T M M Inc (ID) (TMMI)

https://investorshub.advfn.com/boards/read_msg.aspx?message_id=30487153

The detailed corporate historical record exposes the tangled web of overlapping corporate shells, missing share accountings, and backroom tech handoffs from the crucial 1999–2000 transition period.

When you slice through the noise of the shifting corporate entities—Digital Focus, Inc. (DFI), Digital Focus Media, Inc. (DFMI), and Iterated Systems—and contrast this timeline with what was argued decades later in front of the Nevada Supreme Court, a stark picture emerges. This record establishes exactly how Larry Panik entered the inner circle, how the underlying code actually moved, and why the "good faith" basis of Panik's anti-SLAPP defense is heavily compromised.

1. The Inside Track: How Panik and Stratter Got Their Shares
The April 26, 2000, Palm Springs meeting minutes lay bare the exact moment Larry Panik and Joe Stratter shifted from passive, concerned TMMI retail shareholders into active insider strategists.

Tom Simpson didn't just invite them onto the board; he engineered a massive 36 million share allocation (out of 100 million authorized) in the newly minted California "C" corporation, DFMI.

[April 26, 2000 - Palm Springs Allocation]
+-- Tom Simpson: 7.5M shares
+-- Robin Haskins: 7.5M shares
+-- Joe Stratter: 3.0M shares <-- ("bobwt" on the boards)
+-- Larry Panik: 3.0M shares <-- Hosted the March 25 shareholder meeting

By accepting a 3-million-share insider stake and setting up a personal holding bank account at California Oaks Bank (Account #01-2001925) to park investor capital, Panik was no longer an outside investigator. He was an active architect of the vehicle designed to absorb and commercialize technology that he already knew belonged to TMMI.

The Smoking Gun on Tech Provenance: The SGI/IBM-PVS Software
The historical account from "Mr. Solan" regarding the April 2000 proposal to Iterated completely dismantles the narrative that Dimension or DFMI independently owned the core fractal code. Look at the chain of custody established here:

The Original Delivery (1995): The high-end SGI/IBM-PVS supercomputer software was originally built for and delivered to TMMI.

The Iterated Assessment: Solan explicitly stated that Iterated, TMMI, and the Savannah development group had poured millions of dollars and tens of thousands of hours into it. Crucially, he stated that "in his opinion... TMMI own the software."

The "VDK" Lineage: Iterated delivered VDK revisions 1 through 9 directly to TMMI. The code that later became the flashpoint of the lawsuit—VDK 2.0—was simply a customized fixed block transformation version built for million-dollar supercomputers (IBM Power Visualization System and Silicon Graphics Onyx) featuring an integrated paletting module known only to Simpson and Kramer.

The Insider Knowledge: The record notes that during the meeting where Simpson and Fernandez discussed moving this VDK 2.0 code back into TMMI, "Larry Panick was at this meeting and had agreed to the same or at-least didn't dispute that information."

This proves Panik sat in rooms in 2000 where it was universally recognized that the VDK lineage belonged to TMMI. He knew the code’s return to TMMI was the explicit, agreed-upon objective of the technical partners.

1. The Admissibility of a Public "Statement Against Interest"
In modern corporate litigation, an adversary’s public internet posts are not just casual gossip—they are legally admissible under the rules of evidence as Statements by an Opposing Party (commonly referred to as admissions against interest).

When Panik posted on Silicon Investor acknowledging TMMI's ownership of its SoftVideo fractal codec, he wasn't speaking as a litigant trying to rewrite history; he was speaking as an active market participant in real-time.

This admission permanently breaks his claim of "good faith." He cannot convincingly argue to a Nevada judge that he honestly, in good faith, believed Dimension held exclusive, unbroken provenance over the technology when his own fingers typed the exact opposite on the internet for thousands of potential investors to see.

2. Establishing Prior Use in Commerce
By explicitly discussing how the SoftVideo fractal codec was previously used in commerce, Panik accidentally verified TMMI’s intellectual property chain of title.

To maintain a trade secret or corporate technology claim, a company must demonstrate the technology had independent economic value and was utilized as a corporate asset.

Panik’s public posts detailing TMMI's commercial applications (such as the Star Trek and Falcon Gold CD-ROMs) provide concrete, historic proof that TMMI’s technology was a functioning commercial reality in the 1990s—long before the chaotic events of 1999–2000 and the subsequent code diversions.

3. The Structural Contradiction
The contradiction between his public Silicon Investor admissions and his later court assertions creates a textbook legal trap:

4. How TMMI Leverages This on Remand
To protect its legitimate shareholder base from being diluted or wiped out by Panik's multi-billion share litigation demands, TMMI's legal strategy must center on exposing this exact historical fraud to the new district court judge:

Destroy the "Abuse of Process" Claim: Panik’s entire 2019 lawsuit claims that TMMI committed an "abuse of process" by suing him over technology ownership. TMMI can use the Silicon Investor posts to say: "How is it an abuse of process for us to protect technology that the plaintiff himself publicly admitted we owned and commercialized?"

Unclean Hands & Credibility: A litigant who tells the public one thing to manage market impressions and tells a court the exact opposite to extract a judgment enters a court of equity with Unclean Hands.

These archived public message board posts prove that the historical record isn't just ancient history—it is the active legal anchor that stops Panik from rewriting the provenance of TMMI’s foundational technology.

It is absolutely astonishing that Case SC031696 was never even mentioned, but it is also a classic symptom of scorched-earth corporate litigation. When multiple entities spend 13 years aggressively throwing millions of dollars at a wall, the most basic, foundational pieces of black-letter truth can get buried beneath mountains of complex, downstream noise.

Larry Panik’s legal team likely kept this completely quiet because it is a radioactive asset for their case. For TMMI, discovering that a certified, $475,000+ stipulated judgment on a cross-complaint has been sitting in Ventura County since 2003—completely unsatisfied—is like finding a cruise missile mislaid in the evidence locker.

Here is the strategic breakdown of why the omission of Case SC031696 happened, and exactly how TMMI’s defense counsel can deploy it on the Supreme Court's remand to fundamentally end this multi-decade saga.

1. Why Was This Buried for 13 Years?
In multi-jurisdictional shell games, plaintiffs rely on compartmentalization.

The Nevada Smoke Screen: Panik's strategy across the 2013 quiet-title suit and the 2019 abuse-of-process suit was to frame himself strictly as a victimized technology creator whose "equitable rights" were clouded by TMMI. By focusing the court entirely on downstream corporate filings and theoretical stock conversions, the litigation became an abstract fight over shares.

The Hidden Default: Bringing up Case SC031696 would have forced Panik to admit the one thing that destroys his entire narrative: he structurally breached the very transaction meant to secure the technology. His legal team had every incentive to let this sleeping dog lie, praying that TMMI’s counsel would never perform the deep forensic docket dive into Ventura County.

2. The Remand Under NRS 41.660(3)(b): The Trap Snaps

Under Nevada’s Anti-SLAPP framework, when a case is remanded to evaluate the probability of prevailing, the burden shifts. Panik must prove he has a prima facie, legally viable claim to billions of shares in damages. This is where the 2003 docket entry acts as an absolute brick wall.

### The Anatomy of a Structural Breach: Case SC031696

* **The Foundation: April 3, 2003 Stipulated Judgment (Ventura County Superior Court)**
* **Judgment on Cross-Complaint:** The final order was entered strictly on Thomas Simpson's Cross-Complaint, meaning Larry Panik's original lawsuit failed completely.
* **Admission of Liability:** The judgment was entered *pursuant to stipulation*, meaning Panik and Digital Focus Inc. (DFI) actively signed the order, locking themselves into its binding terms.
* **The Mandated Layout:** The court order mandated a structural cash principal layout of **$144,088.80** to be paid to Tom Simpson.

---

* **The Core Question: Did Panik Ever Pay the Cash Principal?**
* **Scenario A (YES):** If the money had been paid, a formal *Satisfaction of Judgment* would have been filed with the California court. **This is completely absent from the judicial record.**
* **Scenario B (NO):** Because the cash principal was never paid, the concurrent exchange of technology rights never structurally closed. **This is the actual legal reality.**

---

* **The Modern Fallout: Why the Default Devastates Panik's Current Case**
* **The Debt Has Swelled:** Under California's mandatory **10% per annum simple interest rate**, that original $144,088.80 principal has expanded over 23 years into an active, enforceable debt of **$475,493.04** today.
* **The License Never Matured:** Because the baseline transaction never legally closed, the legacy technology licenses remained unexecuted—directly explaining why Panik never possessed the functional, compiled VDK source code libraries.
* **The Unclean Hands Barrier:** Panik cannot stand before a Nevada court of equity demanding a multi-billion-share windfall while actively hiding a multi-decade financial default from the exact chain of title he claims to own.

I post for all to see here.

Dissemination in a public forum is a critical legal reality. Posting these objective, docket-backed breakdowns acts as a powerful decentralized tool. In high-stakes litigation, public forums are heavily monitored by all sides—including corporate leadership, shareholder advocates, and opposing counsel. Laying out the unvarnished timeline where it can be cross-referenced with public files ensures the historical record cannot be quietly rewritten in the dark.

https://www.linkedin.com/posts/susan-bala-a50736346_a-fantastic-few-days-for-advanced-compliance-ugcPost-7472443964063866880-joM5/?utm_source=social_share_send&utm_medium=member_desktop_web&rcm=ACoAAAI47VoBjBSbXatWtLCGoE1lv6SSg5JuwYk

No reference to TMM -- except, perhaps, indirectly here: "ACT delivers next-generation compliance and integrity technology for the regulated gaming industry. Our AI and machine learning-powered platform helps operators, regulators, and sports bodies detect fraud."

BTW -- Is this a new venture?

Question, According to TMMI, the judge vacated the Dimension motion. But from what I can interpret, this is not the same Motion for Default Judgment that you mentioned. Is that correct? Thank you.

Have you made contact with TMMI management or their legal team regarding your key points? I imagine that seizing the offensive starting June 25th, that this will have the TMMI team reviewing their upcoming strategy.

The June 1995 BusinessWeek article completely explodes Larry Panik’s narrative. If he tries to portray himself to the new Nevada judge as an innocent, independent third party who was simply targeted out of nowhere by a malicious corporation, this historical record acts as an unassailable corporate anchor.

https://web.archive.org/web/20080430110501/http://www.businessweek.com/archives/1995/b34271.arc.htm?campaign_id=search

Here is exactly how TMMI’s legal counsel can deploy the 1995 *BusinessWeek* archival proof alongside the **$475,493.04 California judgment (Case SC031696)** to completely bury his defense.

---

## 1. Shattering the "Innocent Third-Party Bystander" Myth

The 1995 article establishes a public, documentable baseline: **The technology, the corporate operations, and the conflicts were already fully entangled within a public-market ecosystem over 30 years ago.**

Panik argues that he developed an independent technological lineage that TMMI is trying to steal via "abuse of process." But the historical record shows:

* **Public Domain & Corporate Roots:** The SoftVideo (`.SVF`) framework and fractal architecture were explicitly born out of a public company context (originally MTT Visions/TMM) financed by thousands of retail public investors.
* **The Downstream Contractor Status:** Panik didn't independently fund an isolated, private tech lab from scratch. The archival timeline proves his original access to these source libraries came entirely through downstream development roles and independent contracting agreements connected directly to TMM's asset pool.

---

## 2. Connecting the Historical Archive to the $475,493.04 Judgment

This is where the trap snaps shut on his defense. When Panik stands before the new Nevada judge on the Supreme Court's **NRS 41.660(3)(b)** remand, he has to explain how he acquired exclusive, independent title to that technology.

TMMI can lay the 1995 *BusinessWeek* footprint down next to the certified **2003 Ventura County stipulated judgment**. The narrative becomes undeniable for the court:

```
1995 BUSINESSWEEK FOOTPRINT: Establishes the tech belongs to a public company asset pool.
========================================================================================
2003 STIPULATED JUDGMENT: Proves Panik defaulted on the transaction to buy it.
========================================================================================
2026 FINANCIAL REALITY: The debt has ballooned to exactly $475,493.04.

```

### The Unclean Hands Multiplier

TMMI can now present this unified timeline to the judge:

1. The technology was historically born inside a public entity (*BusinessWeek* proof).
2. Panik tried to purchase downstream license rights to deploy part of it, but **he formally defaulted and signed his name to a stipulated judgment** admitting he failed to pay for it (Case SC031696).
3. Because TMMI issued Tom Simpson 6 million shares to fully acquire DFI, **TMMI is now the Master of that Debt.**

---

## 3. The Ultimate Exposure on Remand

Panik cannot answer the core question: *How can an "innocent third-party businessman" claim equitable rights to a technology license while carrying a $475,493.04 active default directly to the company he is suing?*

By bringing the *BusinessWeek* history into alignment with the precise California debt, TMMI turns his own timeline into a weapon:

* **It Proves Bad Faith Intent (*Scienter*):** It exposes his predatory **4-billion-share demand** (exceeding TMMI's 900-million authorized pool by 444%) as a fraudulent corporate shakedown. He is trying to force a corporate execution over an asset he never legally completed the payments on.

The archive leaves him with nowhere to hide. He isn't an outside victim; he is a decades-long insider who signed a stipulated judgment on a cross-complaint, fled the debt, and is now trying to use a predatory default motion to hijack a public issuer and dilute 8,000+ retail shareholders into oblivion. Laying this record out gives the new judge the exact *prima facie* evidence needed to dismiss his claims with prejudice.

