Impact Research Corporation, Joan C. Benz, Tax Matters Person - Page 23




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          Gould and invited shareholders of IRC and RIC to discuss the                
          progress of the research.  However, the parties herein have                 
          stipulated that “No shareholder of * * * [IRC or RIC] monitored             
          the substance of the research being performed by Systems”.  The             
          record does not disclose how many, if any, of the shareholders              
          attended the meetings of Systems and Gould.                                 
               Under the exclusive license agreement, IRC transferred to              
          Systems certain rights in exchange for royalty payments.  Because           
          of the limitations on use of various stipulated documents (supra            
          note 7), we cannot determine on the basis of the record herein              
          whether these rights are the rights given to IRC (and RIC?) under           
          the R & D Agreement.  Systems did not remit to either IRC or RIC            
          any royalties in 1984.  In light of the parties’ herein agreeing            
          that “The research under the R & D Agreement was not intended to            
          and did not result in any commercially viable product”, it is not           
          clear whether the parties to the exclusive license agreement                
          contemplated that Systems would ever be obligated, in a real-               
          world sense, to make any royalty payments under the exclusive               
          license agreement.                                                          
               Under the option agreement, Systems had the option to buy              
          all of IRC’s and RIC’s assets in exchange for Systems’ common               
          stock which would be (1) worth at least twice the aggregate                 
          contributed capital of IRC and RIC, and (2) at least 10 percent             
          of Systems’ outstanding common stock immediately after the                  






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