software, applications, data, products, web sites, systems and other products and 

services, or any combination of one or more of the foregoing, ever Exploited by 

or on behalf of Licensee, which in the absence of this Agreement would infringe 

at least one of the claims of the Licensed Patents. "Licensed Products" shall not 

include the machines, manufactures, compositions of matter, methods, processes, 

apparatuses, devices, products, web sites, systems or services of any Third Party 

(any of the foregoing a "Third Party Product"), except to the extent such Third 

Party Product is or was Exploited: (i) within or as any part or portion of Licensee's 

Licensed Product; (ii) for the direct benefit of Licensee; or (iii) by or on behalf 

of Licensee. 

1.8, "Person" shall mean a trust, corporation, partnership, joint venture, limited 

liability company, association, unincorporated organization or other legal or 

governmental entity. 

1.9. "Third Party" means a Person other than the Parties. 

2. Releases and Covenants

2.1. Licensor Release of Licensee. Subject to the payment provided under Section 

5 .I, Licensor irrevocably releases, acquits and forever discharges Licensee, its 

Affiliates, and its respective officers, directors and attorneys from any and all 

past, present, or future claims or liabilities of any kind and nature, at law, in 

equity, or otherwise, known or unknown, suspected or unsuspected, disclosed or 

undisclosed, arising out of or relating in any way to acts of Licensee or its 

Affiliates in connection with: (i) the claims and counterclaims asserted in the 

Pending Litigation; (ii) the Licensed Patents solely with respect to the Licensed 

Products; and/or (iii) the conduct of settlement negotiations occurring before the 

Effective Date (except for representations or obligations expressly included in 

this Agreement). 

2.2. Licensor Release of Third Parties. Subject to the payment provided under 

Section 5. I, Licensor irrevocably releases, acquits and forever discharges all 

vendors, suppliers, manufacturers, developers, depositors, distributors, 

contractors, partners, hosts, direct and indirect customers, and end-users of 

Licensee or the Licensed Product (such third parties individually referred to 

herein as a "Licensee Third Party" and collectively as the "Licensee Third 

Parties") from any and all past, present, or future claims or liabilities of any kind 

and nature, at law, in equity, or otherwise, known and unknown, suspected and 

unsuspected, disclosed and undisclosed, arising out of or relating in any way to 

acts of a Licensee Third Party or the Licensee Third Parties in connection with 

the Licensed Patents solely with respect to the Licensed Products. For clarity, 

this release shall only protect Licensee Third Patties to the extent their activities 

concern or relate to Licensed Products. 

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2.3. Licensee's Release. Subject to the compliance by Licensor with the terms and 

conditions of this Agreement, Licensee irrevocably releases, acquits and forever 

discharges Licensor and their respective officers, directors, shareholders, 

members, employees, agents, consultants, experts, representatives, and attorneys 

from any and all claims or liabilities of any kind and nature, at law, in equity, or 

otherwise, known or unknown, suspected or unsuspected, disclosed or 

undisclosed, arising out of or relating in any way to acts of Licensor in connection 

with the claims and counterclaims asserted in the Pending Litigation, with respect 

to the Licensed Patents and with respect to the conduct of settlement negotiations 

occurring before the Effective Date (except for representations or obligations 

expressly included in this Agreement). Notwithstanding the foregoing, nothing 

in this Paragraph or in this Agreement shall prevent Licensee or any Licensee 

Third Paiiy ( other than as provided in Paragraph 3 .5 hereof) from asserting that 

any of the Licensed Patents are invalid, not infringed or unenforceable if the 

Licensed Patents are asserted against Licensee or any Licensee Third Party. 

