I/P Engine, Inc. v. AOL, Inc. et al

Filing 974

Declaration re 973 Opposition, Declaration Of Keith R. Ugone, Ph.D. In Support Of Defendants' Response To Plaintiff I/P Engine, Inc.'s Notice Of Calculation Of Supplemental Damages, Prejudgment Interest, and Post-Judgment Interest by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation. (Attachments: # 1 Exhibit 1 (Public Version), # 2 Exhibit 2, # 3 Exhibit 3)(Noona, Stephen)

Exhibit 2

Prejudgment Interest
Compounded Quarterly Using The Prime Rate (3.25%)
9/15/2011 - 11/20/2012

Q3 2011
Google
Allocated Damages
Interest
AOL
Allocated Damages
Interest
Gannett
Allocated Damages
Interest
IAC
Allocated Damages
Interest
Target
Allocated Damages
Interest
Total Interest

Q4 2011

Q1 2012

Q2 2012

Q3 2012

Total

$661,780

$3,805,236

$3,763,874

$3,763,874

$3,805,236

$15,800,000

$24,815

$110,866

$78,442

$47,475

$16,941

$278,538

$332,691

$1,912,974

$1,892,181

$1,892,181

$1,912,974

$7,943,000

$12,475

$55,735

$39,434

$23,867

$8,517

$140,027

$181

$1,041

$1,030

$1,030

$1,041

$4,322

$7

$30

$21

$13

$5

$76

$278,534

$1,601,571

$1,584,162

$1,584,162

$1,601,571

$6,650,000

$10,444

$46,662

$33,015

$19,981

$7,130

$117,233

$4,140

$23,803

$23,544

$23,544

$23,803

$98,833

$155

$693

$491

$297

$106

$1,742

$47,896

$213,986

$151,403

$91,632

$32,699

$537,616

Notes:
(a) For the purpose of this analysis, it is assumed that interest starts accruing at the end of each period.
(b) Jury awarded damages are allocated to the quarters between September 15, 2011 and September 30, 2012 using the number of days
in each quarter relative to the number of days in the entire time period (i.e., 382 days).
(c) As an illustrative example, for Google, interest associated with the Q3 2011 allocated damages is calculated as
$661,780*(((1+3.25%/4)^4)*(1+(3.25%/365)*50)-1). Interest associated with the Q3 2012 allocated damages is calculated as
$3,805,236*(3.25%/365)*50.
(d) Interest on supplemental damages is included in post-judgment interest because those damages accrued during the fourth quarter of
2012 and therefore would not be due until December 31, 2012.
Source:
Federal Reserve Selected Interest Rates (Daily) - H.15. (http://www.federalreserve.gov/releases/h15/data.htm.)

Prejudgment Interest
Compounded Quarterly Using The 1-Year Treasury Rate
9/15/2011 - 11/20/2012

Q3 2011

Q4 2011

Q1 2012

Q2 2012

Q3 2012

0.11%

0.16%

0.19%

0.18%

$661,780

$3,805,236

$3,763,874

$3,763,874

$3,805,236

$15,800,000

$1,223

$5,952

$4,411

$2,654

$938

$15,178

$332,691

$1,912,974

$1,892,181

$1,892,181

$1,912,974

$7,943,000

Interest

$615

$2,992

$2,218

$1,334

$472

$7,630

Gannett
Allocated Damages

$181

$1,041

$1,030

$1,030

$1,041

$4,322

$0

$2

$1

$1

$0

$4

$278,534

$1,601,571

$1,584,162

$1,584,162

$1,601,571

$6,650,000

$515

$2,505

$1,857

$1,117

$395

$6,388

$4,140

$23,803

$23,544

$23,544

$23,803

$98,833

$8

$37

$28

$17

$6

$95

$2,360

$11,488

$8,514

$5,122

$1,811

$29,296

Treasury Rate
Google
Allocated Damages
Interest
AOL
Allocated Damages

Interest
IAC
Allocated Damages
Interest
Target
Allocated Damages
Interest
Total Interest

Total

Notes:
(a) For the purpose of this analysis, it is assumed that interest starts accruing at the end of each period.
(b) Jury awarded damages are allocated to the quarters between September 15, 2011 and September 30, 2012 using the number of days
in each quarter relative to the number of days in the entire time period (i.e., 382 days).
(c) As an illustrative example, for Google, interest associated with the Q3 2011 allocated damages is calculated as
$661,780*((1+(0.11%/4))*(1+(0.16%/4))*(1+(0.19%/4))*(1+(0.18%/4))*(1+(0.18%/365)*50)-1). Interest associated with the Q3
2012 allocated damages is calculated as $3,805,236*(0.18%/365)*50.
(d) Treasury rates shown reflect quarterly averages. Interest calculations may not tie due to rounding.
(e) Interest on supplemental damages is included in post-judgment interest because those damages accrued during the fourth quarter of
2012 and therefore would not be due until December 31, 2012.
Source:
Federal Reserve Selected Interest Rates (Daily) - H.15. (http://www.federalreserve.gov/releases/h15/data.htm.)