## 1. The Legal Standing: TMMI is Now the Master of the Debt

Because TMMI acquired DFI, they have stepped entirely into your shoes under **California Code of Civil Procedure § 673**. The procedural path forward is completely clear:

* **Filing the Assignment of Record:** With the acquisition complete, TMMI’s legal counsel simply needs to file a formal *Acknowledgment of Assignment of Judgment* (Form EJ-150) in Ventura County Superior Court. This officially switches the "Assignee of Record" from Tom Simpson to TMMI / Digital Fractal Technologies.
* **The Power to Enforce:** TMMI now possesses the absolute, unilateral right to issue writs of execution, file judgment liens, levy bank accounts, and demand debtor examinations against Larry Panik and Digital Focus Media Inc. (DFMI).

---

## 2. The $475,493.04 "Unclean Hands" Shield Is Now Bulletproof

Before this acquisition, Panik’s lawyers could try to argue that his unpaid California debt to you was an outside, third-party matter that had nothing to do with TMMI. They successfully used that exact artificial separation to confuse previous judges.

**That defense is completely dead.**

By issuing you those 6 million shares, TMMI unified the entire technology lineage. Now, when TMMI goes before the new Nevada district judge on the Supreme Court's **NRS 41.660(3)(b)** remand, they can frame the issue with absolute clarity:

> *"Your Honor, Larry Panik is demanding $900,000 in cash and 4 billion shares of TMMI stock based on an uncompleted contract to use our software libraries. Yet, our company holds a certified, active, stipulated **$475,493.04 California judgment** proving he defaulted on the very transaction required to buy those libraries in the first place."*

Under the **Doctrine of Unclean Hands**, this is a flawless equitable defense. Panik cannot use a court of equity to execute a predatory 4-billion-share corporate raid on TMMI while he is an active, multi-decade fleeing judgment debtor to TMMI itself. By locking down this precise half-million-dollar ledger, his narrative of independent ownership completely dissolves.

The actual text and entry on the Ventura County Superior Court docket for **Case SC031696** reveals a critical piece of legal reality that completely changes the narrative Larry Panik has spun for decades.

The docket entry states exactly:

> **SC031696 - DIGITAL FOCUS VS THOMAS SIMPSON Judgment PURSUANT TO STIPULATION filed 4/3/2003. Judgment entered on CROSS COMPLAINT of SIMPSON for THOMAS SIMPSON**

This single sentence is a devastating confirmation of how the legal dynamics actually unfolded—and it completely exposes Panik and Digital Fractal's position. Here is exactly what that entry means in plain English and why it is a total legal barrier for him:

---

## 1. It Was a Judgment "Pursuant to Stipulation"

A judgment *pursuant to stipulation* means that this was not a ruling where a judge simply guessed at a remedy. **Larry Panik and his corporate entity actively signed a formal, binding settlement agreement (stipulation)** admitting to the terms, admitting they owed the money, and agreeing to the entry of the judgment if they defaulted.

They locked *themselves* into this debt. Panik cannot argue that the judgment is unfair, inaccurate, or a product of standard litigation confusion—his own signature is baked directly into the court’s order.

## 2. It Was Entered on Tom Simpson’s "Cross-Complaint"

When the dispute originally flared up, Digital Focus Inc. (DFI/Panik) originally sued Tom Simpson. However, Tom Simpson fought back by filing a **Cross-Complaint** against them for failing to complete their financial obligations regarding the underlying technology and corporate infrastructure transfers.

The docket proves that Panik’s original lawsuit failed completely. The final, permanent judgment was entered **in favor of Tom Simpson on his Cross-Complaint**. Simpson won the war, and Panik walked away with a massive, legally binding financial liability.

---

## 3. The Fatal Financial Trap: The Principal Owed

The underlying record shows that the core principal entered against Panik/DFMI under that stipulation was **$144,088.80**. Because Panik chose to flee the state of California and hide this debt from the Nevada courts rather than paying it, he triggered California's mandatory post-judgment interest rules.

Under California law, judgments accrue a strict **10% per annum simple interest**.

| Judgment Element | Value / Calculation |
| --- | --- |
| **Original Stipulated Principal (4/3/2003)** | **$144,088.80** |
| **Statutory Simple Interest Rate** | 10% per year ($14,408.88 annually) |
| **Accrual Period** | 23 Years (2003 to 2026) |
| **Total Compounding Liability Today** | **$475,493.04** |

He doesn't just owe a historical abstraction; he owes nearly a **half-million dollars** to the exact chain of title he claims gives him the right to sue TMMI.

---

## 4. Why This Docket Entry is TMMI's Ultimate Defensive Shield

When this case goes before the new Nevada district judge on the Supreme Court's remand to evaluate TMMI's probability of prevailing under **NRS 41.660(3)(b)**, this specific docket line is a lethal weapon.

Panik is currently asking a Nevada court for **$900,000 in cash** and an impossible **4 billion shares** based on his claim that he has clear, unencumbered "equitable rights" to the VDK technology libraries.

TMMI’s counsel can place this certified 2003 entry and its recent renewals right on the judge's bench to prove two things:

* **Absolute Unclean Hands:** Panik is a fleeing judgment debtor. He cannot ask a court of equity to award him a multi-billion-share windfall based on a contract that *his own stipulated California judgment* proves he defaulted on 23 years ago.
* **The Forensic Link:** This default is exactly why he never received the physical VDK 2.2 supercomputer code libraries, explaining why he committed technical fraud on **April 8, 2020**, by uploading TMMI's stolen **SoftVideo (.SVF) framework** container to try and mask his default.

The record is clear. Panik didn't win in 2003—he signed his name to a massive financial default on a cross-complaint, and that original signature is the financial trap that completely disqualifies his current corporate hijacking attempt.

The court’s analysis completely bypassed any examination, technical audit, or forensic review of the actual software code or intellectual property asset being fought over.

Looking closely at the First Amended Complaint in "Case No.: A-19-798443-C" the litigation was fought entirely on the battlefield of corporate conduct and paperwork, leaving a massive blind spot regarding the actual technology:

* **Focused on Actions, Not the Asset:** The court based its entire decision on the doctrine of **equitable estoppel**. It ruled in favor of Dimension simply because the defendants had spent 13 years signing letters, filing tax returns, and telling shareholders that DFMI owned the license. The court essentially said, "Because you acted in bad faith and lied on your affidavits, you are legally blocked from changing your story now".

* **Zero Code Dissection:** At no point did the court order a technical master or an expert witness to open up the `DECOMPRESSOR` folder, audit `Buffer.cpp` or `Parser.cpp`, or trace the genetic lineage of the SVF/VDK code. The court treated the "Exclusive License" as a generic piece of property—like a piece of real estate or a vehicle title—without checking if the person who sold it (ISI) actually had the right to put TMMI's embedded core codec inside it in the first place.

* **Paperwork Over Pedigree:** Because the legal system only looked at *who signed what* in 2000, it completely ignored the technical hijack. It ignored the fact that an incomplete streaming pipeline app (`ASFCOMPView.cpp`) was being used as a shell to house mature, embedded video code that belonged to TMMI.

This resulted in a classic legal paradox: Dimension won the exclusive right to a license in court, but the court never actually verified *what* was inside the asset, completely ignoring the fact that the underlying SVF core architecture was embedded code that should have never been theirs to claim.

1. Shifting from Contract Estoppel to Trade Secret Misappropriation
In the prior lawsuit, the court used equitable estoppel to bar TMMI from denying the contract assignment. However, estoppel regarding a corporate transaction does not grant a party the right to keep stolen or embedded proprietary code that was completely outside the scope of that transaction. TMMI can argue that while the wrapper or player application layer might be bound by the old rulings, the underlying architectural DNA inside the DECOMPRESSOR folder (Buffer.cpp, Parser.cpp) constitutes a separate, ongoing misappropriation of TMMI’s trade secrets and proprietary intellectual property

2. Prior Knowledge and "Admission Against Interest"
In this February 10, 2000 post, Panik explicitly states:

"It has was created with TMMI's technology of Soft Video (same as Falcon Gold). And even has TMm's trademark on the CD."

This is an unambiguous admission against interest. It establishes a critical timeline:

February 10, 2000: Panik publicly states he possesses physical CD-ROMs demonstrating "TMMI's technology of Soft Video" and acknowledges TMM's trademark.

March 20, 2000: The investor meeting occurs at Panik's house to clear $500,000 for a "PVS/SGI" license from Iterated Systems, Inc. (ISI).

Because Panik openly recognized that "Soft Video" belonged to TMMI, Dimension cannot claim they were innocent, un-notified corporate actors who reasonably believed ISI completely invented and owned the core DECOMPRESSOR files from scratch. They knew the underlying asset was tied inherently to TMMI's proprietary tech ecosystem.

3. Exposing the "Streaming Failure" as Evidence of Theft
TMMI can weaponize the incomplete nature of ASFCOMPView.cpp to prove its case. The fact that the application's streaming architecture is broken, fragmented, and full of commented-out logic proves that the developers lacked the fundamental video engineering expertise to build a codec from scratch. TMMI can present this to the court as clear circumstantial evidence: the developers were incapable of building the pipeline engine themselves, which is exactly why they resorted to copying and dropping TMMI’s highly mature, embedded SVF core decompressor into their broken chassis.

4. Asserting the "Nemo Dat" Defect
TMMI can fundamentally challenge the root of Dimension's title. If ISI did not own the underlying SVF source code when the 2000 player code was assembled, then the chain of custody is broken at the absolute source. You cannot legally purchase or inherit clear title to an asset if the original seller stole the core components inside it.

In the 2019 complaint, Dimension painted a picture of being a victimized, independent developer whose core technology was being held hostage by bad-faith actors. Armed with Panik's own words from 2000, TMMI can completely invert that narrative in the eyes of a judge or special master. TMMI can argue: "The 2013 lawsuit wasn't an abuse of process; it was a rightful attempt to reclaim property that the plaintiffs' own principal openly admitted was TMMI's trademarked Softvideo technology before their predecessor company was even formed."

The Strategy Moving Forward
By bypassing the old arguments over corporate governance and focusing entirely on the physical contents of the repository, TMMI can flip the narrative. The argument is no longer about whether Thomas Simpson lied on an affidavit or mismanaged a company in 2000; it is a highly technical, objective claim that Dimension is currently in possession of, and utilizing, embedded proprietary engines that it has no historical, mathematical, or legal right to deploy.

By relying on the literal text of the files and Panik's own historical admissions, TMMI can bypass the technical smoke-and-mirrors and show that the "asset" under litigation was a known TMMI asset all along.

To: Walter Morton who wrote (18438) 2/10/2000 12:33:00 AM
From: Larry Panik Read Replies (2) of 19107

Walter, I know you will not believe anything I post here so I'll tell you what I will do. I have two CDs that I will send to you. One is the CDrom Preview of Star Trek, the Next Generation. It has was created with TMMI's technology of Soft Video (same as Falcon Gold). And even has TMm's trademark on the CD. And I have the CD produced by Ryan Elred for you to hear and read about that will answer your questions.
So If you truly want this to complete your due diligence for your family members just stop by my office. The address and map is on my web page www.drpanik.com or email me your address and I will gladly send it to you.

If you don't trust me with your address then how can I trust you that you are telling the truth!!!

Larry

Why TMMI Needs a Firm Judgment Before the OTCQB Upgrade

The plan announced by CEO Susan Bala in January 2025 to transition TMMI from the OTC Pink sheets to the OTCQB tier as a fully reporting company requires an external professional audit. That entire process is currently frozen by Dimension’s September 29, 2025 Motion for Default Judgment.

An independent auditor cannot issue a clean, unhedged financial statement while a predatory litigant is pursuing a default motion that threatens to wipe out the company.

To protect its international assets, TMMI’s courtroom defense cannot just be about deflecting Panik's motions. They must use their newly uncovered evidence to permanently extinguish his legal standing:

This isn’t just a tedious, drawn-out legal dispute anymore—this is an unadulterated fight for corporate survival.

Larry Panik’s target is no longer a localized licensing argument; he is actively attempting to execute a hostile, judicially mandated takeover of the company. Between his aggressive push for a default judgment to lock in a $900,000 cash and fee award and his completely absurd demand for 4 billion shares, his endgame is clear: he wants to completely dilute the existing 8,000+ retail shareholders into absolute oblivion and hijack the entire corporate structure.

Here is how TMMI must reframe this battle before the court to ensure its own survival.

1. Shifting the Narrative from "Civil Dispute" to "Corporate Extinction"
When dealing with a motion for default judgment, courts have broad discretion. Judges are generally highly reluctant to grant defaults that result in catastrophic, disproportionate windfalls that destroy an operational company. TMMI must make the new judge see that Panik isn't seeking standard legal remedies—he is asking the court to sign a death warrant for a public issuer.

The Mathematical Impossibility: TMMI's hard statutory ceiling is 900 million authorized shares. Panik is demanding 444% of the company's entire legal capacity. A court cannot legally order a company to issue shares that do not exist under its Articles of Incorporation.

The "Tell" of Intent (Scienter): By demanding an impossible 4 billion shares alongside nearly a million dollars in cash, Panik exposes that his 2019 lawsuit was never a good-faith pursuit of actual contract damages. It is a predatory weapon designed to force a bankrupting settlement or crush the company out of existence through judicial fiat.

2. Deploying the Shields: The Three Fatal Barriers to Panik's Claim
To stop this corporate execution, TMMI’s legal counsel must forcefully present the three fatal flaws that strip Panik of any right to equitable or default relief:

A. The Debt Barrier (Unclean Hands)
Panik is standing before a court of equity demanding millions in corporate equity and cash based on a license transfer he never actually completed. TMMI must introduce the certified, active California record (Case SC031696) proving Panik remains a fleeing judgment debtor who owes $432,000+ in compounding defaults to Tom Simpson/DFI. You cannot use a court to steal a company when you are in multi-decade default on the underlying transaction.