3. Grants and Covenants

3 .1. Licensor License to Licensee. Subject to the payment provided under Section 

5.1, Licensor hereby grants to Licensee and Licensee's Affiliates a non-exclusive, 

non-transferable ( except as provided for in Section 7. I), perpetual, irrevocable, 

royalty-free, fully paid-up, worldwide license, without the right to sublicense, in 

and to the Licensed Patents solely to Exploit the Licensed Products. Licensor 

hereby also grants to Licensee Third Parties, manufacturers, developers, vendors, 

suppliers, distributors, contractors, depositors, partners, hosts, direct or indirect 

customers and end-users a non-exclusive, non-transferable (except as provided 

for in Section 7.1), perpetual, irrevocable, royalty-free, fully paid-up, worldwide 

license, without the right to sublicense in and to the Licensed Patents solely to 

Exploit the Licensed Products. Under the terms of this Agreement, Licensee shall 

have no right to sublicense and further, there is no right to further sublicense by 

any Third Party. No royalties or additional payments of any kind shall be required 

in order to maintain this Agreement in force. 

3.2. Covenant Not to Sue Licensee. Subject to the payment provided under Section 

5 .1, Licensor covenants not to sue Licensee or its Affiliates for actual or alleged 

infringement of the Licensed Patents. Licensor further covenants not to sue 

Licensee Third Parties and their respective direct or indirect customers, 

depositors, end-users, suppliers, vendors, manufacturers, hosts, partners, 

distributors, contractors, developers and other Third Parties for actual or alleged 

infringement of any Licensed Patents to the extent such actual or alleged 

infringement is based on activities that concern or relate to Licensed Products. 

3.3. Covenant Not to Sue Licensor. Subject to the compliance by Licensor with the 

terms and conditions of this Agreement, Licensee covenants not to sue Licensor 

for any claims with respect to the Licensed Patents. 

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3.4. No Other Rights. No rights are granted under any Patents except as expressly 

provided in this Agreement, whether by implication, estoppel, or otherwise. No 

right to grant covenants, rights, or sublicenses or to become a foundry for Third 

Parties is granted under this Agreement. 

3.5, Future Enforcement Activity by Licensor. In the event that Licensor brings a 

claim under the Licensed Patents against any Licensee Third Party or any entity 

that claims that the alleged infringing conduct arises out of any communication, 

interaction, transaction, cooperation, or contractual obligation with or on behalf 

of Licensee, then upon Licensee providing written notice and sufficient written 

evidence to corroborate that claim, then Licensor shall within ten (10) days cause 

such claim to be dismissed with respect to such entity, to the extent the claim is 

based on conduct that is properly subject to protection from suit under Section 

2.1, 2.2, 3.1 or 3.2. 

4. Dismissal of Litigation

4.1. Timing of Dismissal. Within five (5) court days after the payment of the 

consideration to Licensor under Section 5.1 below, the Parties shall cause their 

respective counsel to file the stipulated motion as set forth in Exhibit A, 

dismissing with prejudice all claims brought by Licensor against Licensee, 

dismissing with prejudice all non-infringement counterclaims brought by 

Licensee, and dismissing without prejudice all invalidity counterclaims brought 

by Licensee in the Pending Litigation, to the extent any such claims or counter 

claims have been raised in litigation between the Pm1ies at that time. The Parties 

shall promptly proceed with any and all additional procedures needed to effect 

the above dismissal. If for any reason (except for Licensee's failure to make the 

payment under Section 5.1), Licensor or its counsel refuses to file the motion as 

set forth in Exhibit A, Licensee shall have the right to demand Licensor 

immediately refund in full the Consideration to Licensee. 

4.2. Costs. The Pm1ies agree that they shall bear their own costs and attorneys' fees 

relating to the Pending Litigation and to the negotiation of this Agreement. 

4.3. Dismissal of Licensee Third Parties. To the extent Licensor has any pending 

lawsuits against Licensee Third Parties related to the Licensed Products and the 

Licensed Patents, Licensor will undertake to dismiss with prejudice all claims 

against Licensee Third Parties related to the Licensed Products within 5 days after 

Licensor's receipt of the payment of the "Consideration" (as hereinafter defined), 

provided Licensee provides written notice to Licensor of the lawsuits involving 

such Licensee Third Parties. 

