Expert Report of Chelton D. Tanger PricewaterhouseCoopers...

CONFIDENTIAL

Expert Report of Chelton D. TangerPricewaterhouseCoopers, LLP

FieldTurf USA Inc., FieldTurf Inc., and FieldTurf Tarkett SASv.

TenCate Thiolon Middle East, LLC f/k/a Mattex LeisureIndustries, Polyloom Corporation of American d/b/a TenCate

Grass North America, and TenCate Thiolon B.V.

Civil ActionFile No.: 4:11-CV-00050

June 28, 2012

Case 4:11-cv-00050-TWT Document 358-29 Filed 10/04/12 of 70

FieldTurf USA Inc., et al. v. TenCate Thiolon Middle East, LLC, et al.Expert Report of Chelton D. Tanger

June 28, 2012

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Contents

Section Page

I Introduction 1

II Background 4

A. The Parties 4

B. FieldTurf Synthetic Turf 4

C. Supply Relationship 5

D. Radiation Exposure 7

E. Summary of Dispute 8

III Damages 11

A. Overview 11

B. Incurred and Planned Replacement Costs 12

C. Projected Replacement Costs 15

D. Incurred and Planned FiberGuard Costs 20

E. Projected FiberGuard Costs 22

F. Improper Price Increases After April 2011 24

G. Remaining Evolution Inventory 26

H. Prejudgment Interest 26

I. Conclusion 27



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Appendices

Contents Tab

Qualifications of Chelton D. Tanger 1

Summary of Matters in which Chelton D. Tanger has Testified as anExpert Witness

2

Summary of Hourly Rates 3

Documents Considered in Forming Opinion 4

Exhibits 5



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I Introduction

I have been retained by counsel for the Plaintiffs in the matter of FieldTurf USA Inc.,

FieldTurf Inc., and FieldTurf Tarkett SAS (collectively, "FieldTurf" or the "Plaintiffs") v.

TenCate Thiolon Middle East, LLC formerly known as Mattex Leisure Industries ("Mattex"),

Polyloom Corporation of American doing business as TenCate Grass North America, and

TenCate Thiolon B.V. (collectively, "TenCate" or the "Defendants"). I have been asked to

render opinions regarding the methodology and quantification of economic damages adequate

to compensate for the economic harm suffered by the Plaintiffs as a result of the alleged

actions of the Defendants, including fraudulent inducement, breach of contract, breach of

warranty, and other related claims.1 In addition, I have also been retained to evaluate and

respond to the damages opinions, if any, rendered by the Defendants’ expert witness on

damages in this matter.

I am a Partner in the Advisory practice of PricewaterhouseCoopers LLP in Atlanta, Georgia.

I received my B.S. degree in Business Administration from the University of Connecticut and

hold an MBA with an emphasis in Finance and Banking from Adelphi University. My

professional qualifications and experience are summarized in my curriculum vitae, located in

Appendices 1 and 2 to this report.

During the course of my work on this matter, I, or staff working under my direction, have

reviewed and analyzed documents produced by the parties to this matter as well as publicly

available information and deposition testimony. Furthermore, I have relied upon the data and

information provided to me by the Plaintiffs and understand that this data and information are

1 Complaint, pp. 59-68



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not in any material way false or misleading. Included in Appendix 4 of this report is a listing

of the information that was considered in reaching my opinions.

Additional information may come to my attention after the date of this report that could affect

the opinions stated herein. Therefore, I reserve the right to supplement and/or amend my

report and opinions as appropriate in light of such additional information.

My opinions are based on my skills, knowledge, training, education and experience in matters

of this nature and my examination of the materials utilized in preparing this report. In

addition, my analysis and opinions rest on the assumption that liability will be decided in

favor of the Plaintiffs. While this assumption is necessary as a basis for my analysis, it does

not imply that I have been retained to provide opinions as to liability. Counsel has also asked

me to assume that Plaintiffs are entitled to a reasonable measure of their direct and

consequential damages.2

This report was developed in accordance with an engagement letter dated March 26, 2012

and is subject to the terms and conditions included therein. This report has been prepared in

connection with the above referenced matter and in accordance with Standards for Consulting

Services established by the American Institute of Certified Public Accountants ("AICPA").

Accordingly, I am providing no attestation or other form of assurance with respect to my

work, and I did not verify or audit any information provided to me. This information has

been prepared solely in connection with FieldTurf USA Inc., et al. v. TenCate Thiolon Middle

East, LLC, et al. and is not intended for reliance in any other context. Any disclosure,

whether oral, written or otherwise, of the contents of this report to parties outside of this

2 If as a matter of law some different measure of damages is found to apply, I will provide a calculation of suchdamages.



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matter shall not be provided without the express written consent of PricewaterhouseCoopers

LLP.



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II Background

A. The Parties

FieldTurf

FieldTurf was founded by Jean Prevost and John Gilman, former professional athletes whose

vision was to design artificial grass and synthetic turf systems that replicated natural grass

and prevented player injuries.3 With thousands of installations, FieldTurf is recognized as the

market leader globally in synthetic sports fields.4 For example, out of the National Football

League's 32 teams, 21 have selected FieldTurf installations for their stadiums and/or practice

fields.5 FieldTurf was acquired by Tarkett in 2004, becoming part of Tarkett Sports.6

TenCate

In early 2007, TenCate acquired the synthetic grass business of Mattex Leisure Industries

("Mattex"), which specialized in producing monofilament fibers.7 TenCate is a supplier of

synthetic turf fibers and backing materials used to create synthetic turf fields.8

B. FieldTurf Synthetic Turf

FieldTurf synthetic turf systems are primarily comprised of extruded monofilament and slit-

film linear low density polyethylene fibers that are tufted, or stitched, into a backing material

and then surrounded and stabilized by FieldTurf's proprietary layered infill system.9 The

3 www.fieldturf.com4 www.fieldturf.com5 www.fieldturf.com6 www.fieldturf.com7 TenCate Press Release: TenCate strengthens its position in the synthetic grass market by acquiring MattexLeisure Industries and announces an offering of new ordinary shares, 2/12/20078 www.tencate.com9 www.fieldturf.com



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backing is composed of permeable polypropylene fabric.10 Utilizing a patented spacing

formula, the fibers are tufted into the backing material in rows, leaving space so that cleats

penetrate the infill material instead of the field's surface fiber.11 After the fibers are stitched

into the backing, coating is applied over the back of each row of stitching, sealing the fiber

rows but still leaving the remainder of the backing permeable for field drainage.12 Finally,

when the synthetic turf is being installed, FieldTurf uses its patented infill system comprised

of sand and rubber granules to stabilize and support the system.13

C. Supply Relationship

It is my understanding that FieldTurf has historically purchased synthetic grass fibers for use

in its products from a number of suppliers, including Mattex and TenCate. Mattex and

TenCate, following its acquisition of Mattex, supplied the defective monofilament fiber that

is at issue in this litigation. This product was sold to FieldTurf under the name Evolution

3GS (“Evolution”). A significant portion of this Evolution fiber was sold to FieldTurf

10 www.fieldturf.com11 www.fieldturf.com12 www.fieldturf.com13 www.fieldturf.com



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pursuant to supply contracts that pre-date TenCate's acquisition of Mattex. FieldTurf entered

into its first supply agreement with Mattex on September 10, 2005 (the "2005 Supply

Agreement") to purchase synthetic grass fibers from October 1, 2005 through December 31,

2006.14 I understand that, in connection with the 2005 Supply Agreement, Mattex provided a

warranty (the "2005 Warranty") to FieldTurf guaranteeing the performance of its Evolution

fiber for six to nine years, depending on the location and corresponding radiation exposure of

the installation.15

On November 29, 2006, FieldTurf extended its supply relationship with Mattex by entering

into a second agreement covering December 1, 2006 through December 31, 2007 (the "2006

Supply Agreement").16 Included with the 2006 Supply Agreement was a warranty (the "2006

Warranty") similar to that included with the 2005 Supply Agreement, guaranteeing the

performance of Mattex's Evolution fiber for six to ten years, depending on the location and

corresponding radiation exposure of the installation.17

As previously noted, TenCate acquired the synthetic grass business of Mattex in early 2007.18

It is my understanding that, at that time, TenCate continued to supply FieldTurf with

Evolution fiber under the 2006 Supply Agreement. I further understand that, on April 4,

2007 and April 11, 2007, FieldTurf and TenCate executed amendments to the 2006 Supply

Agreement related to the prices charged for Evolution.19

14 Exhibit A to the Complaint: The 2005 Supply Agreement15 Exhibit B to the Complaint: The 2005 Warranty16 Exhibit C to the Complaint: The 2006 Supply Agreement17 Exhibit D to the Complaint: The 2006 Warranty18 TenCate Press Release: TenCate strengthens its position in the synthetic grass market by acquiring MattexLeisure Industries and announces an offering of new ordinary shares, 2/12/200719 Exhibits E and F to the Complaint: Amendments to the 2006 Warranty



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FieldTurf and TenCate entered into a new supply contract on July 1, 2008 covering the period

from July 1, 2008 through December 31, 2011 (the "2008 Supply Agreement").20 It is my

understanding that in 2009, TenCate notified FieldTurf of its intent to terminate the 2008

Supply Agreement as of June 15, 2011.21 Exhibit A to the 2008 Supply Agreement was a

warranty (the “2008 Warranty") covering Evolution for eight to eleven years, depending on

the location and corresponding radiation exposure of the installation.22

It is my understanding that the Evolution fibers that are the subject of this litigation are, in

most cases, represented by FieldTurf product types coded as FTOM and XM. I understand

that both of these FieldTurf products utilize Evolution fibers sourced from Mattex and

TenCate.

