I should also have mentioned in my last email that it is also critical that
Enron obtain an opinion of counsel, upon which Enron can rely, and which
counsel will likely be called to testify in the litigation, that Enron does
not infringe any valid claim of the Odom patent.  The law imposes a duty
upon Enron to get an opinion or run the risk of being held guilty of wilful
infringement which can be the basis of an award of treble damages and
attorneys fees, if Enron is found to be an infringer.  Pete Peterson is
standing by to work on this project, and he also will have a need to have
access to the technical information and documents that we are seeking.

-----Original Message-----
From: Sims, Bill
Sent: Tuesday, October 09, 2001 1:11 PM
To: Sanders, Richard B. (Enron); McCullough, Travis (Enron)
Cc: LaFuze, William; Mims, Peter; Lewis, Veronica
Subject: Settlement conference


I spoke with Bid/Ask's lead lawyer Sam Baxter earlier today about getting
together in person to have an off-the-record "settlement discussion" where
we would try to persuade him to drop his suit because we do not infringe. He
suggested Friday morning. If you want me to attend, we have to do it early
so I can catch my SW flight to Houston for the Halliburton docket call.
Please let me know your availability on Friday, and if not then, when.

Also, Dr Phil MCGraw ("Dr Phil" on the Oprah show) and his company Courtroom
Sciences is on board for witness prep and jury consulting - if we want to
use them. He has been told that ENRON may prefer someone it has worked with
previously, so let me know.

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