5. Consideration

5.1. Payment. In consideration of the licenses, releases, and covenants granted by 

Licensor and the dismissal by Licensor of the Pending Litigation, Licensee agrees 

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to pay to Licensor a total payment of

(the "Consideration"). The Consideration shall be paid within five 

(5) days of the Effective Date. Such payment shall be by electronic or wire

transfer to an account specified by Licensor and attached to this Agreement as

Exhibit B. No other payments are required by this Agreement. Notwithstanding

anything contained herein to the contrary, this Agreement shall not be effective

until the Consideration has been received by Licensor. The Parties hereby agree

that this is a settlement and no representation is made by Licensor that the

foregoing Consideration represented a reasonable royalty from the infringement

alleged in the Litigation. The Consideration paid to Licensor under this

Agreement shall be nonrefundable, including in the event of a finding of

invalidity, unenforceability, or non-patentability of the Licensed Patents.

5.2. Taxes. Licensor shall bear all U.S. taxes imposed with respect to payments made 

to it hereunder. For clarity, this does not include any other taxes, charges, or fees, 

for example, non-U.S. taxes or non-U.S. tax withholdings. 

5.3. No Withholding. Licensee's payment of the Consideration hereunder shall be 

made free and clear of any taxes, withholding taxes, assets, duties, permits, tariffs, 

fees and other charges of any kind. 

6. Term and Termination

6.1. Term. The term of this Agreement shall be from the Effective Date until the 

expiration of the last-to-expire Licensed Patents, unless earlier terminated as 

allowed by this Agreement, provided that the licenses, releases, and covenants 

granted by Licensor herein shall survive in perpetuity. 

6.2. Agreement Obligations Not Released. Notwithstanding anything to the 

contrary herein, the Parties reserve all rights and remedies, including damages 

and equitable relief, for breach of this Agreement by the other Party and nothing 

herein releases any Party from its respective obligations under this Agreement or 

prevents any Party from enforcing the tem1s and conditions of this Agreement 

against the other. 

7. Assignment and Change of Control

7.1. Assignment by Licensee. Licensee may assign its rights under this Agreement 

without prior written consent of Licensor as follows: (A) In the event of a change 

of Control of Licensee, this Agreement shall continue to benefit and obligate 

Licensee or the successor entity and the licenses granted in Subsection 3.1 may 

be assigned to such successor entity, provided that (i) such licenses will extend 

only to the Licensed Products and that part of the business relating to the Licensed 

Products prior to such change of Control and will not extend to any machines, 

manufactures, compositions of matter, methods, processes, apparatuses, devices, 

6 

Redacted for confidentiality Redacted for confidentiality

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products, web sites, systems of the successor or acquiring entity ( other than the 

Licensed Products ( or reasonable extensions of the foregoing and whether 

re branded or not) of the Licensee's business that existed prior to the change of 

Control); and (ii) the obligations of Licensee are similarly assigned. (B) Licensee 

may assign its rights under this Agreement, in whole or in part, as part of a sale, 

transfer, or spin-off of a substantial portion of Licensee or its Affiliate's business, 

provided that any assignment of rights under this Agreement shall only extend to 

the Licensed Products of Licensee and/or of its Affiliates immediately prior to the 

date of the sale, transfer or spin-off and will not extend to any other products, 

services or activities prior to, on or after the effective date of the assignment 

except with respect to the same type and scope of Licensed Products that were 

conducted immediately prior to the sale, transfer, or spin-off. All rights under 

this Agreement shall continue to apply to a Departing Affiliate to the extent of 

the Departing Affiliate's pre-departure Licensed Products as an Affiliate of Valve, 

but shall not extend to any activities of any Third Party that acquires such 

Departing Affiliate or any activities of any Third Party acquired by that Departing 

Affiliate. 

Any assignment or transfer of licenses in violation of this Subsection 7 .1 shall be 

null and void, but only from such time as the violation occurs. Subject to the 

foregoing, this Agreement shall be binding upon and inure to the benefit of the 

Parties and their permitted successors and assigns. Except as set forth in this 

Section 7. l, this Agreement may not be assigned by Licensee without the prior 

written permission of Licensor, and any attempt to assign without such 

permission will be void. 