D. Radiation Exposure

As noted above, the warranties provided to FieldTurf by the Defendants included as one of

the factors of the warranties the solar radiation levels at the installation locations, as

measured in kLangley and/or Watt/m2. I understand that kLangley and Watt/m2 are related

measures of solar radiation per unit area of surface, and that 1 kLangley per year equals 1.33

Watt/m2.23 The 2005 Warranty and the 2006 Warranty both cited the Ciba kLangley map as

the standard for solar radiation, while the 2008 Warranty cited the climate map of the world

published by the Royal Netherlands Meteorological Institute, also known as KNMI. Exhibit

1 is a copy of the Ciba kLangley map. The warranty periods by radiation levels for the

product at issue in this litigation are summarized in the table that follows:

20 Exhibit G to the Complaint: The 2008 Supply Agreement21 Complaint, p. 3322 Exhibit G to the Complaint: The 2008 Supply Agreement23 Ciba kLangley Map



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Table 1Summary of TenCate Warranties

Radiation in kLangley 2005 Warranty 2006 Warranty

0-100 9 Years 10 Years



161 and up 6 Years 6 Years

Radiation in Watt/m2

kLangley Conversion(A)

2008 Warranty

100-160 75-120 11 years

161-200 121-150 10 years

201-240 151-180 9 years

241 and more 181 and up 8 years

Sources: Exhibit B to the Complaint: The 2005 Warranty, Exhibit D to the

Complaint: The 2006 Warranty, Exhibit G to the Complaint: The 2008 Supply

Agreement (Exhibit A to the 2008 Supply Agreement is the 2008 Warranty)

(A)I calculated this conversion as follows: 1 kLangley per year = 1.33 Watt/m

2

E. Summary of Dispute

I understand that in 2009, FieldTurf began receiving a large number of customer complaints

about premature fiber degradation in field installations using Evolution, and that some

FieldTurf customers under their FieldTurf warranties have demanded full replacement of

their fields or threatened litigation against FieldTurf.24 I understand that in at least one case,

a FieldTurf customer has commenced litigation against FieldTurf due to the failure of its field

incorporating Evolution fibers. I understand that these fiber failures occurred well within the

TenCate warranty periods described previously. It is my understanding that FieldTurf has

reported customer complaints related to defective Evolution fibers to TenCate, and while

TenCate representatives inspected some fields and acknowledged fiber failures in field

24 Complaint p. 36; I understand that FieldTurf grants its customers 8-year warranties.



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inspection reports and other internal correspondence, TenCate has failed to replace or repair

any of these fields. FieldTurf filed this action against TenCate on March 1, 2011, alleging

the claims that follow: fraudulent inducement, breach of contract, breach of warranty, and

bad faith.25

To date, FieldTurf has had to repair and/or completely replace in numerous instances the

failing fields brought to its attention by customers exercising their rights under their

FieldTurf warranties.

I further understand that since the filing of this action, FieldTurf has developed a process

whereby a chemical product called FiberGuard is applied to fields incorporating Evolution

fibers to try to slow damage and possibly prevent complete field failures, mitigating the

associated future losses and damages. I also understand that FiberGuard is a post-installation

coating that can be applied to a synthetic turf field to improve ultraviolet (“UV”) radiation

resistance and therefore extend the field's life. It should be noted that this FiberGuard

process has only recently been developed and employed and its effectiveness is unknown.

There is some concern that it may not be effective in preventing future field failures.

Furthermore, it is my understanding that after FieldTurf advised TenCate of its intention to

file this action based on its allegations that TenCate supplied FieldTurf with defective fiber,

TenCate notified FieldTurf that it would prematurely terminate the 2008 Supply Agreement

on March 2, 2011, instead of its previously planned termination date of June 15, 2011. This

in effect would cut off supplies to FieldTurf more than three months earlier than planned,

causing additional damages as FieldTurf would not be able to meet or fulfill existing

contracts and/or sales. Since the filing of this action, I understand that FieldTurf and TenCate

25 Complaint, pp. 59-68



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entered into a settlement agreement whereby TenCate agreed to continue supplying materials

to FieldTurf. However, I understand that FieldTurf has since alleged that, during this

extended period, TenCate has, in breach of this settlement agreement, increased its prices as a

retaliatory measure on certain products sold to FieldTurf.26

26 TENCATE0001339



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III Damages

A. Overview

In the following sections of this report, I address the issue of damages suffered by FieldTurf

due to the actions of TenCate, which include fraudulent inducement, breach of contract,

breach of warranty, and other related claims.

My opinions as to the damages suffered by FieldTurf are based on my skills, knowledge,

training, education, and experience in matters of this nature and my examination of the

materials reviewed or considered in preparing this report. Based on my experience in matters

of this nature and direction from counsel, a number of economic remedies are available to a

Plaintiff such as FieldTurf. These remedies include, but are not limited to: the costs of

repairing fields installed with defective Evolution fiber; the incurred and planned costs of

replacing fields installed with defective Evolution fiber; the incurred and planned costs of

applying FiberGuard to fields; the projected future costs of replacing fields installed with

such fiber, or in the alternative, the projected costs associated with applying FiberGuard to

the fields that have been identified as having a high probability for failure; the amount

overcharged by TenCate to FieldTurf on products sold after April 2011; the remaining

inventory of Evolution fiber at issue in this litigation that FieldTurf can no longer sell; as well

as prejudgment interest.

It is my opinion that damages in this matter prior to the application of prejudgment interest

would range from approximately $21.3 to $36.2 million based on the categories described

above (Exhibit 2).



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It is important to note that the range above represents a conservative estimate of FieldTurf’s

damages in this matter. To begin, while this damages range includes field replacement costs,

it does not capture any amounts related to minor and/or major repair costs that FieldTurf has

incurred and will continue to incur to repair degrading fields. The repair costs, which

specifically relate to Mattex and TenCate’s Evolution fiber, are numerous in nature, but have,

to date, been difficult to organize, itemize and quantify. I reserve the right to include such

repair costs in my analysis should additional documentation and/or information be made

available.

In addition to the exclusion of repair costs, the damages calculated above do not include any

replacement or repair costs associated with failing fields installed in international locations.

As of the date of this report, while I understand that FieldTurf has incurred costs associated

with field degradation in international locations, I have been asked by counsel for the

Plaintiffs to exclude such international costs from my opinion of damages. This report also

does not include an opinion as to reputational damage that FieldTurf may have suffered.

B. Incurred and Planned Replacement Costs

As of the date of this report, it is my understanding that 27 fields originally installed with

Mattex and TenCate’s Evolution fiber have been replaced due to premature fiber degradation.

Additionally, I understand that 14 fields are currently being replaced, and that an additional

10 fields are scheduled to be replaced within the next three months. In all instances, these

fields were brought to the attention of FieldTurf management under warranty claims asserted

by customers.



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To determine the replacement costs incurred by FieldTurf to date, I analyzed supporting

documentation and data provided by FieldTurf. For each replaced field, I began by reviewing

the related project summary, which I understand is maintained in the normal course of

business by FieldTurf for each field replacement and details the various costs associated with

each replacement. Based on these project summaries, I identified five general categories of

replacement-related costs: grass and rubber, logos and inlays, base, installation, and other

materials. I then reconciled the costs listed on the project summaries to supporting business

and financial documentation and data kept in the normal course of business.

For example, costs related to grass and rubber and other materials for each replaced field

were supported by internal invoices for manufacturing materials, while logos and inlay costs

were supported by invoices from third party vendors. Base costs generally consisted of tear

out costs for the old artificial turf that was installed and any material costs associated with

repairs to the base that may be required. The tear-out portion of the costs was supported by

sub-contractor installation agreements or contracts, and the material costs by third-party

invoices.

