`Case 1:17-cv-00770-JDW Document 410-4 Filed 06/12/24 Page 1 of 2 PagelD #: 38663
`
`EXHIBIT R4
`EXHIBIT R4
`
`
`
`Case 1:17-cv-00770-JDW Document 410-4 Filed 06/12/24 Page 2 of 2 PageID #: 38664
`Wirtgen America v. Caterpillar - Reasonable Royalty and Interest Calculations
`Calculation 2 - Royalty Payment at End of Quarter
`2016 to Partial February 2024
`
`Year/
`Quarter
`
`2016
`Qtr1
`Qtr2
`Qtr3
`Qtr4
`2017
`Qtr1
`Qtr2
`Qtr3
`Qtr4
`2018
`Qtr1
`Qtr2
`Qtr3
`Qtr4
`2019
`Qtr1
`Qtr2
`Qtr3
`Qtr4
`2020
`Qtr1
`Qtr2
`Qtr3
`Qtr4
`2021
`Qtr1
`Qtr2
`Qtr3
`Qtr4
`2022
`Qtr1
`Qtr2
`Qtr3
`Qtr4
`2023
`Qtr1
`Qtr2
`Qtr3
`Qtr4
`2024
` Qtr1 partial *
`
`Total Royalties and Pre-Judgment Interest
`
`Reasonable Royalty
`- End of Quarter
`(a)
`
`Balance at Start
`of Quarter
`(b)
`
`Seth Quarterly
`Prime Rate
`(c)
`
`Interest
`(d)=(b)x(c)
`
`Cumulative Total
`(e)=(a)+(b)
`
`$0
`$52,080
`$234,360
`$156,240
`
`$234,360
`$364,560
`$426,403
`$187,162
`
`$316,545
`$700,632
`$611,976
`$597,897
`
`$420,624
`$969,292
`$834,940
`$254,620
`
`$474,086
`$924,249
`$607,703
`$303,119
`
`$302,428
`$556,358
`$187,713
`$299,724
`
`$194,626
`$467,396
`$418,964
`$204,445
`
`$307,654
`$629,445
`$396,380
`$354,222
`
`$0
`
`$0
`$0
`$52,080
`$286,890
`
`$445,643
`$684,178
`$1,055,563
`$1,493,007
`
`$1,695,930
`$2,031,364
`$2,755,945
`$3,401,809
`
`$4,043,747
`$4,518,861
`$5,549,045
`$6,456,226
`
`$6,787,432
`$7,334,978
`$8,318,111
`$8,992,590
`
`$9,367,901
`$9,745,533
`$10,380,125
`$10,651,168
`
`$11,036,398
`$11,320,699
`$11,897,718
`$12,473,290
`
`$12,885,172
`$13,433,705
`$14,329,190
`$15,018,455
`
`$15,682,123
`
`0.864%
`0.864%
`0.864%
`0.876%
`
`0.937%
`0.997%
`1.046%
`1.056%
`
`1.114%
`1.179%
`1.230%
`1.295%
`
`1.348%
`1.348%
`1.302%
`1.186%
`
`1.082%
`0.803%
`0.803%
`0.803%
`
`0.803%
`0.803%
`0.803%
`0.803%
`
`0.813%
`0.968%
`1.316%
`1.663%
`
`1.869%
`1.980%
`2.044%
`2.060%
`
`2.060%
`
`$0
`$0
`$450
`$2,513
`
`$4,175
`$6,825
`$11,041
`$15,761
`
`$18,888
`$23,949
`$33,888
`$44,041
`
`$54,490
`$60,892
`$72,241
`$76,585
`
`$73,461
`$58,884
`$66,776
`$72,191
`
`$75,204
`$78,235
`$83,330
`$85,506
`
`$89,675
`$109,623
`$156,608
`$207,437
`
`$240,878
`$266,040
`$292,885
`$309,446
`
`$0
`$52,080
`$286,890
`$445,643
`
`$684,178
`$1,055,563
`$1,493,007
`$1,695,930
`
`$2,031,364
`$2,755,945
`$3,401,809
`$4,043,747
`
`$4,518,861
`$5,549,045
`$6,456,226
`$6,787,432
`
`$7,334,978
`$8,318,111
`$8,992,590
`$9,367,901
`
`$9,745,533
`$10,380,125
`$10,651,168
`$11,036,398
`
`$11,320,699
`$11,897,718
`$12,473,290
`$12,885,172
`
`$13,433,705
`$14,329,190
`$15,018,455
`$15,682,123
`
`$134,930
`
`$15,817,053
`
`$12,990,205
`Total
`Memo: Dr. Seth's Total (quarterly payments, mid-period convention):
`
`$2,826,848
`$2,920,085
`
`$15,817,053
`
`Note:
`
`* Calculated for 38 days at 8.50%, as done by Dr. Seth.
`
`Source: (a) and (c) calculated to match Dr. Seth's calculated royalty figures and quarterly Prime Rate.
`Interest compounded quarterly.
`(a) assumes royalty payment made at end of the quarter.
`(b) reflects balance (cumulative total) at the end of the prior period.
`Dr. Seth applies a 0.69 adjustment in Q2 2016 and other small adjustments that slightly
`lower her interest calculations, taking into account starting damages periods for individual patents.
`These small adjustments of Dr. Seth are not performed here.
`
`Highly Confidential - Attorneys' Eyes Only
`
`
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