7.2. Assignment by Licensor. Licensor may not assign, or exclusively license, any 

of the Licensed Patents without such assignee or licensee agreeing to be bound 

by the obligations of Licensor hereunder as if it were a party hereto, and any 

assignment or exclusive license made in violation of this provision shall be void. 

7.3. Notice of Assignments. To the extent either Party makes an assignment, whether 

complete or partial, of its rights under this Agreement where pem1itted by the 

express terms of the Agreement, that Party shall provide written notice to the 

nonassigning Party. In the event of any change of control of Licensee, a public 

announcement of such change of control shall be deemed to constitute written 

notice of assignment for purposes of this section. 

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8. Notices

9. 

8.1. Notices and other communications regarding or under this Agreement shall be 

sent (i) by overnight courier or by registered or certified mail and (ii) if available, 

electronic mail to the following addresses: 

1.1.1. Notices to Licensor shall be sent to Licensor's agents at: 

Ni Wang & Massand, PLLC 

8140 Walnut Hill Lane 

Suite 310 

Dallas, Texas 75231 

nmassand@nilawfirm.com 

1.1.2. Notices to Licensee shall be sent to Licensee at: 

Valve Coq)oration 

c/o General Counsel 

10900 NE 4

th Street 

Suite 500 

Bellevue, WA 98004 

With a copy to: 

Ed Cavazos 

Pillsbury Winthrop Shaw Pittman LLP 

111 Congress Ave., Suite 400 

Austin, Texas 78701 

ed.cavazos@.pillsburylaw.com 

8.2. A Party may change the above addresses for notices relating to this Agreement in 

a written notice to the other Party complying as to delivery with the terms of 

Section 8.1. All such notices, requests, demands and other communications shall 

be effective, if by mail or overnight courier, when delivered or if not delivered 

due to refusal or failure to advise the other Party of a change of address, five (5) 

days after depositing such notice in the U.S. mail or one (1) day after depositing 

such notice with an overnight courier. 

Representations, Warranties and Disclaimers 

9 .1. Each Party and each person signing this Agreement on behalf of a Party 

represents and warrants to the other that it has the full right and power to enter 

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into this Agreement, and the person executing this Agreement has the full right 

and authority to enter into this Agreement on behalf of such Party and the full 

right and authority to bind such Party to the terms and obligations of this 

Agreement. 

9.2. Licensor represents and warrants that as of the Effective Date (a) Licensor is the 

sole owner of the entire right, title and interest in and to the Licensed Patents, 

including all rights to enforce and sue for past damages, as reflected by the 

"Assignee" entities listed in Exhibit C; and (b) Licensor has the right and authority 

to grant the rights, licenses and releases hereunder on behalf of the entities listed 

in Exhibit C. 

9.3, Other than that which is required of Licensee by Comt Order or rule of law, 

Licensee represents and warrants that it will not contest or assist in contesting the 

validity or enforceability of the Licensed Patents and will so instruct its counsel 

and consultants retained for this case other than those retained in conjunction with 

co-defendants not to contest or assist in contesting the validity or enforceability 

of the Licensed Patents on Licensee's behalf. If Licensee (or its counsel on 

Licensee's behalf) intentionally or knowingly contests or assists in the contesting 

of the validity or enforceability of the Licensed Patents, Licensor will have the 

right to unilaterally tem1inate this Agreement. For the avoidance of doubt, no 

production or response by Licensee to a subpoena or other order of a court of 

competent jurisdiction shall be considered contesting or assisting with a contest 

under this Section. Nothing in this section shall be construed so as to restrict any 

counsel, including Licensee's counsel in the Pending Litigation, from taking any 

action whatsoever (including challenging the validity and enforceability of the 

Licensed Patents in any judicial or administrative forum) on behalf of their clients 

who are not parties to this Agreement. Nothing in this Paragraph or in this 

Agreement shall prevent Licensee from asserting that any of the Licensed Patents 

are invalid, not infringed or unenforceable if the Licensed Patents are asserted 

against Licensee or its Licensee Third Parties. 