Installation costs consisted of labor, material, equipment, sand, freight, and other expenses. If

the installation was performed by a third party, sub-contractor installation agreements were

provided to support the labor, material, and equipment costs. For installations performed in-

house by FieldTurf, week by week salary summaries supported labor costs, which included

gross wages for hours worked, overtime, fringe benefits, mileage, and any per diems

incurred. A construction summary was provided for each in-house installation, supporting

expenses that included rental equipment, hotel expense, overhead allocation, construction



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dumpster, and other expenses incurred on site. In addition, sand, freight, and other

installation costs were supported by invoices from third party vendors.

I was able to reconcile the costs listed on the project summaries to supporting documentation

and data, including invoices, contracts, and other supporting documents for over 90% of the

total costs presented on the project summaries.27

I understand that, in some instances, FieldTurf has been able to offset a portion of the field

replacement cost by providing customers with enhancements to their existing fields, for

which they were willing to pay for some or all of the costs. I subtracted any revenue earned

that was associated with the field replacements from the total costs to fully account for the net

costs of each field replacement.

Based on this analysis, I have calculated that FieldTurf has incurred approximately $6.0

million associated with replacement of the 27 fields (Exhibit 3). As demonstrated in Exhibit

3, these replacement costs average approximately $2.61 per square foot on a weighted

average basis.

In order to estimate the cost of the 14 ongoing field replacements, I utilized the budgeted

costs provided by FieldTurf when available (these budgeted costs were provided for 9 of the

ongoing field replacements). For the remaining ongoing replacements (5 fields), I estimated

the field replacement costs by utilizing the weighted average net cost per square foot of $2.61

for the total square feet of turf to be replaced. Finally, in order to estimate replacement costs

for the 10 currently scheduled fields, I also applied the weighted average net cost per square

foot for completed replacements of $2.61 to the total square feet of turf to be replaced. These

27 The remaining costs do not relate to one specific field or one specific type of cost, and all are consistent withthe type of costs for which I have reviewed supporting documentation and data.



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calculations resulted in total budgeted or estimated costs of $4.7 million for the 24 fields that

are currently either being replaced or are scheduled to be replaced within the next three

months (Exhibit 4).

In total, these costs amount to approximately $10.7 million in damages due to incurred,

ongoing, and scheduled replacement costs (Exhibits 3 and 4).

C. Projected Replacement Costs

In order to project future field replacement costs, I began by analyzing data relating to all

FieldTurf fields installed with Evolution fiber. FieldTurf provided me with a download of its

installation database, which I understand is a company record that is kept in the normal

course of business to track all installations and includes various data points for each

installation. For example, the installation database includes project/field name, location of

installation, fiber product type used, square footage, and installation date, among other data

points.28

I analyzed the installation data and removed any fields that appeared to be duplicates. For

example, in some instances, the installation data contained both a line for an original

installation and a second line item for the replacement of the original installation. In

instances of duplicate line items, I combined the two lines into one so that each field

installation was counted only once. Additionally, for field installations that appeared to be

missing certain data points, such as installations where the fiber product type was listed as

"Unknown," I asked FieldTurf management to perform additional research into the field

installation to identify the missing data. FieldTurf management was able to provide

28 FT00413838



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clarifications regarding missing data points by reviewing other documentation related to the

field installations, such as production orders, purchase orders, and FieldTurf's customer

service tracking database, or other business and financial records maintained by FieldTurf in

the normal course of business.

My analysis of the installation data identified the overall population of FieldTurf field

installations using Evolution fiber.29 These field installations included 1,700 Evolution fields

in total. A count of fields summarized by year is as follows:

Table 2Number of FieldTurf Installations by Year

2005 2006 2007 2008 2009 2010 2011 2012 Total

54 213 368 491 343 192 33 6 1700

Source: FT00413838 (FieldTurf All Installations - SharePoint Export)

As previously discussed in this report, the warranties provided by the Defendants varied in

length of time based on the location and corresponding radiation exposure of the installation

(see Table 1). Consequently, I further analyzed the 1,700 Evolution fields by their respective

field locations and installation dates to determine kLangley radiation zones and warranty end

dates for each field installation. In order to ascertain the relevant kLangley zones that applied

to the field installations in the U.S., I overlaid U.S. state lines over the Ciba kLangley map for

North America (Exhibit 5).

29 It is my understanding that Evolution fibers include product types coded as FTOM and XM.



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In conducting my analysis, while I focused principally on higher radiation zones identified on

the kLangley map, there were a small number of fields outside of these areas that have failed

for reasons that were similar and were subject to a warranty claim asserted by a customer.

As a means of checking this approach, I looked at the number of fields either replaced or

scheduled to be replaced to confirm that the majority of these fields fell within these

geographic boundaries (Exhibit 5).

I then categorized each U.S. state into one of the kLangley radiation zones to determine the

correct kLangley range for each field based on its location by state (Exhibit 6). In

categorizing each U.S. state, I utilized the kLangley radiation zone that covered the majority

of a state. For states that were evenly split by two kLangley radiation zones, I selected the

more conservative (i.e. lower) radiation range. The only state that I divided into two different

kLangley radiation zones was California, which I divided into Northern California and

Southern California.

Exhibit 7 summarizes the 1,700 field installations by kLangley radiation zone by year

installed. Exhibit 8 summarizes the 51 replacements by kLangley radiation zone by year

installed.

As demonstrated in Table 1, the warranties granted by the Defendants covered longer periods

for fields installed in lower radiation zones than those installed in higher radiation zones. The

rate of degradation of the artificial fibers supplied by TenCate is deemed by them to be

affected principally by the amount of solar radiation exposure (i.e., the higher the solar

radiation exposure, the lower the expected life of the fibers). As illustrated in Exhibit 5, I

plotted the approximate locations of the 51 fields that have been replaced, are currently being



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replaced, or are scheduled to be replaced, which indicated that a higher percentage of field

replacements occurred in higher radiation zones.

To project future field replacements, I then analyzed the historical replacement rates of the

oldest field installations, or those fields installed between 2005 and 2006, by radiation zone,

as displayed in Table 3 below.30

Table 32005-2006 Replacement Percentages by Radiation Zone

100-120 120-140 140-160 160-180

2005 Installs Replaced 1 0 2 1

2006 Installs Replaced 2 6 12 4

2005-2006 Installs Replaced 3 6 14 5

2005-2006 Total Installations 102 31 35 13

2005-2006 Replacement % 3% 19% 40% 38%

Sources: FT00413838 (FieldTurf All Installations - SharePoint Export); Exhibit 6

kLangley Radiation Zone

Applying the historical replacement rates for fields installed between 2005 and 2006 by

radiation zone to the population of installations in 2007 through 2012, I have projected that

approximately 162 fields installed in 2007 and later will likely need to be replaced, as

detailed in the table that follows:

30 My analysis of field replacements by year indicated that while a number of fields installed in 2007 have beenreplaced, the overall replacement percentage for 2007 is expected to exceed replacement levels incurred to date.This would be consistent with my understanding that fiber degradation occurs as fields age. I reserve the rightto supplement my opinions should additional information become available regarding actual field replacementsand/or actual claims incurred in the future.



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Table 4Projected Replacements of 2007-2012 Installs by Radiation Zone

100-120 120-140 140-160 160-180 Total

2007 Installs 199 43 48 20

2008 Installs 252 54 77 23

2009 Installs 186 34 38 35

2010 Installs 108 16 17 15

2011 Installs 14 10 2 2

2012 Installs 1 0 0 0

2007-2012 Installs 760 157 182 95

2005-2006 Replacement %(A)

3% 19% 40% 38%

Projected Replacements of

2007-2012 Installs 22 30 73 37 162


kLangley Radiation Zone

(A)Table 3

I subtracted from this total the 23 fields that were installed in 2007, 2008 and 2009 that have

already been replaced, to arrive at a total projection of future field replacements of 139. I

then multiplied the 139 fields by the average square footage of fields installed with Evolution

fiber in or after 2007, which equated to approximately 82,000 square feet. Finally, I

multiplied the total square footage to be replaced by the historical weighted average net

replacement cost per square foot experienced by FieldTurf on completed field replacements,

or approximately $2.61 per square foot. I believe this is conservative as it assumes all costs

to replace fields have and will remain constant, and that none of the many components

previously identified would experience any increases. My calculation resulted in a projection

of future replacement costs of approximately $29.9 million (Exhibit 9).

Because these projected replacement costs represent an estimate of damages that FieldTurf

will incur in the future, they must be discounted to their present value as of the date of my



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report. The present value represents the value of a future stream of payments or cash flows,

discounted to a current date at a given rate of return, or discount rate. In my experience, a

discount rate that would be appropriate in matters such as these is the plaintiff’s weighted

average cost of capital (“WACC”), which represents the weighted average of a firm’s cost of

debt and equity capital. I have estimated FieldTurf’s WACC to be approximately 11%

(Exhibit 10).