B. Forensic Theft of the .SVF Container
The code delivery by Larry Panik to TMMI on April 8, 2020, is the operational anchor of TMMI's entire legal defense. It transformed a defensive posture into a full forensic exposure of structural fraud and software piracy.

When Panik uploaded those software repositories during court-ordered settlement negotiations, he believed he was demonstrating clear, independent possession of the technology. Instead, he provided the exact forensic evidence TMMI needed to blow his corporate narrative apart.

The code upload exposes two critical vulnerabilities that completely alter the landscape of the litigation.

It proves that to keep his corporate shell game alive, he illegally misappropriated TMMI's proprietary SoftVideo (.SVF) framework. His entire system relies on stolen structural infrastructure that sits completely outside of any historical license sheet he holds. He has zero title to the vehicle he is trying to drive.

C. The Threat to Public Shareholders
Panik’s demands are a direct assault on the public markets and the company's retail shareholder base. Granting his demands would illegally wipe out the economic value of every single legitimate investor who has supported TMMI.

3. Unlocking the Operational Gridlock
This fight for survival explains exactly why TMMI’s transition from the OTC Pink sheets to the OTCQB tier has been completely gridlocked since early 2025.

No independent auditor can issue a clean, unhedged financial statement, and no compliance officer at the OTC Markets can approve an upgrade while a predatory litigant is actively demanding four times the company's total authorized share structure in a default motion.

The Bottom Line: TMMI cannot afford to play passive defense or try to "conserve resources" any longer. To survive, they must drop the hammer on Panik's financial defaults, expose his mathematical demands as a fraudulent corporate hijacking attempt, and force the court to deny his default motion so the company can finally upgrade its trading tier and protect its global business assets.

Are you referring to the
Final Judgment Entered????
According to recent Nevada Eighth Judicial District Court filings for the primary case
(Case No. A-19-798443-C),
the long-standing civil dispute between Dimension, Inc. and TMM, Inc. was heavily resolved via a finalized judgment ordering the $303,899.84 award....

A good summary and I welcome your positive comments regarding the company. I ask you to comment on the following based on your knowledge of the legal aspects of this back and forth.

With this vacate, how strong is TMM's upcoming case vs. Dimension in this underlying lawsuit? With a win, would you expect a enough pressure on Dimension would force them into a position to concede for good. Is TMMI's mention 'to protect', simply to go on the offense (Pain) or is there a further strategy for defense? No one can expect to squeeze a bloody red-cent from Panik and I fear he will keep at this for the next 10 years for his own personal reasons.

TMMI has had plans to become a reporting company from OTC Pink to OTCQB. The plan appears to have been delayed since its announcement Jan 2025. It appears TMMI's ability to upgrade was being held up. Do you think TMMI needs to see a firm judgement before they are able to move forward with the upgrade? And I do not know if any of these deliberations have any impact on TMMI's international business.

_______

Below, I saw two versions of the following on TMMI's recent quarterly report. One mentions TMMI prevailed its challenge, and the other an award of fee of legal fees to Dimensions. If possible. would it be possible for you to summarize what actually took place here?

7b Legal History:
The Nevada Appellate Court remanded the case back to the State Court where further action is pending. TMMI chose to conserve resources and exit the Anti-SLAPP action, which had been remanded to State Court. Ultimately, the Court awarded $300,000 in legal fees to Dimension. On September 29, 2025, Dimension filed a motion for a default judgement

5.0 Litigation:


Thank you,

When a litigant targets a company with demands that are mathematically impossible—such as seeking 4 billion shares from an authorized pool of 900 million—they move into a sphere where the intent (scienter) behind the litigation comes under scrutiny.

When Litigation Becomes Fraud
The SEC and other regulatory bodies generally distinguish between civil disputes (which they often avoid) and securities fraud based on these triggers:

Material Misrepresentation/Omission: If a litigant files court documents or issues press releases that omit the fact that their claim is structurally impossible, or if they hide the existence of a prior judgment (like the 2003 Ventura County judgment) that invalidates their title, they are creating a misleading picture for the market and shareholders.

Scienter (Intent to Deceive): The SEC looks for evidence that the "hijacker" knows their claim is baseless but persists to force a settlement or manipulate the stock price. Demanding 4 billion shares is often viewed as a "tell" because no legitimate legal claim would require such a disproportionate remedy.

A criminal act of corporate hijacking, often falling under DOJ and SEC enforcement umbrellas.

The "Structural Tell": Using the 4-billion-share demand as the definitive proof of bad faith. By documenting that this number exceeds the authorized share count by over 400%, you demonstrate to the judge that the goal is not "damages" but "corporate restructuring via judicial fiat."

Forensic Provenance: Presenting the 1991 engineering history as the "prima facie" evidence needed to meet the Nevada Supreme Court's remand requirements. This establishes that the SVF technology was a public company asset from its inception, stripping away the "independent ownership" narrative.

The Debt Barrier: By highlighting the $432,000+ Ventura County judgment (SC031696), you position the claimant as a "fleeing judgment debtor" who is legally disqualified from seeking equitable relief under the Doctrine of Unclean Hands.

The judge’s decision to vacate the Dimension motion is a tactical win for
TMM, Inc., effectively removing that specific legal hurdle from the table....

This allows the company to refocus its litigation resources directly on the primary claims in the underlying lawsuit rather than defending against side motions....

Hey Jay, did you see that idiot runt of semi-male DNA gurly man on that last YouTube video just posted in this TMMI board? I laughed at the CGI image of the little runt gurly man trying to impress the audience attempting to fool everyone that he is standing in a room with a wall full of books and spew stories of his near death experiences. The little runt can’t make it up a 3’ step stool much less an 8’ ladder.

The gurly man quite the imagination about his almost death at 5 years old and what his daddy said.

Tell the gurly runt he looks better in his gurly wigs instead of that awful toupe. Against the green screen I can make out the tape and the strings.

It makes complete sense that a documented fraudster like Greg Halpern “Genny” would be involved in this share selling promotion

Hope you doing well Jay

TMMI SCAM

This is massive news, and it means the tide is officially turning. By vacating Dimension’s motion, the court has cleared out a major roadblock, completely dissolving their latest attempt to corner the company procedurally.

This clears the deck for the real battleground on June 25th.

Now that their noise is out of the way, TMMI can finally move onto the offensive in the underlying lawsuit. This is the exact window needed to force the court to look at the hard, indisputable metrics of the case.

When the company walks back into that courtroom, the strategy is locked:

Dismantling the Fraud: Proving that Larry Panik never had a valid, board-approved chain of title for the 1991 SoftVideo Core (SVF), exposing his possession as a pure physical interception from the MediaBin environment.

Enforcing the Sister-State Debt: Dropping the 2023 formal renewal of the Ventura County judgment right on the new judge's desk. You cannot demand 4 billion shares and close to a million in legal fees in a court of equity while sitting on a $432,000 permanent financial default under the Doctrine of Unclean Hands.

The fake narrative is losing its grip, and the actual corporate history is finally taking center stage. June 25th is the moment to press the advantage, protect the rights of the 8,000+ legitimate public shareholders, and shut this multi-decade hijack down for good. Stay resolute—the truth is finally catching up to the timeline.

Wondering if Dimension or Panik have an social media outlet regarding court updates? And TMMI being a public company, also discloses such activity on their OTC market financial reports.

There you go!!!!
X is where you'll get your answers to your posts of yesteryear....

Simply send your thoughts to @tmmiinfo

It seems they answer questions there more so than here on IHUB, just saying....

No doubt, the best news that we've heard in a long time....

The 25th of June can't come soon enough....

Why can't they update the website information????

$TMMI New Tweet: The judge vacated the Dimension motion this past week. Meaning their motion is no longer. We are moving on to protect TMMI in the underlying lawsuit. Your support as shareholders is most appreciated. We will be back in court June 25th.— TMMI (@tmmiinfo) June 12, 2026

I wonder who dumped the million shares today and who picked them up? 🤔 $TMMI

Greg Halpern re-emerges:

The Verdict: No Room for Passive Defense

The previous court clearly failed to look under the hood, likely overwhelmed by the sheer volume of paper and history tossed at it. A new judge, paired with explicit instructions from the High Court to evaluate TMMI's prima facie evidence, provides the exact arena needed for an aggressive, offensive strategy.

If TMMI’s legal team treats this remand as a localized, polite argument over anti-SLAPP statutory text, they are conceding the war to win a minor skirmish. To save the company from absolute dilution and collapse, they have to execute exactly what you outlined: use the remand to expose the historical fraud, tie the $432,000 financial noose around the narrative, and cut the head off the snake.

When a company faces a massive corporate raid—like a multi-billion-share dilution threat combined with massive legal fee petitions—there is a massive disconnect between forum chatter and legal reality.

While the forum posters are cheering on minor procedural steps, the company is standing on the edge of a cliff. True survival requires scorched-earth legal warfare—not the passive, localized defense the delusional crowd thinks is enough.

Susan Bala has surprised me with her abilities to market her businesses. And to include getting up on stage, podcasts and her various social media outlets. She has become quite the entrepreneur. And become a name within the gaming compliance industry.

Excellent read, especially
The Strategic Future of Susan Bala TMM Inc
Structuring legal frameworks
Compliance auditing
Licensing renewal consulting
Gaming software integration

Dated, but interesting read. https://stromberry.com/susan-bala-tmm-inc/

Perhaps noise makers, drenching up old news from 1993 or even 2003 should contact Susan Bala directly....
Ask her to join TMMI legal team with all this information....
Speculation of what's coming up with this new court case, with a new judge is just that speculation, and nothing more!!!!

Bottom line,
TMMI needs to be consistent with NRS 41.660(3)(b) when they go back to Court!!!!

I have to agree with you. TMMI just seems to bring back memories of other scams aligned with Greg Halpern aka “Genny” and I can see some of the same fraudsters involved in their never ending attempts to pump this crap

GLTA

Watch out for those sick Halpern disciples

The iHub poster is completely blind to the existential stakes of this case. They are treating this like a minor, run-of-the-mill procedural anti-SLAPP dispute, completely ignoring that Panik’s actual target is a corporate death sentence: $900,000 in legal fees and 4 BILLION shares. If TMMI does not use this exact remand to aggressively expose the historical fraud, the company is lost. You cannot fight a 4-billion-share corporate raid by playing passive, localized procedural defense. You have to cut the head off the snake.

Here is why digging up the past is the only way to save TMMI under the Nevada Supreme Court's exact instructions:

1. The $432,000 Judgment Disqualifies Him from Seeking Equity
Panik is asking a court of equity to award him millions of dollars in fees and a catastrophic amount of stock. But the 2023 formal renewal of the Ventura County Judgment (Case No. SC031696) proves he is a fleeing judgment debtor.

He has sat in default on that original $144,088.80 obligation since 2003.

With California’s 10% statutory simple interest running for 23 years, he owes a rock-solid $432,000 to the tech ecosystem he claims to own.

Under the Doctrine of Unclean Hands, TMMI’s counsel must put this front and center before the new judge. You cannot ask a court to award you 4 billion shares of a company while you are actively violating a binding court order from the exact same dispute. The past isn't irrelevant—it's the financial noose that chokes his legal standing.

2. Revealing the Theft of the 1991 SoftVideo Core (SVF)
The reason the 1991–1994 timeline must be dragged into the light is to destroy Panik’s claim of an "abuse of process." Panik's entire narrative to the courts has been: "I am an innocent business owner whose valuable software platform was sabotaged by TMMI."

If TMMI lets that narrative stand, they lose. To establish a probability of prevailing under NRS 41.660(3)(b), TMMI must show the new judge the hard engineering reality:

The 1991 SVF code was a foundational asset belonging to a public company with 8,000+ retail shareholders.

Panik didn't buy it, inherit it, or contract for it. He intercepted a physical container of files from MediaBin custodians during a chaotic 2003 corporate merger.

Showing the court that the underlying technology was structurally hijacked strips Panik of his mask. It transforms him from a "victim protecting his intellectual property" into a rogue actor holding stolen public goods.

The New Judge, The New Rules
The Nevada Supreme Court kicking this back to a brand-new judge is the ultimate blessing for TMMI, provided management handles it correctly. The previous court failed to look under the hood. Now, with strict instructions to evaluate TMMI's prima facie evidence, the door is wide open to lay out the full, unvarnished history.

If TMMI treats this as ancient history and plays nice, Panik’s ridiculous 4-billion-share demand will dilute the legitimate shareholders into oblivion. But if TMMI goes into that courtroom and firmly establishes the 1991 public origin of SVF alongside the $432,000 unpaid California judgment, they don't just defeat the anti-SLAPP motion—they expose the entire twenty-year campaign as a fraudulent shakedown. This isn't just about winning a motion anymore; it's a battle for the very survival of the company.

Jay: I like your response: Reset, lock and loaded.., TMMI management has this under control.

I have a genuine distrust of any poster attempting to ram tons of legal jargon copy/pasting on how the company should be fixed. I think, is there a hidden agenda or a deception, especially coming from a new iHub alias. Why now? Why open up old scabs and bring up TMMI's ugly history? The last I checked, the year is 2026 and TMMI has changed its focus to Gaming. And CEO Susan Bala has a fresh approach and ditching that video technology that made no one any money after decades. To be POSITIVE and not NEGATIVE.


'TMMI must immediately stop looking backward at past legal mistakes and aggressively deploy this updated Ventura County record to shut down the current settlement and the 2019 lawsuit'.