9.4. EXCEPT AS EXPRESSLY PROVIDED IN THIS AGREEMENT, NEITHER 

LICENSOR NOR LICENSEE MAKES ANY REPRESENTATIONS OR 

W ARR.L\NTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, OR 

ASSUMES ANY RESPONSIBILITIES WHATSOEVER WITH RESPECT TO 

THE COMMERCIAL SUCCESS, USE, SALE, OR OTHER DISPOSITION BY 

OR FOR ANY OTHER PARTY (OR ITS SUBSIDIARIES) OR THEIR 

DISTRIBUTORS, USERS, OTHER CUSTOMERS, OR SUPPLIERS OF 

PRODUCTS IN CORPORA TING OR MADE BY THE USE OF INVENTIONS 

LICENSED HEREIN. LICENSOR DOES NOT CONVEY ANY RIGHT OR 

LICENSE (EXCEPT TO THE EXTENT NECESSARY TO EXERCISE THE 

RIGHTS EXPRESSLY GRANTED HEREIN) BY IMPLICATION, 

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10. 

ESTOPPEL, OR OTHER WISE, EXCEPT AS EXPRESSLY GRANTED 

HEREIN. 

9.5. In no event shall Licensor be liable for any special, punitive or exemplary 

damages or for loss of profits or revenue, or any indirect, consequential or 

incidental damages arising out of, or in connection with, this Agreement and the 

Licensed Products. Further, in no event shall Licensor be found liable for 

damages to any party for any amount that exceeds the aggregate total amount of 

Consideration paid hereunder with respect to this Agreement and the Licensed 

Products. In no event shall Licensee be liable for any special, punitive or 

exemplary damages or for loss of profits or revenue, or any indirect, 

consequential or incidental damages arising out of, or in connection with, this 

Agreement. 

Confidentiality, Publidtv Material and Marketing 

10.1. Nothing in this Agreement shall confer upon any Party any right to include in 

advertising, packaging or other commercial activities, any reference to the other 

Parties in any manner whatsoever. 

10.2. Each Party agrees not to disclose the tem1s of this Agreement to any third party 

without the prior written consent of the other Party, which may be withheld in 

such parties sole and absolute discretion. This obligation is subject to the 

following exceptions: 

1.1. l. disclosure is permissible if required by government or court order, 

including litigation document requests and SEC (or equivalent) reporting 

requirements, but only to the extent so required, provided that such 

disclosure is subject to confidential treatment to the fullest extent allowed 

by law; 

1.1.2. disclosure is permissible if otherwise required by law or required during 

the course of litigation (e.g., subpoena, discovery request or equivalent), 

but only to the extent so required and provided that such disclosure does 

not affect the confidential nature of such information; 

1.1.3. disclosure is permissible to the extent the information becomes publicly 

available by judicial order or action; 

1.1.4. disclosure is permissible if required to enforce rights under this 

Agreement; and 

1.1.5. each Party may disclose this Agreement or its contents to the extent 

reasonably necessary, on a confidential basis, to its Affiliates, 

accountants, attorneys, auditors, and financial advisors or those of any 

third party in connection with a financing or corporate transaction. 

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1.1.6. Licensee may disclose this Agreement to all Licensee Third Parties 

covered by the releases, grants, and covenants provided in Sections 2 and 

3 above. 

1.1.7. Licensor may disclose the fact that a settlement and/or license agreement 

has been reached with Licensee in connection with any other litigation or 

enforcement efforts by Licensor with respect to the Licensed Patents. The 

terms of the settlement or license shall remain confidential pursuant to the 

terms hereof. 

11. General Terms.

11.1, The construction, validity and performance of the Agreement shall be governed 

in all respects (without regard to conflicts of law provisions) by the law of the 

State of Texas, United States of America, as such law applies to contracts signed 

and fully performed in the State of Texas. The Parties hereby submit to the 

jurisdiction ot� and waive any venue objections against, the State and Federal 

courts in Texas. 