In addition, I have estimated the discount time period to be between the date of my report and

the end of 2018, which represents the expiration of the FieldTurf warranty of 8 years for the

last full year of field installations of 2010.31 I have used the mid-point convention and

discounted the $29.9 million in projected field replacement costs from October 1, 2015, the

approximate mid-point of the discount time period. While some of the field replacement

costs would be incurred before this date and some after, use of the mid-point convention

results in the averaging of the projected future costs across the discount time period.

Based on the calculation described above, I have determined that the present value of the

projected future replacement costs would amount to approximately $21.3 million (Exhibit 9).

D. Incurred and Planned FiberGuard Costs

As previously discussed, FieldTurf developed a process using a chemical product,

FiberGuard, in an attempt to mitigate future losses associated with repairing and replacing

failing fields. I understand that FiberGuard is a post-installation coating that can be applied

to a synthetic turf field to improve UV radiation resistance and therefore extend the field's

life. As of the date of this report, FieldTurf has recently begun applying FiberGuard to

31 While some fields were installed in 2011 and 2012, 2010 represents the last full year of field installations withthe Evolution fibers.



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degrading fields. I have reviewed and analyzed data associated with 8 fields that have been

FiberGuarded to date, including a summary of the associated costs to FiberGuard those fields.

In addition, I have been provided with a list of fields that are currently scheduled to be

FiberGuarded over the remainder of this calendar year.32 I understand from discussions with

FieldTurf management that, at the present time, FieldTurf's initial plan is to have two

FiberGuard crews target fields that were primarily installed from 2007 to 2009 in high

radiation zones. One crew is applying FiberGuard to fields in Texas and to the east, and the

other crew is applying FiberGuard to fields from Arizona to Southern California.

I understand that the company is projecting approximately two days to apply the FiberGuard

process for one field. The costs of applying FiberGuard to a field include application

equipment rental, contract labor, FiberGuard chemicals, as well as other application and crew

costs. For the 8 fields that have been FiberGuarded to date, I have analyzed summary cost

information that indicates the total costs to FiberGuard those fields amounts to approximately

$104,000 (Exhibit 11). Based on these costs, I have determined that the average cost to apply

FiberGuard to date has been approximately $13,000 per field, and the average cost per square

foot has been approximately $0.16 (Exhibit 11).33 To estimate the costs associated with

FieldTurf's FiberGuard application for the currently scheduled fields, I utilized the average

cost per square foot of $0.16, multiplied by the square footage of each of the fields that are

scheduled to be FiberGuarded. This results in estimated FiberGuard costs of approximately

$1.6 million for the 116 currently scheduled fields (Exhibit 12).

In summary, I have calculated FieldTurf's damages based on incurred and scheduled

FiberGuard costs for 124 fields to total approximately $1.7 million (Exhibits 11 and 12).

32 FT0041385033 I utilized square footage information provided from FieldTurf's installation database (FT00413838).



June 28, 2012

CONFIDENTIAL

22

E. Projected FiberGuard Costs

From discussions with FieldTurf management, I understand that the effectiveness of applying

FiberGuard is still unknown. In addition, even if applying FiberGuard is successful in

stopping or slowing the degradation of fields, I understand that the FiberGuard chemical is

only expected to work for 18 to 24 months, at best. Therefore, depending on the success

level of FieldTurf's initial round of FiberGuard application, FieldTurf may or may not

continue to FiberGuard additional fields in the future. Assuming that, at best, FiberGuard

application proves successful in stopping or slowing fiber degradation, I have projected

future costs associated with continuing to FiberGuard additional fields to prevent complete

field replacements and mitigate damages.

To project future FiberGuard costs, I assumed that FieldTurf would FiberGuard all fields

installed with Evolution fiber in only the higher radiation zones, or those greater than or equal

to 120 kLangley. Based on the installation database provided by FieldTurf, I have

determined that FieldTurf had installed 513 fields in radiation zones greater than or equal to

120 kLangley (Exhibit 7). From this number of fields I removed those fields that have been

or will be replaced and are therefore not subject to FiberGuarding. In addition, I assumed

that if a field was nearing the end of the FieldTurf warranty to its customer, which I

understand is 8 years, or the TenCate warranties to FieldTurf, whichever comes first, and if

the field was showing signs of continued fiber degradation, selling a new field as opposed to

FiberGuarding or replacement might be a more economically feasible option for both

FieldTurf and/or the customer. Consequently, I have not projected a FiberGuard application

cost for any field in the last two years of its warranty period. Finally, I have also removed the

fields that have been or are scheduled to be FiberGuarded, as noted in the prior section of this



June 28, 2012

CONFIDENTIAL

23

report, to avoid duplication. My analysis indicated a remaining total of 307 fields to be

FiberGuarded in the future, assuming that the initial wave of FiberGuard applications proves

successful (Exhibit 13).34

In addition, as noted previously, I understand that even if the application of FiberGuard

proves successful in stopping or slowing the degradation of fields, the FiberGuard chemical is

only expected to last 18 to 24 months, at best. Consequently, many of the fields that are

subject to the application of FiberGuard may need more than one application to stop or slow

degradation through the end of either the FieldTurf warranty period to its customer or the

TenCate warranty periods to FieldTurf. I have therefore calculated the years left on the

warranty period for each field installation, utilizing the earlier of the expiration date of the

FieldTurf or TenCate warranties.

For each of the fields, I then estimated the total number of FiberGuard applications that

would be needed to protect the field through the life of its warranty by conservatively

assuming that FiberGuard applications were effective for the longest expected period of two

years. For example, the field at Amador Valley High School was installed in August 2008 in

Northern California, a kLangley radiation zone of 140-160. The TenCate warranty to

FieldTurf for this field will expire in August 2017, while the FieldTurf warranty to the

customer will expire in August 2016. Assuming this field is FiberGuarded in 2013, it would

need to be FiberGuarded once more to protect it through the life of the FieldTurf warranty. I

have thus projected costs associated with FiberGuarding this field twice.

34 I have been informed by FieldTurf management that the remainder of the fields to be FiberGuarded will takeplace in the next 12 to 18 months.



June 28, 2012

CONFIDENTIAL

24

Based on the above analysis, and utilizing the average actual cost per square foot from

completed FiberGuard applications of approximately $0.16 per square foot, I project damages

from future FiberGuard costs to amount to approximately $7.9 million (Exhibit 13).

As previously noted, because these projected FiberGuard application costs represent an

estimate of damages that FieldTurf will incur in the future, they must be discounted to their

present value as of the date of my report. As before, I have used FieldTurf’s WACC to

discount future FiberGuard costs, which results in a present value of $6.5 million in future

costs (Exhibit 13).

F. Improper Price Increases After April 2011

As previously noted, it is my understanding that FieldTurf alleges that beginning in April

2011, TenCate increased prices charged to FieldTurf in retaliation for FieldTurf’s filing of the

Complaint in this litigation. I have reviewed an email sent on March 7, 2011, from Guido

Vliegen, Group Commercial Director at TenCate, to other TenCate personnel that stated the

following:

“In order to respond to an urgent legal matter I had to set prices for FieldTurf

on Friday. These prices are 15% higher than loyal customer price levels for

most products. This level is indicative for the new general gross prices.

Please implement across the board, whereby high loyalty customers will be

granted a 15% rebate that can be converted into net prices on the invoice.”35

35 TENCATE0001339



June 28, 2012

CONFIDENTIAL

25

In contrast, a letter dated just six days earlier on March 1, 2011, from TenCate to FieldTurf

communicated a 4% to 8% price increase to synthetic turf yarns due to the increased prices of

raw materials.36 According to deposition testimony by Ian Petrie, TenCate’s Vice President of

Sales for the Americas Region, this letter was sent to all TenCate customers with the

exception of FieldTurf on March 1, 2011, and then sent to FieldTurf on March 7.37

In order to determine the extent of the improper increase in prices experienced by FieldTurf

as a result of TenCate’s alleged retaliatory actions, I analyzed TenCate invoices to FieldTurf

from January 2011 to April 2012 (Exhibit 14). I compared unit prices for each unique

product number and calculated the unit price change after April 1, 2011. If the unit price

changed more than once after April 1, 2011, I calculated the difference between the original

pre-April price and the new price for each change. For certain products where a pre-April

invoice was not available, I performed the same analysis by utilizing prices from the TenCate

price list to FieldTurf dated March 1, 2011.38

In addition to the above, I incorporated the 4% to 8% price increase communicated to all

TenCate customers in March 2011 by adjusting the pre-April prices charged to FieldTurf

upward by 4% and 8%. I then multiplied the price increases that exceeded 4% to 8% over

pre-April prices by the quantity sold by TenCate to FieldTurf to arrive at the estimated

amount by which FieldTurf was overcharged. As summarized in Exhibit 14, this resulted in

total damages related to TenCate’s improper price increases of approximately $369,000 to

$511,000.