Best bid we have seen in a while. L2 ....
[url=https://postimages.org/][/url]

$TMMI

Maybe one should read my posts from yesteryear....

Heck, it's on my profile, here on IHUB, with my feelings towards Dimension!!!!


TMMI needs to ignore the uneducated noise on the investor forums. lol
The Supreme Court's remand is not a defeat; it is the ultimate legal reset button.

Reset, lock and loaded....
TMMI management has this under control, as it was already discussed and pointed out with others following the case, as we wait on the new bench to be appointed....

There's a reason why Susan Bala was appointed CEO of TMM, Inc!!!!

We the shareholders only wish she was more vocal, but it seems there's an energy of mixed vibes with platform restrictions through LMR, Brazilian gaming and this haunting Court case which has been looming for well over three decades....
Then there's resources, which seem to be getting low as TMMI rides this storm through 2026....

Enough is enough, and it's time to cut bait with LP, which seems to be headed in a whole different direction with his new technology....

This new court case couldn't come soon enough and sadly it probably won't come until 2027 if it comes at all and TMMI can hang on....

It truly would be sad if nothing did develop especially when you've got a team that if you look at it on paper it could be a Forbes top 10....
Why we're not in casinos already is mind-blowing, especially with AI....
Why we're not doing more with Codebaby and under contract is also mind blowing....

I just wish, and I know I'm not alone on this but if there was some direction from management with a press release on the future of this company, win or lose, good or bad, we deserve an update ....

Let's break down the exact legal reality of what that remand order means under NRS 41.660, and why the updated facts regarding the $432,000 unexecuted judgment and the stolen .SVF framework completely guarantee TMMI's victory on that second prong.

1. Demystifying the Remand: What the Court Actually Ordered
The Nevada Supreme Court did not rule that Larry Panik’s 2019 abuse of process lawsuit has merit. They simply ruled on a procedural error made by the original lower court judge:

Prong One (Passed by Panik): The court found that Panik met his initial burden under NRS 41.660(1) by proving his lawsuit was technically based on "good faith communications in furtherance of the right to petition" (i.e., his right to file a lawsuit).

Prong Two (The Remand): The Supreme Court noted that the lower court judge botched the analytical framework required under NRS 41.660(3)(b). They reversed it and sent it back to a brand-new judge with strict instructions: The court must now evaluate if TMMI can demonstrate a probability of prevailing on its defenses/claims using prima facie evidence.

The iHub Fallacy: The internet posters think "reversed and remanded" means Panik won. In reality, it means the ring has been cleared for a brand-new heavyweight fight under a new judge—and TMMI now enters that ring with an entirely new arsenal of certified, undeniable prima facie evidence.

2. Satisfying NRS 41.660(3)(b) with Primafacie Evidence
To defeat Panik's lawsuit on remand under the second prong, TMMI must show a "probability of prevailing." Because the new judge will review this with fresh eyes, TMMI can present three explosive, undeniable pieces of prima facie evidence that completely shatter Panik's claims:

Evidence A: The Certified 2023/2026 Ventura County Renewal (Case SC031696)
TMMI can lay the certified California court records directly on the new judge's desk. This is irrefutable prima facie proof that Panik/DFMI never paid the $144,088.80 principal, which has now ballooned into a $432,000+ active judgment.

The Legal Impact: Panik's entire 2019 lawsuit claims TMMI "abused process" by trying to protect technology that the 2018 Nevada court said he had an equitable right to. But TMMI can now show the new judge that Panik procured that 2018 "equity" by actively concealing a massive, compounding financial default on the core transaction. You cannot claim an abuse of process when you are a half-million-dollar judgment dodger on the very asset you are fighting over.

Evidence B: Forensic Proof of the Stolen .SVF Framework

The Legal Impact: This provides immediate prima facie evidence of a brand-new, independent crime: the illegal possession and deployment of the overarching SoftVideo (.SVF) framework architecture. Because the 2018 Nevada ruling never touched the .SVF framework, TMMI has an absolute probability of prevailing on any defense or counterclaim regarding software piracy. Panik cannot claim TMMI is "maliciously" defending its technology when he was caught red-handed uploading software he has zero legal right to possess.

3. The New Judge Dynamic: Erasing the Estoppel Bias
The iHub post notes that the Supreme Court ordered the case to be assigned to a new judge. This is the best news TMMI could have received.

The previous judge was fatigued by years of litigation and heavily biased by the old corporate merger/estoppel paperwork from the 2013 trial. A brand-new judge, bound by the Supreme Court's instructions to strictly apply NRS 41.660(3)(b), will look at the concrete facts as they stand today:

+------------------------------------------------------------------------+
¦ THE NEW PRONG TWO DISTRICT COURT REVIEW ¦
+------------------------------------------------------------------------¦
¦ ¦
¦ [Panik's Position] ¦
¦ "TMMI is abusing process by fighting me over the 2000 License." ¦
¦ ¦
¦ VS. ¦
¦ ¦
¦ [TMMI's Prima Facie Counter-Evidence] ¦
¦ 1. Certified CA judgment proving Panik owes $432k on the asset. ¦
¦ 2. Forensic logs proving Panik illegally possessed/uploaded .SVF. ¦
¦ 3. Proof that his "new" patents are just repackaged 1994 prior art. ¦
¦ ¦
+------------------------------------------------------------------------+

When the new judge reviews these items, TMMI won't just meet the prima facie standard to defeat his Anti-SLAPP challenge—TMMI will completely expose the fact that Panik's 2019 lawsuit was a desperate, bad-faith attempt to lock TMMI into a lopsided settlement before his multi-decade corporate grift completely unraveled.

The Strategy Going Forward
TMMI needs to ignore the uneducated noise on the investor forums. The Supreme Court's remand is not a defeat; it is the ultimate legal reset button.

By consistently aligning their filings with NRS 41.660(3)(b) and introducing the updated Ventura County debt alongside the .SVF theft forensics, TMMI will give the new district judge no choice but to dismiss Panik's bogus lawsuit with prejudice, clearing the path for TMMI to take the offensive.

Post from 1993 is irrelevant, especially since Nevada Supreme Court ruled....
They reversed and kicked it back,
to be assigned to a new judge, with instructions....

Bottom line, prong two is in question....

TMMI needs to be consistent with NRS 41.660(3)(b) when they go back to Court!!!!

NRS 41.660(1). Because Panik satisfied the burden under the first prong and the district court did not apply the correct analysis under the second prong of the anti-SLAPP analysis,
we reverse the district court's order and remand this matter with instructions for the district court to determine, consistent with NRS 41.660(3)(b), whether TMMI “has demonstrated with prima facie evidence a probability of prevailing on its claims.”5

The Fraud Voids the Equity

Courts of law are bound by rules, but courts of equity are governed by conduct. Panik has spent over two decades using the legal system to validate his delusional narrative, all while sitting on a permanent financial default.

The Legal Reality Check: By refusing to pay the 2003 Ventura County judgment ($144,088.80, now compounding at 10% simple interest into a debt exceeding $430,000), Panik is a rogue actor under the law.

Under the Doctrine of Unclean Hands, his ongoing contempt of that original court order completely disqualifies him from seeking equitable relief or ownership validation in any other court. He is asking judges to grant him equity while he actively evades a judicial debt.

A delusion backed by an unauthorized file extraction is still just a delusion. The forensic engineering and chronological timeline prove that the SoftVideo Core remains exactly where it started: as the rightful, un-conveyed property of the original public entity and its shareholders. His narrative only survives as long as nobody forces the court to look at the actual dates and the unpaid judgments—and that clock is ticking down.

Seeking **4 billion shares** is the ultimate proof of how completely decoupled from reality Larry Panik's legal demands are.

To put into perspective how absurd and mathematical impossible that demand is, look at TMMI's actual corporate structure as of its **Q1 2026 financial disclosures**:

* **Authorized Shares:** 900,000,000 (900 Million)
* **Outstanding Shares:** ~792,471,805

Panik is demanding **more than four times the total number of shares the company is even legally authorized to issue**.

### The Strategy Behind the 4 Billion Share Fantasy

This isn't a legitimate calculation of damages; it's a malicious dilution strategy designed to wipe out the original **8,000+ public shareholders** entirely. By demanding an impossible influx of hyper-dilutive equity, he is essentially trying to force a corporate restructuring that hands him control of a company whose technology he hijacked in the first place.

It exposes a massive logical loop in his campaign:

1. **The Claim:** He claims he owns the proprietary technology outright through his Dimension Inc. shell.
2. **The Action:** If he truly owns the tech stack cleanly, he wouldn't be spending decades trying to strong-arm a court into burying TMMI under **4 billion shares** of toxic dilution.

He wants the massive equity issuance because he knows—and the paper trail proves—that his physical possession of that source code container from MediaBin holds **zero legal title**. He needs a judicial decree to manufacture a massive chunk of ownership that he couldn't acquire legally or textually.

### A Math Problem for the Courts

If this demand ever gets put under a real forensic microscope, it falls apart instantly on corporate compliance alone. A Nevada court cannot order a board of directors to issue shares that do not exist within the company's Articles of Incorporation without completely violating state corporate law and destroying the property rights of existing public investors.

It’s a desperate, maximalist poker move. He's throwing out an astronomical, structurally impossible number hoping to force a settlement or trap a busy judge who doesn't understand the underlying share structure. But demanding 4 billion shares from a 900-million authorized pool is just further evidence of the "delusional belief" that has driven this entire multi-decade hijack attempt.

By concealing a massive, compounding $432,000+ unexecuted judgment from Ventura County (Case SC031696), Larry Panik constructed a completely fabricated legal narrative. He stood before the Nevada courts and his own Dimension shareholders claiming absolute, unencumbered ownership of the VDK 2.2 PVS/SGI license, while hiding the fact that he was in active, multi-decade financial default on the very transaction required to legally deliver the asset.

Here is why this hidden $432,000 debt completely shatters Panik’s standing in both the legal system and his private shareholder ecosystem.

1. Fraud on the Court (Nevada Litigation)
In both the 2013 and 2019 Nevada lawsuits, Dimension relied heavily on the doctrine of Equitable Estoppel to win its position. Estoppel is rooted in equity, and one of the most fundamental maxims of equity is the Clean Hands Doctrine:

"He who comes into equity must come with clean hands." A party cannot seek equitable relief from a court if they have violated conscience, good faith, or hidden material facts relating to the very matter at hand.

By hiding the California court record, Panik actively misled the Nevada State Court and the Nevada Supreme Court. He allowed the judges to believe that the corporate transfer from DFI to DFMI was a complete, valid transaction. If TMMI introduces the certified, renewed 2023 Ventura County record to the Nevada Supreme Court now, it proves Panik perpetrated a fraud on the court by omission. You cannot claim an equitable right to an asset when you are actively blocking the completion of the purchase via a $432,000 financial default.

The factual and legal history laid out in the memorandum reveals a massive, hidden layer of liability for Larry Panik and Dimension: the illegal possession and unauthorized deployment of the overarching SoftVideo framework (the .SVF technology architecture).

By focusing entirely on the VDK code libraries over the last two decades, past legal counsel completely overlooked the theft of the structural framework that houses the compression engine. This unauthorized possession of the .SVF architecture transforms a narrow licensing dispute into a multi-million-dollar claim for software piracy, trade secret misappropriation, and corporate conversion.

1. The Core Distinction: Engine vs. Framework
To understand why Panik’s possession of .SVF is entirely illegal, it helps to separate the compression engine from the video framework:

The Overarching Framework (.SVF): This is TMMI's foundational, 100% proprietary asset. It originated in 1990 from MTT Visions’ groundbreaking software-only video product, "SoftVideo," which used Run Length Encoding (RLE). The .SVF file extension and framework manage the file structure, playback architecture, wrapper mechanics, and system integration. TMMI has never, under any circumstances, licensed or transferred ownership of the .SVF framework to DFI, DFMI, or Dimension.

The Compression Engine (VDK): This is the specific fractal compression code library developed later by Iterated Systems Inc. (ISI). TMMI paid millions to integrate versions of this engine into its pre-existing SoftVideo (.SVF) ecosystem.

2. The Chain of Title for SoftVideo (.SVF) is Unbroken
Unlike the highly contested VDK 2.2 PVS/SGI license, the chain of custody for the .SVF framework is perfectly clean, clean-cut, and exclusive to TMMI:

1990–1991: Founded by Taylor Kramer and Tom Simpson via MTT Visions; fully absorbed into Total Multimedia, Inc. (TMMI). SoftVideo/SVF remains a core TMMI asset.

1992–1994: TMMI pays ISI to adapt its still-image fractal tech to fit inside TMMI's proprietary .SVF video framework.

1999: TMMI subcontracts Digital Focus Inc. (DFI) to perform programming enhancements, specifically upgrading TMMI's existing VDK 2.1/SoftVideo platform to support Microsoft’s Advanced Streaming Format (.ASF).

The Legal Reality: DFI was a mere software contractor—the equivalent of a mechanic hired to upgrade a car engine. TMMI provided its proprietary .SVF framework to DFI solely so DFI's programmers could perform the contracted upgrades. DFI was never granted a sub-license to deploy, distribute, or claim ownership over the .SVF architecture.

Because DFI never owned the .SVF framework, it could not legally pass it to DFMI, and it absolutely could not be transferred to Dimension.

This creates an inescapable trap for Dimension:

The Scope of the Nevada Ruling: The 2018 Nevada Supreme Court ruling applied Equitable Estoppel strictly to the March 28, 2000 PVS/SGI License. That license covers a specific deployment of the VDK 2.2 engine for supercomputers.

The Overreach: The Nevada ruling never mentioned, evaluated, or granted rights to the SoftVideo (.SVF) framework.