11.2. Nothing in the Agreement is to be construed as requiring the commission of any 

act contrary to law. Wherever there is any conflict between any provision of the 

Agreement and any statute, law or ordinance, or a treaty and its valid regulations, 

the statute, law, ordinance, or treaty and its valid regulations shall prevail. In 

such event the provisions of the Agreement shall be curtailed and limited only to 

the extent necessary to bring them within the legal requirements, and such 

provisions, so curtailed and limited, together with all other provisions of the 

Agreement shall continue in full force and effect. 

· 11.3. All rights granted under the covenants not to assert, releases, discharges and other

rights granted under or pursuant to this Agreement are, and shall otherwise be 

deemed to be, for purposes of Section 365(n) of Title 11, U.S. Code (the 

"Bankruptcy Code"), licenses and rights to "intellectual property" as defined 

under Section 101 of the Bankruptcy Code. The Parties agree that each Party 

shall retain and may fully exercise and enjoy all rights and elections available to 

them under the Bankruptcy Code and other applicable laws and regulations. 

. 11 .4. This Agreement will not be binding upon the Parties until it has been signed 

herein below by or on behalf of each Party, in which event, it shall be effective 

as of the Effective Date. No amendment or modification hereof shall be valid or 

binding upon the Parties unless made in writing and signed as aforesaid. 

11.5. The failure of a Party to enforce any provision of this Agreement shall not prevent 

the subsequent enforcement of such provision. No waiver of any provision of 

this Agreement shall be deemed or shall constitute a waiver of any other 

provision, whether or not similar, nor shall any waiver constitute a continuing 

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waiver unless expressly stated in writing by the party making the waiver. No 

waiver of any provision shall be binding in any event unless executed in writing 

by the party making the waiver. 

11.6. The headings of the several Sections are inserted for convenience of reference 

only and are not intended to be a part of or to affect the meaning and interpretation 

of this Agreement. 

11.7. This Agreement embodies the entire understanding of the Parties and supersedes 

all previous communications, representations or understandings, either oral or 

written, between the Parties relating to the subject matter hereof. 

11.8. Each Party shall bear its own costs, expenses and attorneys' foes incurred in 

connection with the making of this Agreement, and its performance under this 

Agreement. Each Party expressly waives any claim of costs and attorneys' fees 

from or against the other Party, including, without limitation, any attorneys' fees 

or costs that may already have been awarded in any action. 

11.9. The language of this Agreement has been approved by counsel for each Party, 

and neither Party (nor their respective counsel) shall be deemed to be the 

draftsman of this Agreement Thus, any rule of construction to the effect that 

ambiguities are to be resolved against the drafting Party will not be applied in the 

interpretation of this Agreement. The words "include" and "including" and 

variations thereof, will not be deemed to be tenns of limitation in this Agreement, 

but rather will be deemed to be followed by the words "without limitation,'' The 

headings in this Agreement are for convenience and organization only, and not 

intended to constitute the substance of this Agreement and will not be referred to 

in connection with the construction or interpretation of this Agreement. 

11.10. This Agreement may be executed in two or more counterparts, each of which 

shall be deemed an original, but all of which together shall constitute but one and 

the same instrument. Such counterparts may be exchanged by fax, or scanned 

and exchanged by electronic mail, confirmed with printed copy, but shall be 

effective upon receipt of fax/electronic mail as applicable. The Parties agree that 

facsimile or scanned copies of signatures shall be deemed originals for all 

purposes hereof and that e.ither Party may produce such copies, without the need 

to produce original signatures, to prove the existence of this Agreement in any 

proceeding brought hereunder. 

11. 11. Marking. Licensee asserts that it has not infringed any claim of the Licensed

Patents and that it is not currently infringing any claim of the Licensed Patents. 