36 FT0004198737 Deposition of Ian Petrie dated May 23, 2012, pp. 252-274.38 FT00005846



June 28, 2012

CONFIDENTIAL

26

G. Remaining Evolution Inventory

It is my understanding at the date of this report that FieldTurf has approximately $2.1 million

in inventory related to Evolution fibers that cannot be sold, or at best could only be sold at

significantly discounted prices (Exhibits 15 and 16). This inventory is made up of Evolution

fiber raw material, as well as manufactured turf rolls made with the Evolution fiber. I have

been provided with schedules from FieldTurf’s financial systems maintained in the normal

course of business that reflect the quantity and cost of both fiber raw material and

manufactured turf rolls by product type. Management for FieldTurf has made some

adjustments to the cost figures by product to reflect which products might have some

remaining value, albeit at less than what FieldTurf paid for that product.39 I have totaled the

net value or cost of the inventory of Evolution fibers currently on hand at FieldTurf which

cannot be used (Exhibits 15 and 16). In my opinion, this $2.1 million represents an

additional amount that would be due FieldTurf in the form of damages in this matter.

H. Prejudgment Interest

It is my experience that in matters of this nature, prejudgment interest may be awarded from

the date damages began. I have not provided a calculation of prejudgment interest in this

report, as I understand that it is often an issue for the court to decide, but I reserve the right to

supplement my opinion with such a calculation.

39 FieldTurf management estimates that green fiber and green turf rolls can be salvaged at 70% and 50% of theiroriginal cost value, respectively.



June 28, 2012

CONFIDENTIAL

27

I. Conclusion

It is my opinion that damages in this matter prior to the application of prejudgment interest

would range from approximately $21.3 to $36.2 million (Exhibit 2).

In my opinion, the lower end of the damages range would include damages for completed,

ongoing, and scheduled field replacements and FiberGuarding, improper price increases,

remaining Evolution inventory deemed to have no future value, as well as projected costs to

FiberGuard additional fields, assuming the process is effective in stopping or slowing fiber

degradation, which is uncertain. However, to account for the uncertainty associated with the

effectiveness of FiberGuard application, I have calculated the higher end of the damages

range based on damages for completed, ongoing, and scheduled field replacements and

FiberGuarding, improper price increases, remaining Evolution inventory deemed to have no

future value, as well as projected future field replacement costs. It is my opinion that based

on the facts and circumstances known to me at the date of this report, the damages in this

matter would be at the upper end of this range. My opinions of damages in this matter are

summarized in the table that follows:



June 28, 2012

CONFIDENTIAL

28

Table 5Damages Summary

Incurred and Planned Replacement Costs

Incurred and Planned FiberGuard Costs

FiberGuard Costs Replacement Costs

Discounted Projected Costs Range $6,461,396 - $21,283,673

Improper Price Increases After April 2011 $369,084 - $511,483

Remaining Evolution Inventory

Total Damages Range $21,282,325 - $36,247,000

$2,072,007

$10,699,540

$1,680,298

$12,379,838


TAB 1 Qualifications of

Chelton D. Tanger


CHELTON D. TANGERPage 1

Name: Chelton D. TangerAddress:Business: PricewaterhouseCoopers LLP Home: 4367 Bridgehaven Drive, SE

10 Tenth Street, Suite 1400 Smyrna, Georgia 30080Atlanta, Georgia 30309-3851

Telephone: 678-419-8464 770-405-8962

Education:B.S. University of ConnecticutMajor in Business Administration with Emphasis in Marketing

M.B.A. Adelphi UniversityEmphasis in Banking and Finance

Relevant Work Experience:

PricewaterhouseCoopers (Atlanta)

1996-Present Partner of Forensic Services Practice - Southeast Market Leader.

1993-1996 Director of Litigation and Claims Services Practice. Promoted to Director of theAtlanta Litigation and Claims Services Practice.

1990-1992 Manager of Litigation and Claims Services Practice. Mr. Tanger transferred to thenewly created practice where he devoted all his time to providing business and financial advice toattorneys and their clients throughout the litigation process.

1988-1989 Chief Financial Officer for Atlantic Region. Following the consolidation of theSoutheastern and Mid-Atlantic regions of the Firm, Mr. Tanger assumed responsibility for allfinancial operations for the newly formed region. In this capacity, he frequently made presentations tosenior management and outside groups regarding financial issues impacting the Firm, its clients andpersonnel. During this period Mr. Tanger also accepted the responsibility as Director of Operationsfor the Business Investigation Services Practice which housed the Firm's bankruptcy, turnaround andlitigation consulting practices. He was instrumental in the formation of 12 new units in the regionduring 1988. The region consisted of over 45 profit centers with revenues in excess of $250 million.

1983-1987 Chief Financial Officer for Southeastern Region. Mr. Tanger transferred to Atlanta toassume responsibility for the financial operations of over 22 profit centers with annual revenues inexcess of $70 million. His responsibilities included oversight of all financial functions includingcapital spending, treasury and budgeting activities. In addition, he had extensive involvement in areassuch as mergers and acquisitions, real estate and construction, commercial leasing negotiations andthe evaluation of new business and market potential.

(New York)1982 Staff Advisor to Chairman. As part of a 5 person advisory team, Mr. Tanger was instrumentalin developing a dramatic financial and strategic realignment of the Firm. He performed complicated



analyses of issues ranging from service penetration in selected markets to viability of geographicmarkets based on business demographics.

1978-1982 Staff Director of Finance and Administration for Vice Chairman of DomesticOperations. Mr. Tanger was promoted to a position where he advised the Vice Chairman on complexfinancial issues impacting over 50 offices with revenues approximating $200 million. He was oftencalled upon to perform analytical procedures and present his findings on various strategic issuesincluding financial performance forecasting and trend analysis, capital spending and resourceallocation, cost accounting, return on investment, profitability performance, budgeting, cost of capitaland matters involving other treasury functions.

1977 Supervisor of the Budget & Strategic Planning Department. Mr. Tanger was one of theoriginal members of the Firm's Budget and Strategic Planning Department. He assisted in developingthe Firm's initial budgeting and strategic planning modeling which remains the foundation for currentmethodology and systems.

Published MaterialRole of the Expert on Patent Damages, Patent, Trademark and Copyright Law SeminarHandbook, October 22, 1992

Accounting for Damages in Intellectual Property Litigation, IP Value 2005,Intellectual Asset Management, February 2005

Affiliations & CredentialsAssociate Member American Bar Association - Intellectual Property SectionAssociate Member American Bar Association - Antitrust SectionMember Institute of Management AccountantsMember Licensing Executives SocietyFounder and Past Chairman - Atlanta Chapter Licensing Executives SocietyMember Computer Law AssociationRegular Member of The Federal Circuit Bar AssociationCertified Mediator

Speeches and PresentationsNovember 2011, "The Next Decade of Patent Litigation", 23rd Annual North AmericanEntertainment, Sports & Intellectual Property Law Conference

October 2011, "Cross Border Disputes: Maximize Your Protection with Contract &Treaty-based Remedies", Association of Corporate Counsel - Georgia Chapter's SecondAnnual CLE Jamboree

September 2010, "2010 IPO Annual Meeting - Establishing an Objective Value of IP",Intellectual Property Owners Association

May 2010, "Sixth Annual SpringPosium Intellectual Property CLE Conference -Effective Use of Experts in IP Litigation", Atlanta Bar Association - Intellectual PropertySection



April 2010, "Educational Briefing, Reception and "First Look" at the 2010 Lead DirectorStudy", PricewaterhouseCoopers LLP

May 2008, "Continuing Changes in Licensing Strategies and Royalties", Atlanta BarAssociation - Intellectual Property Section

August 2006, "The Use of Technology in Complex Cases: Courtroom Tools for a VisualCulture", American Bar Association Annual Conference

January 2006, “Expert Discovery”, American Bar Association – LitigationLeadership Winter Meeting

October 2004, “Calculating the Value of Patents – The Impact of Alternatives, PriceErosion and Convoyed Sales”, Law Seminars International

August 2004, “Spoliation of Evidence”, American Bar Association Annual Conference

March 2004, “Calculating & Proving Patent Damages - Determining “Reasonable andNondiscriminatory Royalties”, Law Seminars InternationalDecember 2002, “Information Technology Litigation, Selecting Computer Models forCalculating Damages”, Law Seminars International