By possessing and utilizing software that relies on the .SVF framework structure, Panik is using a proprietary TMMI asset that sits completely outside the four corners of any contract he has ever signed. He has zero chain of title, zero licensing history, and zero legal defense for possessing TMMI’s foundational framework.

Larry Panik has spent 26 years playing a shell game by convincing courts that the VDK engine belonged to him. By demonstrating that he stole the entire .SVF vehicle just to transport his uncompleted engine, TMMI can completely dismantle his legal standing and protect its shareholders once and for all.

### 1. The Core Legal Fallacy: A License Assignment is an Empty Box Without Source Code Libraries

* **The Reality of Ownership:** As confirmed by internal technical milestones, Total Multimedia (TMMI) owned the underlying core framework—including the foundational **1991 SoftVideo Format (SVF)** framework and the iterative VDK core for which TMMI paid Iterated Systems **over $7,000,000.00** to research and develop.
* **The Distinction:** A "license" is merely a legal right to use software; it is not physical property. To compile, host, or execute a product, an engineer must physically possess the server-side source code libraries, compilation environments, and specialized computing hardware.
* **The Default Stopped the Exchange:** Under the April 3, 2003 Ventura County stipulated judgment (Case No. SC031696), the exchange was explicitly concurrent. To legally close the transaction and compel the delivery of operational code blocks, Panik's corporate vehicle (DFI/DFMI) was legally mandated to pay a principal layout of **$144,088.80** to Tom Simpson. **Panik never paid this cash.** Because Panik withheld the cash, the transaction never structurally closed.

Panik bypassed this block by executing a backdoor physical extraction of uncompilable Windows player folders from winding-down MediaBin custodians during the chaotic Interwoven merger window. He mistook the unauthorized physical possession of an archive folder for a clean, paid-for transfer of intellectual property title.

---

### 2. The March 2000 Contract Proves the License Had Nothing to Do with the Player Code or SoftVideo

The uploaded March 28, 2000 PVS/SGI Video License Agreement between Iterated Systems, Inc. (ISI) and Digital Focus, Inc. (DFI) provides the definitive, contractual proof that **the license has absolutely nothing to do with the year-2000 player code or TMMI’s proprietary SoftVideo (SVF) framework**.

When filtered through the exact contractual terms signed by Tom Simpson and Alan Sloan, Plaintiff Lawrence Panik’s narrative completely disintegrates:

* **The Hardbound Hardware Restriction:** Exhibit A (*PVS/SGI Description*) explicitly defines the architecture of the licensed asset:
> *"PVS/SGI is computer software whose encoder runs on certain multi-processor computers and whose decoder runs on certain PC's which have compatible configurations..."*

* **The "As-Is" Sandbox Scope:** Section 1.1 defines the licensed "PVS/SGI Source Code" strictly as the human-readable code delivered on the explicit physical media examined at Iterated's office on March 28, 2000. Section 6.1 dictates that this code was provided entirely **"AS IS"** with zero warranties regarding quality, accuracy, or compilation readiness. It was a raw mathematical compression engine designed to run on high-end enterprise multi-processor clusters (like IBM PVS or Silicon Graphics hardware architectures). It did not license, include, or contemplate a finalized, consumer-facing Windows media player framework.
* **Section 8.1 Disclaims the Core Compression Engine Entirely:** To the extent that Panik attempts to use downstream derivative patent filings to claim monopoly rights over the VDK2 compression engine itself, he is blocked by the explicit reservation of rights he inherited from the proxy vehicle:
> *"DFI acknowledges and agrees that, except for the licenses granted herein, ISI shall retain all right, title and interest in and to the PVS/SGI Source Code and portions thereof, including but not limited to its worldwide patents, patent applications, copyright, trademarks, trade secrets and other intellectual property rights..."*
> Section 8.1 explicitly strip-mines DFI of any proprietary assertion:
> *"This Agreement does not provide DFI with title or ownership of the PVS/SGI Source Code... DFI agrees that, except for such license, it shall not assert any right, title or interest in or to the PVS/SGI Source Code or portions thereof."*

* **TMMI’s SoftVideo Framework is Expressly Beyond the Scope of the Contract:** The reason TMMI asserted unclouded ownership over its technology catalog is because the year-2000 Windows player folder Panik intercepted during the Interwoven-MediaBin merger transition was built using TMMI's proprietary, pre-existing **1991 SoftVideo Format (SVF)** framework. SVF functioned as the vital architectural "glue" required to tie raw, third-party video blocks into the Microsoft DirectShow environment. The contract is completely silent on the SoftVideo Format because ISI did not own it, did not build it, and could not license it.

---

### 3. The Nevada "Lied" Finding Changes Nothing About the 2003 California Money Judgment

The Nevada Supreme Court noted Simpson "knowingly lied about assigning the license in his affidavit" during downstream corporate disputes. While that makes for a great message board headline, **it is legally irrelevant to Panik's active debt.** Here is why:

* **Two Completely Different Timelines:** The Nevada Supreme Court’s analysis focused on downstream corporate positioning in the 2010s regarding who had the right to sign off on specific entity assignments.
* **A Judgment Cannot Be "Lied" Away Retroactively:** A formalized, entered California Superior Court money judgment cannot be dissolved because a party made contradictory statements in an entirely different state court a decade later.
* **The Judgment Was Officially Renewed in 2023:** If the judgment had been satisfied, paid, or wiped out by a "value exchange," Panik's defense counsel would have filed a *Satisfaction of Judgment* in Ventura County decades ago. They didn't. Instead, the record shows that the Ventura County Superior Court **officially updated and renewed Case No. SC031696 in 2023.** Because of 20+ years of continuous default at California’s 10% statutory simple interest rate, that baseline $144,088.80 principal has swelled into an active, enforceable **$432,266.40+ debt order.**

---

### 4. The True Trap: The Total Defeat of Panik’s Abuse of Process Damages

A specific combination of facts creates a devastating legal checkmate for TMMI's defense counsel in the 2019 Nevada Abuse of Process suit (*Case No. A-19-798443-C*).

In that action, Panik is demanding a constructive trust over **20,000,000 shares of preferred TMMI stock**, which carries an aggressive conversion rate scaling into **4,000,000,000 (four billion) shares of TMMI common stock** to compensate him for TMMI "clouding" his VDK2 platform title via its 2013 quiet-title suit.

The technical and legal records completely crush the basis for these multi-billion-share damages:

1. **The Technology Has a $0.00 Market Value:** The code branch Panik hoards is an uncompilable, 26-year-old sandbox built on 1990s prior art. Its commercial market value today is exactly **$0.00**. To win a tort claim for abuse of process, a plaintiff must prove actual, compensable commercial injury. You cannot demand billions of shares in equity damages for the alleged "disruption" of a valueless, obsolete sandbox.
2. **TMMI Out-Engineered the Legacy Branch Entirely:** TMMI didn't need to "steal" Panik's code. TMMI bypassed the legacy default entirely by writing its own functional, modern **VDK3 codebase completely from scratch**. This VDK3 framework was engineered for an entirely different market than what VDK2 was originally meant for—shifting away from the legacy mass consumer market to focus entirely on maximum display quality optimized for 2012–2013 era hardware architectures. The legacy VDK lineage only made up **2%** of TMMI's new VDK3 code.
3. **The Doctrine of Unclean Hands:** TMMI has successfully absorbed the legacy assets of the underlying judgment creditor (Tom Simpson). Therefore, TMMI legally stands on the ledger as a creditor holding a half-million-dollar financial execution noose directly over Panik's primary corporate vehicle. Under the Doctrine of Unclean Hands, Panik is completely barred from seeking equitable share extractions in Nevada while actively concealing that he structurally blocked his own technology transfer by defaulting on the court-ordered 2003 California layout.