Licensee further acknowledges that, before entering into this Agreement, 

Licensee was not authorized to make, have made, sell, offer for sale, or import 

into the United States any product that infringed any claim of the Licensed 

Patents. From the Effective Date fo1ward, for products that are not Licensed 

12 

Case 2:23-cv-00419-JRG Document 63-1 Filed 04/22/24 Page 13 of 22 PageID #: 1535 Case 2:23-cv-01016-JNW Document 1-1 Filed 07/07/23 Page 13 of 22
Products, Licensee will have no products that must be marked with notice of the 

Licensed Patents under 35 U.S.C. § 287. 

13 

Case 2:23-cv-00419-JRG Document 63-1 Filed 04/22/24 Page 14 of 22 PageID #: 1536 Case 2:23-cv-01016-JNW Document 1-1 Filed 07/07/23 Page 14 of 22
IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be duly executed 

with intent to be bound as of the Effective Date. 

Display Technologies, LLC 

Name: Leigh M. Rothschild 

Title: ___ M_a_na�9!gg Director 

Date: --------- 01/11/2016

Leigh Rothschild ( on his own and on 

behalf of all entities listed as "Assignee" 

in ]�fb'il�it•C) i······-.;•...,_ 

Bv ...

. ''L., .. ,·:,�r· 

.... �.� ··"··•···.�·�· .......... �

Name: Leigh M. Rothschild

Title: 

Date: 

Managing Director

01/11/2016 

THIS AGREEMENT DOES NOT BIND OR OBLIGATE EITHER PARTY IN ANY 

MANNER UNLESS DULY EXECUTED BY AUTHORIZED REPRESENTATIVES OF 

BOTH PARTIES 

14 

Case 2:23-cv-00419-JRG Document 63-1 Filed 04/22/24 Page 15 of 22 PageID #: 1537 Case 2:23-cv-01016-JNW Document 1-1 Filed 07/07/23 Page 15 of 22
EXHIBIT A 

THE UNITED ST ATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

DISPLAY TECHNOLOGIES, LLC 

Plaintiff, 

v. 

VALVE CORPORATION, 

Defendant. 

Civil Action No. 2:15-cv-999 

JURY TRIAL DEMANDED 

MOTION TO DISMISS 

Under Federal Rule of Civil Procedure 4l(a), Display Technologies, LLC ("Display") 

dismisses its claims against Valve Corporation ("Valve") with prejudice against Valve and each 

party bears its own attorneys' fees and costs. 

15 tmr 

Case 2:23-cv-00419-JRG Document 63-1 Filed 04/22/24 Page 16 of 22 PageID #: 1538 Case 2:23-cv-01016-JNW Document 1-1 Filed 07/07/23 Page 16 of 22
THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

DISPLAY TECHNOLOGIES, LLC 

Plaintiff, 

V. 

VALVE CORPORATION, 

Defendant. 

Civil Action No. 2:15-cv-999 

JURY TRIAL DEMANDED 

ORDER 

In light of the Motion to Dismiss filed by Plaintiff Display Technologies, LLC 

("Display"), the Court HEREBY ORDERS as follows: 

1. Display' s claims against Valve Corporation are hereby dismissed WITH

PREJUDICE 

. 2. Display and Valve Corporation shall each bear their own attorneys' fees and 

costs incurred in connection with this action. 

16 

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Account Name: 

Reference: 

Account No.: 

Routing No.: 

SWIFT Code: 

Name of Bank: 

Bank Address: 

Bank Phone No.: 

EXHlBlTB 

'\Vire Instructions 

Ni Law Firm, PLLC IOLTA Account 

Display Technologies, LLC 

413981346 

111000614 

CHASUS33 

JPMorgan Chase Bank, N .A. 