December 2001, “Information Technology Litigation, Future Damages &Handling Uncertainty”, Law Seminars International

October 2001, “Patent Litigation”, Practicing Law Institute Seminar

April 2001, “Comparative Analysis of Damages Models (Trademark vs. Patent vs.Copyright)”, Law Seminars International

October 2000, Patent Litigation, "Direct and Cross Examination of a Damages Expert -Demonstrations and Panel Critique", Practicing Law Institute Seminar

October 1999, Patent Litigation, "Direct and Cross Examination of a DamagesExpert - Demonstrations and Panel Critique", Practicing Law Institute Seminar


May 1998, "The Value of Innovation & Information at the Turn of the Century",Fulton County Chamber of Commerce

March 1998, "Managing the Revolving Stable Door", Intellectual PropertyConference 1998


October 1996, "Valuing Intellectual Capital", Sponsored by Georgia Technology Month



October 1996, "Valuing Intellectual Capital", Licensing Executives Society, AnnualMeeting

October 1994, "Patent Licensing - Determining Royalty Rates - Business and FinancialIssues", Technology Network Exchange, Atlanta, Georgia

October 1992, "Role of the Expert on Patent Damages", Patent, Trademark andCopyright Law Section of the State Bar of Georgia

October 1992, "Role of the Expert on Patent Damages", 1992 Executive Forum forTechnology Executives, Sponsored by Georgia Technology Month

April 1992, "Expert Witness Testimony on Hedonic Damages in Wrongful Death", MockTrial Educational Seminar, Atlanta Insurance Claims Conference

CONTACT Chelton D. TangerINFORMATION PricewaterhouseCoopers LLP

10 Tenth Street, Suite 1400Atlanta, GA 30309-3851(678) 419-8464 (voice)(813) 207-3415 (fax)(404) 697-9536 (mobile)[email protected] (e-mail)


TAB 2 Summary of

Matters in which Chelton D. Tanger has Testified as

an Expert Witness



CaseDate of

TestimonyType of

Testimony

HTTP Hypothermia Therapy, LTD. vKimberly-Clark Corporation, Kimberly-ClarkWorldwide, Inc., And Kimberly-ClarkGlobal Sales, Inc.

June 2012 Deposition

Education Logistics, Inc., et al. v. LaidlawTransit, Inc., et al.

November 2011 Deposition

Phyllis T. Craighead v. BlueCross BlueShieldof Tennessee, Inc., et al.

May 2011 Trial

Randall Hill v. Patrick Riley and AGBLLCof Florida

December 2010 Deposition &Trial

Langdale Miller Nalley, IndividuallyAttorney -In -Fact for Virginia Miller, et al. vJohn W. Langdale, Jr. and the Langdale Companyv. Harley Langdale, Jr., et al.


Corey Airport Services, Inc., et al. v.The City of Atlanta, et al.

July 2010 Deposition& Trial

Dow Chemical Company v. NOVA Chemical Corp June 2010 Deposition &Trial

APT Advanced Polymer Technology Corp., et al.v. Textile Management Associates, Inc., et al.

March 2010 Deposition

Barber Auto Sales, Inc. v. United Parcel May 2009 DepositionService, Inc.

Coral SR, LLC v. Matria Healthcare, Inc. et al. November 2008 Deposition &Arbitration

The Matter of Certain Nitrile Gloves -U.S. International Trade Commission

May 2008 Deposition &Trial

The Insurance House, Inc. v.Insurance Data Processing, Inc.

April 2008 Deposition

Barton Protective Services LLC andSpectaguard Acquisition LLC v.Charles Barton Rice, Sr., et al.

December 2007 Deposition



CaseDate Of

TestimonyType of

Testimony

CP Solutions PTE. LTD v. GeneralElectric Company et. al

December 2006 Deposition

Imaging International Inc. v.Hell Graphic Systems, Inc. andLinotype-Hell Company

November 2006 Trial

Uniters S.p.A., et. al. -v- Steven Friedman November 2006 Deposition

VAE Nortrak North America, Inc. v.Progress Rail Services Corp.

August 2006 Deposition

CollegeNET, Inc. v. ApplyYourself, Inc. August 2006 Deposition

Analog Devices, Inc. v. Maxim IntegratedProducts, Inc.


United States ex rel. Scott Pogue v.Diabetes Treatment Centers of America, et al.


Optimum Technologies v. Henkel ConsumerAdhesives, Inc.

February 2006 Deposition &Trial

Tillotson Corporation v. Omnigrace, Ltd. April 2006 Trial

Optimum Technologies v. The Home Depot August 2005 Deposition

KC Partnership v. Perimeter Ford, Inc.and Group 1 Automotive, Inc.

July 2005 Deposition &Arbitration

The Coca-Cola Company v. Pepsico, Inc.,Pepsi-Cola Company, Repak, LLC andDDS Rapak, Inc.

April 2005 Deposition &Trial

Nassau Technologies, Inc., et al. v.RETAINAGROUP Limited


PERGO, Inc. v. FAUS Group, Inc. andIndustrias Auxiliares S.L.


Concerto International Software, LLC v.Noble Systems Corporation

January 2005 Deposition &Arbitration

Metal Press, S.A. de C.V. v. ArrisInternational, Inc.

September 2004 Deposition &Trial



CaseDate Of

TestimonyType of

Testimony

UNIQ Technologies, Inc. v. Emerging DisplayTechnologies Corporation, a Californiacorporation and Emerging Display TechnologiesCorporation, a Taiwanese Corporation


KeyTrak, Inc. v. Key Management, Inc. et al. May 2004 Deposition &Trial

Go Medical Industries Pty, Ltd. andAlexander G.B. O’Neil v. Inmed Corporationand Alpine Medical, Inc.

February 2004 Deposition &Trial

Dial One of the Mid-South, Inc. v.BellSouth Telecommunications, Inc., et al.

October 2003 Deposition &Trial

Conitex Sonoco v. American International Group July 2003 Deposition &Trial

Dr. Ing. h.c. F. Porsche AG and Porsche CarsNorth America, Inc. v. DaimlerChrysler Corporation

February 2003 Deposition

Leon Stambler v. VeriSign, Inc. et al. January 2003 Deposition

Christensen v. Christensen January 2003 Deposition &Trial

Biovail Pharmaceutic v. Eli Lilly and Company September 2002 Deposition

Perry Ellis International, Inc. f/ka SupremeInternational, Inc. v. Premiumwear, Inc. f/k/aMunsingwear, Inc. and New EnglandBusiness Services, Inc.


Reflexxion Automotive v. GoodmarkIndustries

May 2002 Deposition

Morris Communications Corporation v.PGA Tour, Inc.


Owen Mumford USA, Inc. v. Surgilance, Inc. December 2001 Deposition

Lightmedia Interactive et al. v. RaytheonCompany et al.

September 2001 Deposition &Arbitration



CaseDate Of

TestimonyType of

Testimony

American Marine (S) Pte. Ltd. and GrandBanks Yachts, Ltd. v. Composite Structures, Inc.


American Classifieds, LLC, et al. v.Christopher R. Christensen, et al., AmericanClassifieds, LLC, et al., v. C-Cubed, Inc. et al.


The Read Corporation v. Powerscreen ofAmerica, Inc.

February 2001 Trial

SpectRx, Inc. v. Non-Invasive MonitoringCompany, Inc.; Altea Technologies, Inc.; andJonathan Eppstein

September 2000 Arbitration

Blue Ridge Designs, Inc. v. Gemmy IndustriesCorp.


Neogen Corporation vs. Vicam, L.P., et al. February 2000 Deposition

Hansen & Hundebol, Inc. v.Quickwood, Inc., et al.

January 2000 Deposition &Trial

GEAC v. Grace Consulting, Inc. et al. October 1999 Deposition

Rollins, Inc. v. ALE Systems, Inc. June 1999 Arbitration

Tasnet, Inc. v. General ElectricCompany et al.

June 1999 Deposition &Trial

L’Oreal S.A. and Cosmair, Inc. v.Revlon Consumer Products Corp., CharlesRevlon, Inc., and Almay, Inc.


Dun & Bradstreet Software Services, Inc. v.Grace Consulting, Inc. et al.


United Refrigeration, Inc. v. Pameco Corp.and Sid Harvey Industries, Inc.

May 1998 Deposition

Antec Corporation v. MooreDiversified Products


Brasseler, USA I, L.P. v. StrykerCorporation, et al.




CaseDate Of

TestimonyType of

Testimony

Kimberly Clark Worldwide, Inc. v.Inbrand Corporation


Lueder Seecamp v. Glock, Inc. January 1998 Deposition

Seaside Community Development v.Monarch Realty, Inc.