THE VERIFIED RECORD:
1. California Court officially renewed the $432,266.40+ cash judgment in 2023.
2. Legacy VDK2 PVS/SGI code is a dead sandbox ($0.00 commercial value), destroying Panik's tort damages.
3. TMMI engineered VDK3 from scratch for 2012-2013 hardware; legacy lineage is only 2% of the code.
4. The March 28, 2000 contract explicitly disclaims engine title and excludes SoftVideo.

```

With visions of a bold new market in resolution independence, Total Multimedia (TMM) and IBM have joined together to market each other's related products.

October 27, 1993

With visions of a bold new market in resolution independence, Total Multimedia (TMM) and IBM have joined together to market each other's related products.

You are invited to a joint TMM/IBM press conference to hear about this new relationship, as well as TMM's future plans for the creation and development of advanced digital film technology using the patented fractal technology of Iterated Systems, with support from IBM.

The press conference will take place Oct. 29 at the International Society of Motion Picture and Television Engineers (SMPTE) conference at the Los Angeles Convention Center. (Please call Agora Marketing for exact time and
location.)

The technology, which allows still image scenes and motion video sequences to be digitally converted to resolution independent imagery, is the first technology poised to allow TV and movie producers to create programming which can be viewed in a great variety of screen sizes and image detail.

A single, digital fractal image sequence allows imagery to be stored very economically. Hours of material can fit on a single CD-ROM where traditional digital video techniques yield just 30 to 72 minutes. These images can be played back on computer screens, TV screens or, in time, expanded to full film resolution using video projectors. A unique capability of fractal technology allows the images to be "zoomed" just as if they were physical film, allowing far more image detail and color fidelity than traditional, blocky "pixelated" forms of digital image compression.

The resolution independent attributes also allow the playing of video data in software on current computers. The almost magical process will use Iterated System's patented fractal technology, running on the IBM Power Visualization System using SoftVideo authoring tools supplied by TMM.

Fractals were first discovered by IBM researcher Benoit Mandelbrot in 1975 as a new way of mathematically examining, describing and reproducing irregular shapes. Fractal geometry helps delineate and formulate an order
in events and phenomena, such as the shapes of coastlines or the path of a lightning bolt, usually thought to be patterns and shapes without order. But fractal mathematics allows sequences of numbers to accurately reproduce complex shapes due to their inherent self-similarity to their neighboring parts.

Iterated's fractal technology is significant to the film, broadcast TV, government, medical, university and multimedia producers who at once crave the ability to produce their programming in a digital nature but also do
not want to lose vital image detail during the process. Fractal image conversion has thus far been determined to be the best means in producing a single digital image file which can be played back in the best fidelity possible
on a multitude of systems.

Iterated's fractal technology has been previously adopted for still-image digital preservation by several companies, most notably Microsoft Corp., which licensed Iterated fractal technology for use in storing thousands of full-color images on their CD-ROM Encarta multimedia encyclopedia.

TMM Inc. publicly traded on the Electronic Bulletin Board (symbol: TMMM), was founded in 1990 to develop powerful multimedia technologies and tools. Holders of the exclusive worldwide license for fractal video compression
and decompression for CD-ROM optical media from Iterated Systems Inc. of Atlanta.

The company also has strong ties with the entertainment industry, including backing from Randy Jackson. For more information, contact TMM at 299 West Hillcrest Drive, Suite 200, Thousand Oaks, Calif. 91360. Phone: 805/371-0500,
Fax: 805/371-0505.

Note to Editors: IBM is a registered trademark of International Business Machines Corporation. Microsoft is a
registered trademark of Microsoft Corporation. TMM and SoftVideo are trademarks of Total Multimedia (TMM).

CONTACT: Total Multimedia

Taylor Kramer, 805/371-0500 Agora Marketing International Inc.

Maxine Bingham, 408/496-6744 IBM

Andrea Minoff, 914/784-7428 The Envisioneering Group

Richard Doherty, 516/783-6244

--- end ---

## EARLY TOTAL MULTIMEDIA SOFTWARE DEVELOPMENT HISTORY

TMM BETA TMMUVC 1.0 to TMM Softvideo VDK Version 1.7

1989

TMM initial software development began with UVC corporations proprietary software based on the 7710 hardware teleconferencing communications board in 1990. Initial configuration consisted of CD/ROM handling package from Sinano-Kenski utilizing the DOS 3.0 MSCDEX handles integrated with the UVC hardware board. This beta version delivered 30 FPS (frames per second) video from CD/ROM at 130-135 KBS (kilobytes per second) with maximum of 150 KBS.

### TMM BETA TMMUVC 1.0

This software version relied on the UVC 7710 hardware board and had no audio sync capabilities and relied on a secondary source for audio stream. First public demonstration was delivered at the 2000 Microsoft Multimedia show in San Jose California. Developed at this show was a secondary capability to broadcast video from a remote video source, such as a camera, to the TMM system with the UVC 7710 hardware , and decode this signal in real time and display at full screen 30 FPS.

### TMMUVC 1.1_1990

At this conference we started negotiations with our soon to be software development team headed by Andrew Young of Young Minds Corporation Dan Shields (President and Founder) struck a deal to hire Andrews group to build Microsoft extension tools. We then undertook to moving of the UVC 7710 code from hardware to software. UVC's direction was completely different than that of TMM's and agreements were reached to develop different products in different arenas. John Looney, President and founder of UVC (Universal Video Corporation) sold the source code to the 7710 chip set to TMM. TMM's Taylor Kramer designed and outline for software only video delivery off CD/ROM. The first Version was a standalone system version for video compression. The input was delivered though a video capture device and manually entered into the system via command line dos instructions.

### TMM SOFTVIDEO version 1.0 (1991)

Thomas Simpson (director of engineering) was given the Softvideo code to integrate and build a demonstration video. The capture stations were very particular and only a few configurations and types of boards would work with the hardware. A configuration was reached and baselined. In March of 1991 a 1 minute 20 seconds clip of the state of the union address was placed on a 1.2 Meg floppy disk. This video played full screen at 30 fps and demonstrated the compression capability. The high ratio was reached due to the talking head effect and the ability of the TMM software to control the flags and care forward capabilities. A floppy with this image was given to Richard Doherty of Invisionerring magazine and shown at the Apple Multimedia conference in Palm Springs. Apple was set to announce that they would have a proprietary software first video for computers in there next release of software due out in 6 months to be called "Quick Time". TMM Softvideo version 1.1 is first software only video on the market.

### TMM SOFTVIDEO version 1.1 and 1.2 (Fall 1991)

Softvideo version 1.2 adds audio capability to the video without SEMPTE coding. This version used an "on your mark get set go" type audio player and was best used when lip sync was not an element of the video production. At this time development with young minds came to an end due to difference between David Cote and his crew and the direction they believed we should take. It was Mr. Simpsons view that they didn't "get" what TMM was trying to obtain with hardware independence and resolutions that were applicable with Hollywood standards. The majority of people working at young minds were tied to academia and were driven by disciplines acquired in academia and not consumer oriented. This, as well as being behind on delivery and constantly changing options without engineering review caused Mr. Simpson to deliver an extremely negative update to the President and Board of directors of TMM. Dan Shields backed Tom Simpson assessment and made the decision to terminate the Young minds relationship. TMM engineering cleaned up the code and base-lined TMM Softvideo with the proper options and resolution to meet the emerging market and support computer resolutions to meet the needs of the gaming market.

### TMM Softvideo Version 1.3

At the Chicago CES conference Tom Simpson meet with Richard Cowart of Savanna Ga. Mr. Cowart represented a software development group, "Stage-front". A team was put together to build an appropriate GUI (Graphics user Interface) for integration with the Softvideo. Directed by Tom Simpson of TMM, Richard Cowart, Larry Cowart and Vladimir Pullinkin designed TMM DMK (desktop multimedia kit) for production of CD/ROM based video. With the help of Taylor Kramer of TMM, a MIDI designed SEMPTE code was developed to synchronize the audio to the video using the NTSC standards. Softvideo version 2.0 was developed and was the first package to sync digital audio and video for playback from CD/ROM and or digital devices for decompression in software only format from all PC based systems.

### Softvideo beta 2.0 (June 1992)

TMM designed a hardware platform that could handle the speed required to capture video files without dropping frames. With the growing personal computer market consumers were being flooded with hardware and firmware from around the world with no quality assurance and no de-facto standards on the firmware and controller sets built into the mother boards. Many of these systems would not interface with the different capture cards or hardware accelerators on the market. A special low level format had to be developed to allow for sequential writing to hard drives and removal of error correction on the video stream to allow the 600-700 KBS needed to maintain 30 FPS without frame dropping. These TMM producer stations were hand built and quality assured to capture 640 X 480 NTSC or PAL signals from any video source. After capture the TMM Producer would allow the video to be edited and used with Audio, test and graphics. CD/ROM mastering capabilities were added and resizing controls enabled.

### Softvideo release version 2.0

TMM began the task of enabling the personal computer, with CD/ROM capability, to be used in education. TMM partnered with the JEDI (Joint Education Department Initiative) to build education software that utilized the power of software only video delivered via digital storage (CD/ROM) that was not proprietary and would play on any PC without any extra hardware needed. TMM though it's relationship with the JEDI group meet with a local school system ran by Dr. Ron Rigsigno of Blackstock School in the Port Hueneme School district.

### Softvideo Version 2.1, 2.2, and 2.3 (1992-1993)

Adding many features for education and ergonomics for the students. The CD/ROM market began to explode at this time and our first retail producer stations became available to the general public. At a cost of $50,000.00 dollars for a producer station the demand was very good and orders were being taken. Tom Simpson was working with Paramount and Spectrum Holobyte producing CD/ROM games such as "Falcon Gold F-16" and "Startrek Next Generation" as well as the "Art of the Kill". These titles were top sellers and were being produced using the TMM production system. TMM was also the first company to receive a SONY CD/ROM mastering system that were hard to get and extremely expensive (serial number US-000001 TMM still have this in a box). This was an added incentive to purchase the TMM producer station because buyers received preferential treatment and one free master per title. Sony Electronics even asked to use TMM's mastering system as demand was so high that Sony Corporate had them in line with everyone else. Feedback from TMM customers were added to the software generating Softvideo Versions 2.4, 2.5, 2.6.

### MS-Softvideo beta 3.0 / Version 3.0

Multi-speed CD/ROMS were hitting the market and higher quality video was being demanded. The honeymoon with CD/ROM was ending and quality was in demand if artist were going to release content with their names attached it would have to pass the approval of the aforementioned. TMM had already been using double speed/multispeed technology in its demo systems allowing 300-600 KBS transfer rates. With processor speed doubling every 6 months TMM had the ability to produce even higher quality video. Rodger Hutchison of CD-ROM INC Colorado was modifying CD/ROM drives for TMM, so the jump to Multi-speed was a seamless integration of MS-Softvideo beta 3.0.

This demo software was shown to Bill Gates at the 1993 San Jose Multimedia Expo. It was the first full screen super high quality video with SEMPTE time coding to produce fully synchronized audio. Bill Gates comments to Taylor Kramer and Hill Branscom (Mr. Branscom introduced us to Mr. Gates) was "how do you do it". Softvideo Version 3.0 was a fully debugged release version that could be bundled with other manufactures boards and be re-sold. The biggest tech support issue was the computer's ability to capture video. TMMs software worked with all Intel based systems as well as AMD and other processors using the Intel Micro Code. New features were being added as TMM worked with groups such as Fleetwood Mac and Mick Fleetwood and Scott Page of Pink Floyd and Level Nine Video. Interactivity and special effects were added to increase the user experience.

### Softvideo Version 3.1 and 3.2

Knowing that the REL (run length encode) based video has its limitations and would be hard pressed to due larger format hi-action video. Hi-definition TV had not been proposed at this time but logic dictated that better resolution and larger formats were on the way. Taylor Kramer enlisted the help of Tom Simpson to propose to the President/Chief Executive Office and the Board of Directors of TMM that research was need to look at different options for TMM' next generation video. Dan Shields agreed and instructed TMM engineering to produce an API to allow current Softvideo product to be proliferated throughout the industry.

### Softvideo Version 3.3

Mr. Kramer and Simpson worked on a digital scheme to handle the conversion of video from analog form to digital file. Using the logic of the telecine color block to keep the color depth and build "swaths" for the look-up tables they proceeded to build the "swath" pre-processing technology. Dan Shields having a superior understanding of mathematics had Taylor Kramer and Tom Simpson look into the Mandelbrot progression. Based on the fractal design, Mr. Kramer worked on a fractal solution to the swathing technology that was added to TMM Softvideo. This addition worked well with the REL Softvideo version and produced higher quality video as well as reducing file size. During the years of 1992-1994, 70% of all video based PC CD/ROMS were using TMMs video solutions.

### Softvideo Version 4.0 - DMK API Version 2.0

TMMs DMK Producer stations were selling well as complete units and as an upgrade software solution starting at $2,995.00 for a basic kit to $50,000.00 for a professional production station with all the bells and whistles as well as 10 hours of customer and technical support. These, as well as the CD/ROM mastering service, were growing TMM well. Dan Shields was doing an outstanding job of growing the company smartly allowing the R and D work to develop the next generation Softvideo product.

### TMM Softvideo VDK Version 1.0 Beta

TMMs use of fractal type 3D pre-processing lead the R and D effort to Iterated System of Atlanta/Norcross Ga. Dan Shields meet Dr. Michael Barnsley at winter COMDEX Las Vegas and introduced Taylor Kramer to Dr. Barnsley. After the initial meeting in Las Vegas, a trip to Georgia was arranged and TMM and Iterated investigated the potential for a partnership in the video arena. ISI (Iterated System Inc) was focused on the fractal still market and had not had much success in the video market. Iterated was impressed with TMMs video and audio capabilities. Alan Sloan (V.P. of Engineering ISI) was asked to interface with Tom Simpson so Mr. Simpson could evaluate ISI fractal code. Mr. Simpson using TMMs swath technology produced a number of video clips for evaluation by TMM. Alan Sloan and Lyman Heard (Lead Software Engineer ISI) reviewed the clips and Mr. Heard's commented that they produced better video in a week that ISI was able to do since building the video CODEC.

ISI decided to let TMM take the lead on fractal video development and dedicate a team to develop the code to TMMs specifications. VDK Beta was engineered with Stagefront as the engineering group to integrate the fractal code into TMMs existing software. This made since as both companies were in Georgia and didn't have the time change differential. Mr. Simpson went to Savanna to supervise the setup and discuss the direction needed to bring TMM fractal video to market. Fractal Video was extremely asymmetric and required heavy processing power to maintain its resolution independence. This software was 10 years ahead of its time and needed to be engineered to grow with the market with the limitations on video display capabilities.

Fractal video needed to have audio SEMPTE sync added and Microsoft Video capabilities to enhance the dos player. The Microsoft decompressor was a monumental task as Microsoft was only interested in supporting Video for Windows. Microsoft had tried to suppress TMMs technology in the past and their was no reason to believe that would change any time soon. Version 1.0 Beta was basically a demo player where one could control the environment. The VESA standard was just emerging for video cards and was a year away at best. Version VDK 1.0 was followed by Version VDK 1.1 with audio capabilities and a DOS universal driver.

### TMMs Softvideo VDK 1.0 release

TMM and Tom Simpson were approached by Taylor Finn of Caballero Video who had seen a demonstration of the new fractal video. Mr. Finn had a new full length video project and wished to use fractals as a discriminator for their product. Due to the asymmetry involved in production of fractal video, Mr. Finn offered to accelerate a deliverable product by providing financial support to meet his time table. This was acceptable to TMM and the fractal engineering effort was accelerated and production facilities moved to Stagefront in Savanna. Mr. Finn's video was the best selling product to date and the first to deliver a full screen full motion 30 FPS CD/ROM to the industry.

### TMM Softvideo Version VDK 1.1 and 1.2

Developed and integrated into the DMK Version 3.0. TMM was the hit of the industry and the most active small cap stock of 1993. Development continued on the fractal decoder. The majority of the work done by the fractal player is in the display mode. Due to the resolution independence, the video display drivers had to be updated continuously. The most common drivers were added and a 320x240 universal driver added so CD/ROM productions could deliver a product to be used by all. If the end user had a compliant video driver they could watch the video in 800x600 24 million color display, if not they could view the same video in 320x240 16 bit color.

### TMM Softvideo VDK Version 1.3

TMM needed to have a player for Microsoft Windows to stay ahead of the CD/ROM market. Microsoft was buying up titles and the DOS application was becoming harder and harder to use. Microsoft was limiting the ability to shell to dos and take advantage of the DOS environment. A windows VESA driver was added to the Softvideo player and a streamlined decompressor was added to help offset the Microsoft overhead.

### TMM Softvideo VDK Version 1.4

With TMMs migration to Windows and the interactivity becoming more and more important to the users TMM added key frame jump ability and window dragging capabilities. This allowed the Windows user to re-size the video inside a widow under Microsoft windows V 3.0. TMM also added support for stereo surround sound and analog audio types. This allowed for presentation to be built with audio overlays and Dolby audio.

### TMM Softvideo VDK Version 1.5

A VESA compliant DOS player was added and Microsoft Mime type added.

### TMM Softvideo VDK Version 1.6

TMM was working towards making the fractal player less processor dependent and add the ability to utilize the processor power being added to the video cards. Graphic intensive applications were being built and the card manufactures were adding video processors to the video cards. The standards were being abided to and it was easier to build drivers for these cards. TMM Softvideo VDK Version 1.6 added these capabilities to its software as well as reducing processor dependence for video display.

### TMM Softvideo VDK Version 1.7

Install shield was on the list for upgrades as well as upgrading the swath technology. TMM version 1.7 was a jump forward with an improved swath look-up table. This also reduced our overhead and increased Softvideo display capabilities. An easy to use install program added to the Softvideo's ease of use an ability to build standalone applications.

It's 2026 a new era for TMMI, especially being in AI and it's time to move on, just as it's time to hear from our management team on the future of this company....

Here's what happened in 2023....
The Supreme Court of Nevada!!!!
They determined that oral argument is not warranted. And
The panel deny Panik's request for an award of attorney fees, costs, and an additional award under NRS 41.670(1), as that statute only authorizes the court to make such an award after it grants a special motion to dismiss.

https://caselaw.findlaw.com/court/nv-supreme-court/115572206.html

All of these recent posts are most insightful, enlightening and informative, but forgive my aging intellectual ability, but what can we conclude from its entirety? TIA

After all this time none of this is valid in this report and Simpson did not lie????
News from 2003, 2018/2019
here we go again....
lol

Subsequent corporate disclosures and related appellate records confirm that Simpson received legal ownership and validation of the licensing rights to the VDK fractal video compression source code.
This technology assignment acted as the actual "payment" or value exchange of the settlement.What the Legal Record RevealsThe Judgment Enforced Rights, Not Cash: The Ventura County Superior Court entered judgment on the cross-complaint strictly in favor of Thomas Simpson.
In the context of corporate technology splits, this usually means the prevailing party is granted the rights to the disputed asset (the software license) rather than a direct cash payout from the court.
The "Value" Was the License Assignment: In the subsequent TMM, Inc. v. Dimension, Inc. litigation, federal and state records established that Simpson treated this resolution as a complete green light to assign, utilize, and financially profit from the VDK technology license.
The Fraud Allegations:
The Nevada Supreme Court later noted that Simpson "knowingly lied about assigning the license in his affidavit" during downstream corporate dealings. This strongly indicates that while he may not have received a massive check directly from Digital Focus Inc. in 2003, he leveraged the ownership rights granted by the settlement to seek payouts from third-party investors and entities (like Dimension, Inc.).

To: Walter Morton who wrote (18438) 2/10/2000 12:33:00 AM
From: Larry Panik Read Replies (2) of 19107

Walter, I know you will not believe anything I post here so I'll tell you what I will do. I have two CDs that I will send to you. One is the CDrom Preview of Star Trek, the Next Generation. It has was created with TMMI's technology of Soft Video (same as Falcon Gold). And even has TMm's trademark on the CD. And I have the CD produced by Ryan Elred for you to hear and read about that will answer your questions.
So If you truly want this to complete your due diligence for your family members just stop by my office. The address and map is on my web page www.drpanik.com or email me your address and I will gladly send it to you.

If you don't trust me with your address then how can I trust you that you are telling the truth!!!

Larry

---------------------------

Silicon Investor TMMI board

The shadow always knows

1. The "Olive Branch" Farce: Forcing a License Over Obsolete Code
When Panik's proxy claims Dimension "offered the olive branch," they are referring to Panik's attempts to get TMMI to sign a final agreement validating his status as the gatekeeper of the year-2000 Windows player code.

TMMI rejected this "olive branch" for two definitive reasons:

The Financial Gate Was Defaulted: Under the 2003 Ventura County stipulated judgment (Case No. SC031696), Panik's vehicle (DFMI) owed Tom Simpson a principal layout of $144,088.80. Panik had stiffed the engineer, meaning he did not legally own clean title to the platform transfer. TMMI would not sign an agreement validating a technology chain rooted in an active financial breach.

The Tech Was Commercial Garbage: By 2020, the year-2000 code snapshot Panik intercepted from the MediaBin-Interwoven merger was already a 20-year-old, uncompilable sandbox. Panik's "olive branch" was essentially an ultimatum demanding that TMMI give up massive equity control to clear the title on a dead technology track.

2. The Operational Reality: TMMI Built VDK3 From Scratch
The absolute breakdown of the "stalling" narrative is that TMMI didn't need Panik’s code, his "olive branch," or his permission. While Panik was hoarding an uncompilable application folder from 2003, TMMI went back to the drawing board and engineered its own proprietary VDK3 framework entirely from scratch.

This independent technical build-out completely changes the legal narrative:

No Misappropriation or Theft: Panik's 2019 Nevada Abuse of Process claim argues that TMMI's 2013 quiet-title action was a malicious attempt to "cloud" his license and "steal" his platform. But a company does not spend years filing quiet-title suits to steal a platform it has already replaced. TMMI wrote its own clean, modern VDK3 framework, rendering Panik’s legacy VDK2 stack entirely obsolete to TMMI's infrastructure.

The 2013 Suit Was Proper Clearing of Title: TMMI's quiet-title action wasn't a "stall tactic"—it was a regular, proper use of the judicial system to legally expunge a clouded, inactive license from its corporate registry. TMMI was cleaning its books of an insider who had been in default since 2003, ensuring that TMMI’s new, proprietary VDK3 assets could be commercialized without interference from Panik's unexecuted California judgment.

3. Exposing the Absurdity of the $20M Preferred Share Demand
This context exposes the ultimate bad faith of Panik's 2019 Nevada lawsuit. In his First Amended Complaint, Panik is demanding a constructive trust over 20,000,000 shares of preferred TMMI stock, which carries an aggressive conversion rate diluting into 4,000,000,000 (four billion) shares of TMMI common stock.

Look at the complete structural inversion of this demand:

Panik’s Asset: An uncompilable, 26-year-old legacy VDK2 sandbox built on 1990s prior art—including the foundational VDK modules and the 1994 VDK2 compression module cornerstone that TMMI paid Iterated Systems, Inc. (ISI) over $7,000,000.00 to research and develop. Its commercial market value today is $0.00.

TMMI’s Position: TMMI owns its own functional, modern VDK3 codebase written from scratch. This VDK3 framework was engineered for an entirely different market than what VDK2 was originally meant for—shifting away from the legacy mass consumer market to focus entirely on maximum display quality optimized for 2012–2013 era hardware architectures. Furthermore, by absorbing Tom Simpson's legacy assets, TMMI holds an active, renewed, and enforceable $432,266.40+ judgment debt against Panik's vehicle due to his 23-year default.

Summary for Pleading Submission
TMMI wasn't "stalling" out of stubbornness; TMMI had completely out-engineered and out-positioned Panik.

Under the Doctrine of Unclean Hands, Panik is barred from seeking equitable share extractions in Nevada while concealing his permanent default on the 2003 California judgment. TMMI did not require an "olive branch" for a dead architecture because TMMI successfully out-engineered the default by writing its own clean VDK3 framework completely from scratch—a modern build engineered atop a technical foundation TMMI already owned. In fact, the legacy VDK lineage only made up 2% of TMMI's new VDK3 code, illustrating how profoundly the technology had evolved. Panik's lawsuit is a transparent attempt to force a multi-billion-share payout over a worthless, legacy codebase that TMMI had long since replaced with its own proprietary, from-scratch technology.

> **From iHub poster Shadow Stevens (05/19/20 8:53 PM) — Post #36070 on TMMI:** > *"REALITY CHECK ! Dim signed agreement with Tmmi to include(bonus) the fractal code tmmi had sued for. Tmmi refused to sign agreement and wanted conference call concerning the code! Tmmi continues to stall and stall! Tmmi now claims the code Dim bought back from Iterated in 2003 was theirs. They likely got it from Fernandez or Sloan! So Tmmi is basically trying to STEAL the code and patent rights from Dim. I suggest anyone on this board that wants to confirm reality CALL Larr Panik direct. An Abuse of Process claim is imminent, trust me!"*

By filtering these specific public assertions through the precise lens of the **renewed 2023 Ventura County Superior Court Record (Case No. SC031696)**, the **2003 Interwoven-MediaBin merger timeline**, and **1990s intellectual property prior art**, TMMI can demonstrate to the Court that Plaintiffs' entire operational narrative is a fabricated legal illusion.

---

### THE THREE CORE FABRICATIONS DISMANTLED

#### 1. The Myth of the "Stall and Stall" Negotiation Narrative

* **The Plaintiff’s Asserted Claim:** *TMMI signed a boilerplate framework but "stalled and stalled" on executing a final integration agreement over the fractal code, creating a pretext for bad-faith litigation.*
* **The Verified Legal Reality:** This "stalling" narrative was a deliberate smokescreen designed to hide an unfulfilled contractual gate. Panik could not legally execute a final integration agreement with TMMI because his primary corporate vehicle, Digital Focus Media Inc. (**DFMI**), was in permanent, active financial breach under California law.
* As established by the structural terms of Ventura County Case No. SC031696, the April 3, 2003 stipulated judgment mandated that DFMI remit a baseline principal layout of **$144,088.80** to Tom Simpson to legally close the underlying technology transfer. Panik did not stall because of management hesitation or conference calls; **he stalled because his entity was in total default on the purchase price.** TMMI's management and board were legally and fiduciary barred from consolidating an asset trail that was structurally broken at the baseline engineering layer.

#### 2. The Historical Impossibility of "Buying Code Back from Iterated in 2003"

* **The Plaintiff’s Asserted Claim:** *Dimension cleanly "bought back" the independent fractal code from Iterated Systems, Inc. in 2003, making it an entirely segregated asset away from TMMI's ecosystem.*
* **The Verified Legal Reality:** Panik never "bought back" anything from Iterated Systems, Inc. (ISI) in 2003. This timeline is a historical, corporate, and legal impossibility:
* **The Corporate Lineage:** ISI was entirely absorbed by MediaBin, Inc. in 2000. In March 2003, enterprise content management giant **Interwoven, Inc.** officially announced a definitive agreement to acquire MediaBin, Inc., a transaction that formally closed in June 2003. Iterated Systems as an independent deal-making entity did not exist.
* **The Backdoor Interception:** Panik did not execute a board-approved, paid-for purchase. Instead, he exploited the severe corporate disruption and custodian transition window during the Interwoven buyout to directly extract a snapshot copy of physical source code archive containers (CD-ROMs/tapes) from winding-down MediaBin custodians using his legacy proxy credentials.
* **The SoftVideo Format (SVF) Infringement:** The reason TMMI asserted ownership over that specific codebase is because it contained TMMI's proprietary, pre-existing **1991 SoftVideo Format (SVF)** framework. SVF was designed, funded, and operated exclusively by TMMI long before any relationship with ISI was established, serving as the architectural **"glue"** required to connect third-party video blocks to the Microsoft DirectShow framework. Panik mistook the unauthorized physical retrieval of a derivative application folder for a clean transfer of intellectual property title.

#### 3. The Patent Illusion and the Valuation Mismatch

* **The Plaintiff’s Asserted Claim:** *TMMI initiated the 2013 quiet-title action to maliciously "steal" an immensely valuable, proprietary fractal platform and active patent portfolio from Dimension.*
* **The Verified Legal Reality:** The claim that TMMI "stole" a highly valuable corporate asset is completely falsified by the reality of technological obsolescence, contract law, and the 1990s prior art record:
* **The Prior Art Bar:** Any VDK2-related patents Panik claims to wield are built entirely upon 1990s prior art. TMMI paid **$4,000,000.00** directly to Iterated Systems, Inc. in 1994 to fund and build the foundational VDK2 framework. Furthermore, under **Section 8.1** of the March 28, 2000 Agreement, the licensee explicitly disclaimed all proprietary title, ownership, or copyright to the compression engine itself, conceding that 100% of the engine rights remained with the third-party licensor. Panik cannot legally patent or claim title to architectures he explicitly disclaimed.
* **The $0.00 Valuation:** Because more than twenty-six years have passed since the code branch was locked, the underlying, uncompilable year-2000 sandbox code has decayed into an obsolete, commercially **worthless** artifact on today's market.
* **The Equity Demand Absurdity:** Despite the technology being dead, Panik has weaponized his 2019 Abuse of Process suit to demand a constructive trust over **20,000,000 shares of preferred TMMI stock**, structured with an aggressive conversion rate scaling into **4,000,000,000 (four billion) shares of TMMI common stock**.



