Contract analysis

1. Pre-Filing / Investigation | Pre-suit investigation; infringement, validity, and enforceability analysis; claim charting ('271, '893, '647 Patents vs. ProstaSignal™); engagement and conflict clearance | March 2025 | 180 | 240 | $175,000 | $235,000 | $15,000 | $25,000 | $190,000 | $260,000 | Includes preparation of claim charts for all 3 patents-in-suit (asserted claims: '271 Cls. 1,3,5,7,12,18; '893 Cls. 1,2,9,14,

2. Pleadings | Drafting and filing Complaint (March 28, 2025); service on Helios (April 14, 2025); reviewing Answer and Counterclaims (May 12, 2025); drafting Answer to Counterclaims (May 30, 2025); initial CMC preparation (June 18, 2025) | March – June 2025 | 250 | 320 | $245,000 | $320,000 | $10,000 | $15,000 | $255,000 | $335,000 | Counterclaims include invalidity under §§ 101, 102, 103; non-infringement; unenforc

3. Motion to Dismiss Practice | Opposition to Helios's MTD of Counts II and III under § 101 (filed Sept. 15, 2025); briefing (Opp. Nov. 3, 2025; Reply Nov. 17, 2025); oral argument preparation; ruling (denied Jan. 13, 2026) | September 2025 – January 2026 | 280 | 380 | $280,000 | $385,000 | $5,000 | $10,000 | $285,000 | $395,000 | Distinguished Mayo and Myriad; Court held § 101 challenges premature without full claim

4. Fact discovery | Document requests (GDT: 47 RFPs; Helios: 52 RFPs); interrogatories (GDT: 15; Helios: 17); 30(b)(6) depositions (GDT: 14 topics to Helios; Helios: 12 topics to GDT); individual depositions (~10 witnesses); meet-and-confer; motion to compel (RFP Nos. 22, 23, 31 — 34 of 83 withheld privilege documents challenged); Protective Order (two-tier, entered Dec. 18, 2025); third-party subpoena to Corinth Ven

5. E-discovery (Canfield Document Solutions LLC) | Collection (~482,000 docs, 1.7 TB from GDT custodians); processing; hosting on RevealIQ platform (TAR 2.0 / predictive coding); privilege screening; de-duplication; production; project management (Sandra Neville, PM) | March 2025 – Trial (Feb. 2027) | 0 | 0 | $0 | $0 | $1,400,000 | $1,800,000 | $1,400,000 | $1,800,000 | Canfield Document Solutions LLC estimate. Inclu

6. Expert discovery | Retention and management of technical expert (Dr. Franklin Ogawa, Stanford — computational oncology) and damages expert (Dr. Louise Tremaine, Ashworth Economics Group LLC); expert report preparation (due May 15, 2026); rebuttal reports (due July 10, 2026); review of opposing expert reports; expert depositions | January 2026 – August 2026 | 700 | 1000 | $680,000 | $975,000 | $450,000 | $650,000 |

7. Claim Construction (Markman) | Joint Claim Construction and Prehearing Statement; opening and responsive claim construction briefs; preparation of tutorial materials; Markman hearing (Sept. 18, 2026); key disputed terms include 'trained machine-learning classifier,' 'random-forest classifier,' 'panel of at least 22 genes selected from a predefined gene set,' 'risk category,' 'composite risk metric' | March – Septe

8. Pre-Trial / Dispositive Motions | Summary judgment briefing (anticipate motions on invalidity, non-infringement, damages); Daubert motions re: expert testimony; motions in limine; pretrial conference preparation; pretrial order | October 2026 – January 2027 | 550 | 800 | $540,000 | $800,000 | $25,000 | $40,000 | $565,000 | $840,000 | Anticipate Helios will renew § 101 challenge at SJ; also anticipate § 102 (Nakamu

9. Trial | Jury trial preparation; witness preparation; trial presentation and exhibits; jury instructions; verdict form; opening/closing statements; estimated 7–10 trial days | February 2027 | 600 | 850 | $580,000 | $850,000 | $80,000 | $120,000 | $660,000 | $970,000 | Trial team: Bloom (lead trial counsel), Ngo (second chair), Vassiliev, Schultz. Costs include trial graphics/presentation vendor, witness travel, jur

10. Post-Trial (Contingency) | Post-trial motions (JMOL, new trial); permanent injunction / ongoing royalty briefing; potential appeal to Federal Circuit | Post-February 2027 | 0 | 0 | $0 | $0 | $0 | $0 | $0 | $0 | NOT included in current budget estimate. Post-trial and appellate costs would be subject to a separate budget authorization. Estimated range if needed: $1.5M–$3.0M for Federal Circuit appeal. SUBTOTAL — At