September 1997 Trial

Pacrim Associates v. Turner HomeEntertainment

July 1997 Deposition

Glock, Inc. v. Smith & Wesson , Corp. April 1997 Deposition &Trial

Mohawk Industries, Inc. v. Southwest SyntheticTurf, Inc.


Crider Furs, Inc. v. North Central TradingCompany and Southeastern Mills

January 1997 Deposition

Labor Force, Inc. v. LSW, Inc. et al. June 1996 Deposition

J.T. Eaton & Co. v. Enforcer Products, Inc. February 1996 Deposition &Trial

Hansen & Hundebol A/S v. Quickwood Inc. July 1995 Deposition &Trial


TAB 3 Summary of Hourly Rates


Professional Staff Hourly Rate

Chelton D. Tanger $600

Other Professionals $230-$400

Summary of Hourly Rates


June 28, 2011


TAB 4 Documents

Considered in Forming Opinion


No. Beginning Bates Ending Bates Description

1 FT00005846 FT00005846 March 1, 2011 TenCate Price List

2 FT00041986 FT00041987 Exhibit 075 - Vliegen.pdf

3 FT00203458 FT00203459 Email with pricing information

4 FT00204418 FT00204427 Invitations to inspect

5 FT00204444 FT00204444 Invitation to inspect - Valhalla

6 FT00205502 FT00205502 Notice of Customer Claim 2011-06-21

7 FT00205728 FT00205728 Invitation to inspect - Rochester

8 FT00206088 FT00206088 Invitation to inspect - Edison



11 FT00295180 FT00295185 Email about upcoming FieldTurf orders

12 FT00408051 FT00408088 TenCate Invoices (January 2011 - April 2012)




16 FT00408533 FT00408585 Bishop Verot High School Replacement Cost Documents

17 FT00408536 FT00408617 Atlanta Silverbacks Replacement Cost Documents

18 FT00408618 FT00408657 Humble ISD-Turner Stadium Replacement Cost Documents

19 FT00408658 FT00408727 Aledo ISD Replacement Cost Documents

20 FT00408728 FT00408767 Navasota Replacement Cost Documents

21 FT00408768 FT00408799 Lake Brantley High School Replacement Cost Documents

22 FT00408800 FT00408848 Kirkwood Soccer Replacement Cost Documents

23 FT00408849 FT00408882 Camden County High School Replacement Cost Documents

24 FT00408883 FT00408912 Little Elm High School Replacement Cost Documents

25 FT00408913 FT00408948 Traz Powell Stadium Replacement Cost Documents

26 FT00408949 FT00409001 Lakeland Christian School Replacement Cost Documents

27 FT00409100 FT00409119 Baker University Replacement Cost Documents

28 FT00409120 FT00409136 Calabasas High School Replacement Cost Documents

29 FT00409137 FT00409159 Midlothian Practice Replacement Cost Documents

FieldTurf USA Inc., et al. v. TenCate Thiolon Middle East, LLC, et al.