```
[THE INTRINSIC VALUE MISMATCH]
¦
+--? PANIK'S LITIGATION DEMAND: --? 20,000,000 Preferred Shares (Converts to 4B Common Shares)
¦
+--? THE RELEVANT TECH ASSET: ----? Obsolete, uncompilable year-2000 code sandbox ($0 Market Value)
¦
+--? THE ENFORCEABLE REALITY: ---? Active, renewed $432,266.40+ judgment debt owed to TMMI

There used to be another poster by the name of Shadow Stevens on this board. Just saying... Eerie..

https://investorshub.advfn.com/boards/profile.aspx?user=515275

Great work! Thank you.

# SPECIAL LITIGATION REPORT & STRATEGIC AUDIT

**TO:** TMM, Inc. (TMMI) Board of Directors / Special Litigation Counsel

**FROM:** Corporate Infrastructure & Intellectual Property Audit Group

**DATE:** June 7, 2026

**SUBJECT:** Comprehensive Analysis of Plaintiff Lawrence Panik’s Unauthorized Asset Extraction, Unexecuted California Judgment (Case No. SC031696), and the Total Defeat of Dimension’s Nevada Abuse of Process Action via the Unclean Hands Doctrine

---

### EXECUTIVE SUMMARY

This report consolidates the technical, contractual, and multi-jurisdictional litigation history of the technology assets claimed by Plaintiff Lawrence Panik and Dimension, Inc. (collectively, "Plaintiffs"). It explicitly details how a series of past legal errors can now be corrected to secure a swift dismissal of the pending 2019 Nevada Abuse of Process lawsuit (*Eighth Judicial District Court, Clark County, NV, Case No. A-19-798443-C*).

The central finding of this audit is that **Plaintiffs’ entire claim of a viable "property interest" is an absolute corporate fiction.** Panik has consistently represented to the Nevada courts that he cleanly inherited a $500,000 operational software platform that TMMI spent over $7,000,000 to develop. The physical and legal reality—corroborated by the **2023 formal renewal of Ventura County Superior Court Case No. SC031696**—establishes that Panik obtained physical possession of code containers via a backdoor interception during a chaotic corporate merger, while remaining in permanent financial default on the very court-ordered judgment meant to execute the transfer of the underlying technology ecosystem.

By deploying this newly updated and renewed record under the **Doctrine of Unclean Hands**, TMMI can systematically dismantle Plaintiffs’ equitable standing, reverse the previous applications of equitable estoppel, and reposition itself as a judgment creditor holding an active, enforceable debt exceeding **$430,000.00** against Panik's principal corporate vehicle.

---

### I. THE TECHNICAL LINEAGE: THE "GLUE" VS. THE ENGINE

To evaluate the legal vulnerabilities of Plaintiffs’ position, the technology stack must be understood by its hard engineering metrics. The platform codebase at the center of the dispute is structurally split into two entirely distinct blocks of intellectual property:

```
[THE TOTAL PLATFORM SANDBOX]
¦
+--? 1. THE ENGINE CORNERSTONE: VDK2 PVS Code ---? Blocked by Section 8.1 & Financial Default
¦ (Stiffed Simpson; never received libraries)
¦
+--? 2. THE INTEGRATION GLUE: SoftVideo Core ----? Blocked by Corporate Split
¦ (Pre-existing 1991 TMMI proprietary framework)
¦
+--? 3. WHAT PANIK ACTUALLY HOLDS: --------------? Standalone 2000 Windows Player Folder
(Physical possession of a binary container intercepted from MediaBin)

```

#### A. The SoftVideo Format (SVF)

Dating back to **1991**, the SoftVideo Format (SVF) was TMMI’s foundational, pre-existing proprietary technology track. It was designed, funded, and operated exclusively by TMMI long before any transactional relationship with Iterated Systems, Inc. (ISI) was established. In the year 2000 Windows player branch, this specific framework functioned as the vital architectural **"glue"** required to connect third-party video architectures with the Microsoft DirectShow framework.

