Pelle Karlsson and EvelynT. Karlsson - Page 13

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                  Petitioners' experts emphasize that under Technology-1980's                         
            development license, Technology-1980 was obligated to pay $20,000                         
            as an advance process royalty for each oil recovery installation                          
            that was actually constructed.  Petitioners' experts, however,                            
            neglect the provision that would allow Technology-1980 to apply                           
            any such advance process royalty paid to reduce or offset the                             
            production royalty that would become due.                                                 
                  Petitioners emphasize that Cromwell agreed to pay a fourth                          
            for its license of EOR technology of what Technology-1980 agreed                          
            to pay.  The only reason, however, that Cromwell was obligated to                         
            pay less for its license of EOR technology was that Cromwell sold                         
            fewer partnership units to investors.  As stated, total license                           
            fees due from the partnerships were based on the number of                                
            partnership units sold.                                                                   
                  Because the evidence establishes that the fixed license fees                        
            that were agreed to were not justified at all, that they did not                          
            bear any relationship to what was acquired, and that they were                            
            not normal in the oil and gas industry, nominal differences                               
            between Cromwell’s stated license fees and Technology-1980's                              
            stated license fees do not constitute a material distinguishing                           
            fact.                                                                                     
                  Petitioners' expert, Bursell, testified that Cromwell's                             
            license fees for EOR technology were not particularly excessive                           
            in amount.  Bursell, however, did not even know what Cromwell had                         





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