3610 McKinney Ave., Dallas, TX 75204 

214-443-1555

17 

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No. Patent Number 

1 

2 

3 

4 

5 

6 

8 

9 

10 

11 

9054860 

8897833 

8671195 

8594722 

8437797 

8346920 

8307089 

8219590 

8204437 

7979434 

6101534 

Exhibit C 

Licensed Patents 

Title 

Digital verified identification system 

and method 

Wireless image distribution system 

and method 

Digital media communication protocol 

Wireless image distribution system 

and method 

Wireless image distribution system 

and method 

Managing network resource requests 

System and method for storing 

broadcast content in a cloud-based 

computing environment 

Media validation system 

Wireless image distribution system 

and method 

System and method for storing and 

retrieving digital content with physical 

file systems 

Interactive, remote, computer 

interface system 

18 

Assignee 

SRR Patent Holdings, LLC; 

Leigh Rothschild 

Display Technologies, LLC; 

Rothschild Storage Retrieval 

Innovations, ., 

Rothschild Storage Retrieval 

Innovations, LLC; 

SRR Patent Holdings, LLC; 

Ariel Inventions, LLC; 

Rothschild Trust Holdings, L.L.C.; 

Rothschild Storage Retrieval 

Innovations, LLC; 

SRR Patent Holdings, LLC; 

........... _ .... 

Rothschild Digital Media LLC; 

Case 2:23-cv-00419-JRG Document 63-1 Filed 04/22/24 Page 19 of 22 PageID #: 1541 Case 2:23-cv-01016-JNW Document 1-1 Filed 07/07/23 Page 19 of 22
12 

13 

14 

15 

16 

17 

18 

19 

20 

8856221 

9053498 

8799088 

7698164 

8832542 

8469270 

8151180 

8799263 

8370141 

System and method for storing 

broadcast content in a cloud-based Ariel Inventions, LLC; 

computing environment 

Systems and methods for indicating 

the existence of accessible Reagan Inventions, LLC; information pertaining to articles of 

commerce 

System and method for verifying user 

identity information in financial SRR Patent Holdings, LLC; 

transactions 

Method and system for providing a 

payment incentive for distributing Matthew Inventions, LLC; 

digital files over a network 

System and method embedding 

symbology in alphabetic letters and Leigh Rothschild then linking the letters to a site or 

sites on the global computer network 

Systems and methods for indicating 

the existence of accessible Reagan Inventions, LLC information pertaining to articles of 

commerce 

System and method of embedding 

symbology in alphabetic letters and Reagan Inventions, LLC then linking the letters to a site or 

sites on the global computer network 

Systems, devices, and methods for 

providing multidimensional search Ariel Inventions, LLC 

results 

Device, system and method for 

enabling speech recognition on a Reagan Inventions, LLC 

portable data device 

19 

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No. Patent 

Number 

l 8838693

2 8504652 

,.., 

.) 8473514 

4 8396931 

5 8122466 

6 8069164 

7 8046813 

8 7711774 

9 76310 00 

10 7318061 

11 8909729 

p 7503059 

.... 

Exhibit D 

Patents Licensed if Licensor Gains Ownership or Control 

Title Assignee 

Multi-user media delivery system for synchronizing Portulim 

content on multiple media players Foundation LLC; 

Method and system for selectively supplying media Portulim content to a user and media storage device for use Foundation LLC; therein 

Schust 

Media validation system Development 

LLC; 

Interactive, multi-user media delivery system Portulim 

Foundation LLC; 

System and method for updating digital media Portulim 

content Foundation LLC; 

Schust 

Media validation system Development 

LLC; 

Method of enhancing media content and a media Portulim 

enhancementsy�tc111 Foundation LLC; 

Interactive, multi-user media delivery system Portulim 

Foundation LLC; 

Schust 

Media validation system Development 

LLC; 

Schust 

Media validation and registration system Development 

LLC; 

System and method for sharing digital media No apparent 

content assignment; 

Method of enhancing media content and a media Portulim 

enhancement system Foundation LLC; 

20 

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13 6952697 

I 

.. 14 6766363 

.. 

15 6430554 

Media validation system 

System and method of linking items in audio, 

visual, and printed media to related information 

stored on an electronic network using a mobile 

device 

Interactive system for investigating products on a 

network 

21 

Schust 

Development 

LLC 

Neomedia 

Technologies, 

Inc. 

Neomedia 

Technologies, 

Inc. 

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