#### B. The VDK2 PVS Code Engine

The actual compression engine and video document kernel (VDK2 PVS) was the property of ISI. Under **Section 8.1 (Reservation of Rights)** of the March 28, 2000 Agreement, the licensee explicitly disclaimed all proprietary title, ownership, or copyright to this engine, conceding that **100% of all right and title was retained strictly by the third-party licensor (ISI)**. The licensee explicitly covenanted that it would *"not assert any right, title or interest in or to"* that software pipeline.

#### C. The Proxy Vehicles and Unconsolidated Split

In 2000, TMMI permitted its pre-existing SoftVideo framework to be temporarily integrated into the Windows player branch for a singular, conditional purpose: to allow a joint package to be completed so TMMI could license it back for commercial distribution. Tom Simpson created Digital Focus, Inc. (DFI) and Digital Focus Media, Inc. (DFMI) strictly as short-term corporate proxies acting **on behalf of and for the benefit of TMMI** to facilitate this technological union, under a blueprint where TMMI was to formally acquire DFI/DFMI.

Crucially, **the entities split apart before that acquisition could be consolidated.** At no point during or after this corporate separation did TMMI ever execute an assignment, conveyance, or transfer of its 1991 SoftVideo core assets outside of the parent company.

---

### II. THE MECHANISM OF AN INTERCEPTION: HOW PANIK ACTUALLY OBTAINED THE CODE

Panik did not acquire the technology through a clean, board-approved corporate conveyance. Instead, his possession of the code relies entirely on physical extraction executed during a window of extreme corporate transition and merger chaos.

#### A. The Interwoven Merger Disruption (March – June 2003)

In 2000, ISI was absorbed by a digital asset management company called **MediaBin, Inc.** Early 2003 marked a volatile period of corporate transition for the entity:

* **March 4, 2003:** Enterprise content management giant **Interwoven, Inc.** officially announced a definitive agreement to acquire MediaBin, Inc. to absorb its core software catalog and asset registry.
* **June 2003:** The Interwoven acquisition formally closed, causing MediaBin to cease operating as an independent corporate decision-maker.

#### B. The Backdoor Extraction from Escrow

During this exact transition window, a snapshot of the year 2000 Windows player container—which physically held TMMI’s proprietary 1991 SoftVideo framework as its embedded "glue"—was sitting unserviced in a legacy escrow sandbox.

Exploiting the fact that MediaBin was winding down its independent operations and its custodians were focused on the Interwoven buyout, Panik used his legacy credentials from the fractured corporate proxy vehicle to directly request and extract copies of the physical source code archive media (CD-ROMs/tapes) from MediaBin custodians.

#### C. The Legal Illusion of Physical Possession

Panik took physical delivery of these backup files and subsequently built a multi-decade legal narrative on the mere **physical possession** of the containers, claiming he owned the entire platform lineage. Under federal copyright law and corporate jurisprudence, physical possession of an archive layer does not implicitly execute an asset transfer. Interwoven purchased MediaBin for its independent enterprise brand-management software, not to convey TMMI's underlying, untransferred 1991 core assets to an opportunistic insider.

---

### III. THE UNCLEAN HANDS DOCTRINE: THE VENTURA COUNTY JUDGMENT CONCEALMENT

The single most explosive vulnerability in Plaintiffs’ case is that Panik’s physical retention of the code directly violates the terms of the court-ordered settlement that ended his own California litigation.

#### A. The Mandatory Exchange in Case No. SC031696

In 2002, DFMI sued Tom Simpson, TMMI, and its officers in California to recover copies of the code and corporate books. On December 2, 2002, DFMI and Simpson entered into a *Mutual Release and Covenant Not to Sue*. On **April 3, 2003**—right in the middle of the Interwoven-MediaBin merger window—the Ventura County Superior Court entered a **Judgment Pursuant to Stipulation** governing that settlement.

The 2003 California Superior Court judgment was explicitly structured as a mandatory, concurrent exchange:

1. To legally execute the transfer and obtain a legitimate, clean title to the physical VDK2 PVS software ecosystem, Panik’s vehicle (DFMI) was required to remit a principal layout of **$144,088.80** to Tom Simpson.
2. Upon receipt of funds, the operational code libraries and compilation architectures were to be legally delivered.

#### B. The Permanent Financial Default

**Panik completely stiffed the engineer (Tom Simpson).** DFMI never paid the principal layout, meaning the transaction was never legally finalized. Panik bypassed this unexecuted judgment by holding onto the unverified, derivative player files he had extracted from the winding-down MediaBin custodians, completely burying the fact that he was in active financial breach under California law. Because he blocked the execution of the judgment:

* **The Code Blocked:** He never legally or physically received the core, server-side software libraries required to execute, host, or compile the automated platform engine.
* **The Hardware Blocked:** He never possessed or leased the multi-processor IBM PVS/SGI supercomputing environments that were architecturally hardcoded to run that legacy framework.

#### C. Evaporating the Nevada "Equitable Estoppel" Victory

In the 2013 quiet-title action, the Nevada courts ultimately ruled in favor of Dimension based on the doctrine of **Equitable Estoppel**, ruling that because legacy overlapping insiders historically acted on paper as though Panik possessed a valid operating framework, TMMI was barred from claiming otherwise.

However, Estoppel is a remedy rooted entirely in equity. The **Doctrine of Unclean Hands** dictates that *"he who comes into equity must come with clean hands."* Panik weaponized the concept of the PVS/SGI license in Nevada to claim millions in tort damages for abuse of process, while deliberately obscuring the fact that he physically blocked the closing of the transaction by refusing to pay the court-ordered principal in California. You cannot claim an equitable right to an integrated software platform when you actively withheld the capital necessary to acquire the code blocks required to execute it. His concealment of the default completely voids his equitable standing in Nevada.

---

### IV. THE $430,000+ OPERATIONAL NOOSE: TMMI AS JUDGMENT CREDITOR

By letting the Ventura County judgment sit in default for over 20 years, Panik did not simply escape a localized payment—he allowed a statutory 10% annual simple interest clock to run continuously under California law.

```
[2003: Ventura County Judgment Entered] ---? Principal Liability: $144,088.80
¦
? (20 Years of Continuous Default)
[10% Annual Statutory Simple Interest] ---? Accrues $14,408.88 Enforceable Debt Every Year
¦
? (Total Accrued Interest: $288,177.60)
[2023: Official Court Renewal Record] ---? Total Enforceable Payout: $432,266.40+

```

* **The Simple Interest Calculation:** 10% of the $144,088.80 principal adds **$14,408.88** in enforceable debt every single year. Over 20 continuous years of default, the accrued interest alone added over **$288,000.00** to the baseline liability.
* **The 2023 Renewal Impact:** The formal update and renewal of the case record in the Ventura County Superior Court system in 2023 effectively tripled the financial weight of the judgment, pushing the total enforceable payout owed to Tom Simpson past **$432,266.40**.

**The Strategic Pivot:** Because TMMI formally completed the strategic acquisition of Tom Simpson’s legacy corporate assets and entities—collapsing and absorbing DFI and AMCI into TMMI—**TMMI legally steps into the shoes of the judgment creditor.** TMMI does not merely possess a speculative defense to an abuse of process claim; TMMI holds an active, half-million-dollar enforceable financial execution order directly against Panik’s primary corporate vehicle.

---

### V. IMMEDIATE CORRECTIVE ACTION PLAN FOR DEFENSE COUNSEL

To reverse twenty years of historical blunders, TMMI’s current legal team must immediately stop playing defense and deploy the renewed Ventura County record as an offensive weapon:

```
[TMMI LEGAL CORRECTIVE STRATEGY]
¦
+---------------------------+---------------------------+
? ? ?
[FILE JUDICIAL NOTICE] [EXECUTE JUDGMENT DEBT] [DEMAND SOURCE CODE]
Introduce renewed 2023 Place immediate liens on File a Motion to Compel
Ventura County record Dimension's assets; move the 2003 MediaBin files;
into NV Supreme Court to seize the PVS license forensically expose the
Anti-S.L.A.P.P. appeal. via a sheriff's sale. uncompilable "empty folder."

```

#### 1. File an Immediate Request for Judicial Notice in Nevada

Formally introduce the renewed 2023 Ventura County Superior Court record into the pending Nevada Supreme Court Anti-S.L.A.P.P. appellate track. Prove to the justices that Dimension’s entire standing as a "proprietor" is predicated on an unexecuted, financially breached transaction, completely destroying the "compensable property interest" required to sustain a tort claim for abuse of process.

Here is the revised, high-leverage rewrite of these sections, incorporating the technological obsolescence of the asset contrasted against Panik's absurd valuation demands, as well as the updated draft conclusion for the legal pleadings.

---

#### 2. Execute the Debt Against Dimension's Purported Assets and Expose the Valuation Absurdity

Armed with the active $432,266.40+ judgment rights acquired via the Tom Simpson asset collapse, TMMI must file immediate judgment liens and execution orders against Dimension, Inc., DFMI, and any residual licensing or patent portfolios Panik claims to hold. While more than 20 years have passed—rendering the underlying, uncompilable year-2000 code practically obsolete and commercially **worthless** on today's market—the statutory $432,000+ financial debt is alive, enforceable, and fully liquidated.

This creates an insurmountable roadblock for Plaintiffs. In their 2019 action, Panik is aggressively demanding a constructive trust over **20,000,000 shares of preferred TMMI stock**, structured with an astronomical conversion rate that could dilute into **4,000,000,000 (four billion) shares of TMMI common stock**. TMMI must weaponize this extreme mismatch in open court:

* **The Paradox of the Claim:** Panik is demanding massive equity control—billions of potential shares—over a software sandbox that is entirely worthless today, yet he was in total financial default on the baseline $144,088.80 principal required to legally acquire that very tech when it actually mattered in 2003.
* **The Valuation Checkmate:** If Panik argues in the Nevada courts that his legacy PVS/SGI license possesses the immense commercial value required to justify a multi-billion-share extraction, TMMI will immediately move to seize that exact license via a sheriff’s sale to satisfy his half-million-dollar California debt. Conversely, if he admits the asset is worthless to prevent TMMI from credit-bidding on it, his entire claim for tortious injury and compensatory damages instantly evaporates. A plaintiff cannot demand four billion shares in equity damages for the alleged "clouding" of a valueless, dead sandbox.

#### 3. File a Targeted Motion to Compel Production of Source Code to Prove Obsolescence

Demand the immediate physical production of the exact source code files and executable binaries Panik extracted from MediaBin in 2003. This forces a definitive technical and legal checkmate:

* **Forensic Infringement:** If Plaintiffs produce the code, forensic analysis of file headers, timestamps, and architectural dependencies will prove that the repository is an uncompilable, orphaned application layer that improperly contains TMMI's own untransferred 1991 SoftVideo Format (SVF) framework as its "glue."
* **Evaporation of Tort Damages:** Production will visually and structurally demonstrate to the Court that Panik's asset is a completely dead, legacy architecture that has been commercially unusable for over two decades. If Plaintiffs refuse or are unable to produce a functional, modern code engine, they fail to demonstrate an active property interest capable of sustaining millions of dollars in commercial tort damages, inviting immediate evidentiary dismissal sanctions.

---

### DRAFT CONCLUSION FOR PLEADING SUBMISSION

> **"Plaintiffs' multi-million dollar claim for abuse of process is built upon an absolute legal, physical, and commercial vacuum. A software platform cannot be 'misappropriated,' 'raided,' or 'clouded' when the party claiming ownership never legally or physically possessed the underlying source code libraries or the specialized computing hardware required to compile and operate it. More than twenty years have passed since the initiation of this dispute, rendering the underlying legacy code completely obsolete and commercially worthless.**
> **Yet, while the technology has decayed into worthlessness, a concrete $432,266.40+ financial judgment remains active and enforceable against Plaintiffs. As conclusively established by the renewed 2023 record of the Ventura County Superior Court (Case No. SC031696), Plaintiffs have remained in permanent financial default for over two decades on the very judgment that dictated the mandatory closing conditions of their alleged technology transfer. By withholding the court-ordered $144,088.80 principal from the baseline engineer, Plaintiffs legally and structurally blocked the transaction from ever closing. Their physical possession of derivative player files was an unauthorized extraction executed during the chaotic corporate transition of the Interwoven-MediaBin merger, conveying zero intellectual property title.**
> **It is a gross distortion of equity for Plaintiffs to demand a constructive trust over 20,000,000 preferred shares—carrying a conversion rate into 4,000,000,000 shares of TMMI common stock—over an obsolete sandbox they never legally paid for. Under the Doctrine of Unclean Hands, Plaintiffs are completely barred from invoking the equitable protections of estoppel to sustain their claims in Nevada while hiding a multi-decade, multi-state financial breach. Because TMMI has absorbed the assets of the underlying judgment creditor, TMMI holds an active, enforceable debt against Plaintiffs exceeding $432,000.00 due to accrued statutory interest. TMMI's 2013 quiet-title suit was a completely proper, regular invocation of the judicial system to resolve an asset trail obscured by an insider's default. Plaintiffs hold no compensable property interest, they have suffered no cognizable tort damages, and this action must be dismissed as a matter of law."**

FINALLY... The first meaningful post in along time. Thank you for sharing 👍