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Golden of Hambrecht Quist in the letter dated September 19, 1995, together with all documents relied on or referred to in the fairness opinion. IBM also asks for all paperwork referring to or connected to the Asset Buy Agreement dated September 19, 1995 in between Novell and Santa Cruz and all files concerning the sale or transfer of Unix or Unix associated assets from Novell to Santa Cruz, specially like how they arrived at a buy price tag.

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Simultaneously, IBM failed to provide the essential Speak to data. SCO followed up and questioned for this data, but IBM once more refused to provide it. As a result, in November 2003, SCO was pressured to file a motion to compel trying to find, among the other objects, the necessary contact data.

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