Expert Report of Chelton D. Tanger

June 28, 2012

Documents Considered in Forming Opinion

CONFIDENTIAL





June 28, 2012


30 FT00409160 FT00409198 Occidental College Replacement Cost Documents

31 FT00409199 FT00409224 St. Thomas Aquinas Replacement Cost Documents

32 FT00409225 FT00409239 St. Genevieve High School Replacement Cost Documents

33 FT00409240 FT00409259 Valhalla High School Replacement Cost Documents

34 FT00409260 FT00409277 West Covina High School Replacement Cost Documents

35 FT00409278 FT00409295 Mission Viejo Replacement Cost Documents

36 FT00409296 FT00409310 Edison Elementary School Replacement Cost Documents

37 FT00409311 FT00409325 Gilmer High School Replacement Cost Documents

38 FT00409326 FT00409346 New Fairfield High School Replacement Cost Documents

39 FT00409347 FT00409360 Atlanta Silverbacks Replacement Cost Documents (contracts)

40 FT00409361 FT00409371 Project Summaries for ongoing replacements

41 FT00409840 FT00409853 Midlothian Stadium Replacement Cost Documents

42 FT00409898 FT00409944 War Memorial Replacement Cost Documents

43 FT00409945 FT00409969 Lincoln High School Replacement Cost Documents

44 FT00409970 FT00409988 Wake Forest Replacement Costs Documents

45 FT00412420 FT00412420 Fiberguard chemical invoice

46 FT00412421 FT00412421 Fiberguard chemical invoice: Brophy College

47 FT00412422 FT00412422 Fiberguard chemical invoice: Monument High School

48 FT00412423 FT00412423 Fiberguard chemical invoice: Sedona Red Rock High School

49 FT00412424 FT00412424 Fiberguard chemical invoice

50 FT00412425 FT00412425 Fiberguard chemical invoice: Winslow High School

51 FT00412426 FT00412436 Baker University Replacement Cost Documents (removal and disposal contract)

52 FT00412437 FT00412438 Kirkwood Soccer Replacement Cost Documents (application for payment)

53 FT00412439 FT00412442 Midlothian Practice Replacement Cost Documents (invoices)

54 FT00412443 FT00412452 Midlothian Stadium Replacement Cost Documents (application for payment and invoices)

55 FT00412453 FT00412454 St. Thomas Aquinas Replacement Cost Documents (application for payment)

56 FT00412455 FT00412458 War Memorial Replacement Cost Documents (application for payment and invoice)

57 FT00412459 FT00412460 Lake Brantley High School Replacement Cost Documents (invoice)

58 FT00412461 FT00412462 New Fairfield High School Replacement Cost Documents (invoice)

CONFIDENTIAL





June 28, 2012


59 FT00412463 FT00412467 Atlanta Silverbacks Replacement Cost Documents (invoices)

60 FT00412468 FT00412476 Wake Forest Replacement Costs Documents (removal contract)

61 FT0041247 FT00412490 Calvary Baptist Academy Replacement Cost Documents

62 FT00412491 FT00412507 Invoices from purchases by Fieldturf for material from TenCate

63 FT00412508 FT00412508 Customer Service List

64 FT00413838 FT00413838 FieldTurf All Installations - SharePoint Export

65 FT00413839 FT00413839 Notification Replacement Reserve

66 FT00413840 FT00413841 FiberGuard (Arizona Cluster)

67 FT00413842 FT00413849 FiberGuard (Dallas Cluster)

68 FT00413850 FT00413850 Field List & Costs (Incl FiberGuard Schedule)

69 FT00413851 FT00413855 FiberGuard (San Diego Cluster)

70 FT00413856 FT00413856 TenCate Inventory Receipts

71 FT00413857 FT00413857 Vendor Ledgers - TenCate.xlsx

72 FT00413858 FT00413858 Midlothian Stadium replacement cost documents (invoice)

73 FT00413865 FT00413867 Aledo ISD Replacement Cost Documents

74 FT00413868 FT0041372 Lakeland Christian School Replacement Cost Documents (Invoices)

75 FT00413873 FT00413877 Atlanta Silverbacks Replacement Cost Documents (invoices)

76 FT00413878 FT00413881 Valhalla High School Replacement Cost Documents (Salary summary)

77 FT00413882 FT00413888 Mission Viejo Replacement Cost Documents (invoices)

78 FT00413889 FT00413901 Edison Elementary School Replacement Cost Documents (Job Accrual Analysis Report)

79 FT00413902 FT00413936 Lincoln High School Replacement Cost Documents (Contracts and invoices)

80 FT00414019 FT00414021 St. Genevieve High School Replacement Cost Documents (Salary Summary)

81 FT00414027 FT00414048 West Covina High School Replacement Cost Documents (Salary Summary and invoices)

82 FT00414049 FT00414050 Barron Collier High School Job Accrual Analysis Report

83 FT00414051 FT00414083 Agoura Hills Replacement Cost Information (10-Agoura Hills-CA.pdf)

84 FT00414091 FT00414096 Backup for Costs - Bishop Verot High School .pdf

85 FT00414097 FT00414101 Revenue Backup - Aledo ISD.pdf

86 FT00414102 FT00414105 Revenue Backup - Baker University.pdf

87 FT00414106 FT00414106 Revenue Backup - Camden County .pdf

CONFIDENTIAL





June 28, 2012


88 FT00414113 FT00414117 Revenue Backup - Gilmer ISD.pdf

89 FT00414118 FT00414126 Revenue Backup - Humble ISD Turner Stadium.pdf

90 FT00414127 FT00414132 Revenue Backup - Lakeland Christian School .pdf

91 FT00414133 FT00414135 Revenue Backup - Little Elm ISD.pdf

92 FT00414136 FT00414141 Revenue Backup - Midlothian ISD Practice.pdf

93 FT00414142 FT00414147 Revenue Backup - Midlothian ISD Stadium.pdf

94 FT00414148 FT00414161 Revenue Backup - Occidental College.pdf

95 FT00414162 FT00414167 Revenue Backup - St. Thomas Aquinas High School.pdf

96 FT00414168 FT00414169 Revenue Backup - Traz Powell Field .pdf

97 FT00414170 FT00414174 Revenue Backup - War Memorial Stadium.pdf

98 FT00414175 FT00414179 Revenue Backup - West Covina High School.pdf

99 FT00414180 FT00414180 Remaining TenCate Inventory

100 TENCATE0001339 TENCATE0001342 Pricing Emails

101 TENCATE0008091 TENCATE0008092 Price Update Email

102 TENCATE0008092 TENCATE0008092 Competitive price information (TENCATE0008092.xls)

103 TENCATE0008204 TENCATE0008207 Pricelist Email

104 TENCATE0008687 TENCATE0008692 Pricelist Emails

105 TENCATE0008730 TENCATE0008730 Email about outstanding orders for Fieldturf

106 TENCATE0008865 TENCATE0008865 Email about approval for delivery from TenCate to Tarkett

107 TENCATE0008874 TENCATE0008878 Emails about pricing

108 TENCATE0009133 TENCATE0009133 Email about agreement with FieldTurf

109 TENCATE0009198 TENCATE0009199 Email about pricing

110 TENCATE0009199 TENCATE0009199 FieldTurf Prices (TENCATE0009199.xlsx)

111 TENCATE0009340 TENCATE0009345 Email with Price List (Effective Date: 9/15/2010 and 7/21/2009)

112 TENCATE0009988 TENCATE0009989 Email with Price List Attachment

113 TENCATE0009989 TENCATE0009989 Price Summary for different customers (TENCATE0009989.xlsx)

114 TENCATE0010288 TENCATE0010293 Email with Price List (Effective Date: 9/15/2010 and 7/21/2009)

115 TENCATE0010518 TENCATE0010522 Email with Price List (Effective Date: 4/15/2010)


CONFIDENTIAL





June 28, 2012



118 TENCATE0011760 TENCATE0011760 Email about price increases

119 TENCATE0011783 TENCATE0011783 Email about price increases


121 TENCATE0012087 TENCATE0012088 Email asking for updated price matrix


123 TENCATE0012345 TENCATE0012346 Email correcting price list


125 TENCATE0012524 TENCATE0012525 Email with price proposal


127 TENCATE0012547 TENCATE0012547 Email asking if FieldTurf was notified of price increase

128 TENCATE0012600 TENCATE0012601 Email with attached price list









137 TENCATE0013528 TENCATE0013528 Email about approval for delivery from TenCate to Tarkett

138 TENCATE0013530 TENCATE0013531 Email with attached price summary


140 TENCATE0013537 TENCATE0013547 Email with attached price lists (Effective Date: 4/16/2010 and 9/15/2010)

141 TENCATE0013550 TENCATE0013553 Emails with attached price lists



144 TENCATE0013605 TENCATE0013607 Emails with attached price lists


CONFIDENTIAL





June 28, 2012


146 TENCATE0015212 TENCATE0015215 Email with attached price lists (Effective Date: 4/25/2011)

147 TENCATE0015221 TENCATE0015231 Email with attached price lists (Effective Dates: 7/21/2009, 4/16/2010 and 9/15/2010)

148 TENCATE0017358 TENCATE0017359 Emails about 2011 prices

149 TENCATE0017391 TENCATE0017414 Email with attached price lists (Effective Dates: 7/21/2009, 4/16/2010 and 9/15/2010)







156 TENCATE0026138 TENCATE0026138 Notice of Customer Claim 2011-01-24

157 List of ongoing and scheduled field replacements

158 Field Replacements - prepared by Finance as of April 30, 2012.xlsx

159 Field Replacements - as of June 6 2012.xlsx

160 Ciba kLangley Map (http://www.meteor.co.il/download/radiation map.pdf)

161 TenCate Press Release, 2/12/2007

162 www.fieldturf.com

163 www.tencate.com

164 Deposition of Ian Petrie dated May 23, 2012

165 U.S. Department of the Treasury Daily Treasury Yield Curve Rates (www.treasury.gov)

166 2011 Ibbotson SBBI Valuation Yearbook

167 Moody's Bond Indices Corporate BAA Analysis (www.bloomberg.com)

168 Value Line Cost of Capital by Sector

169 Dow Jones Company Snapshot: FieldTurf Tarkett Sas (djce.dowjones.com)

170 Federal Reserve Euro Spot Rates 1999 - 2012 (www.federalreserve.gov)

171 Tarkett Company Report 2007

172 Tarkett Company Report 2011

173 News Article "KKR buys controlling stake in Tarkett" (www.floorcoveringweekly.com)

CONFIDENTIAL


TAB 5 Exhibits


CONFIDENTIAL

Source: http://www.meteor.co.il/download/radiation map.pdf

Exhibit 1Ciba kLangley Radiation Map


Incurred and Planned Replacement Costs1

Incurred and Planned FiberGuard Costs2

FiberGuard Costs Replacement Costs

Discounted Projected Costs Range3$6,461,396 - $21,283,673

Improper Price Increases After April 20114$369,084 - $511,483

Remaining Evolution Inventory5

Total Damages Range $21,282,325 - $36,247,000

1Exhibit 3; Exhibit 42Exhibit 11; Exhibit 123Exhibit 13; Exhibit 94Exhibit 145Exhibit 15; Exhibit 16

$2,072,007

$10,699,540

$1,680,298

$12,379,838

Exhibit 2

Damages Summary

CONFIDENTIAL


School Location Sq. Ft. Grass & Rubber Installation Base Logos & Inlays Other Materials Total Before Sale Sale Grand Total Net Cost per Sq. Ft.

1 Bishop Verot High School FL 77,523 97,629 99,963 67,941 10,652 2,453 278,638 278,638 3.59

2 Atlanta Silverbacks GA 89,760 125,689 83,880 30,963 1,000 241,533 241,533 2.69

3 Humble ISD-Turner Stadium TX 78,406 110,908 85,666 29,525 15,091 1,505 242,695 (53,600) 189,095 2.41

4 Aledo ISD Stadium TX 90,451 135,071 108,698 45,268 14,095 2,150 305,282 (25,000) 280,282 3.10

5 Lake Brantley High School FL 91,608 118,477 91,028 38,666 27,170 2,389 277,729 277,729 3.03

6 Kirkwood Soccer DE 77,000 81,454 123,536 58,624 3,721 1,805 269,140 269,140 3.50

7 Camden County HS GA 85,000 135,186 98,140 6,281 18,665 2,416 260,688 (4,500) 256,188 3.01

8 Little Elm High School TX 80,740 81,963 88,909 3,417 6,353 1,787 182,428 (7,500) 174,928 2.17

9 Traz Powell Stadium FL 102,760 142,971 106,461 25,655 2,196 277,283 (77,875) 199,408 1.94

10 Lakeland Christian School FL 88,291 134,890 120,324 46,359 15,703 5,724 323,000 (70,000) 253,000 2.87

11 Mission Viejo High School CA 78,632 98,451 90,172 49,780 5,612 7,213 251,227 251,227 3.19

12 Baker University KS 84,630 102,361 79,980 54,923 5,202 5,942 248,408 (100,000) 148,408 1.75

13 Calabasas High CA 97,604 98,406 150,786 17,405 5,886 272,483 272,483 2.79

14 Midlothian Practice TX 87,401 96,915 89,926 29,687 1,701 218,229 (80,000) 138,229 1.58

15 Occidental College CA 100,933 168,603 103,417 3,784 6,008 281,812 (150,000) 131,812 1.31

16 St Thomas Aquinas FL 97,765 114,661 103,208 43,008 16,257 2,113 279,247 (50,000) 229,247 2.34

17 St. Genevieve High School CA 39,069 39,280 61,607 8,832 1,597 111,316 111,316 2.85

18 West Covina High School CA 83,062 118,164 110,605 77,747 27,460 333,976 (25,000) 308,976 3.72

19 Calvary Baptist Academy LA 76,832 7,315 160,889 19,745 187,949 187,949 2.45

20 New Fairfield High School CT 81,105 100,997 89,423 58,500 3,385 2,305 254,609 254,609 3.14

21 Lincoln High School CA 96,352 137,919 134,608 62,260 15,097 277 350,160 (168,652) 181,508 1.88

22 Wake Forest University NC 95,238 123,003 109,694 30,000 10,792 1,784 275,274 275,274 2.89

23 Midlothian Stadium TX 81,441 97,463 100,076 31,270 18,295 6,522 253,626 (82,400) 171,226 2.10

24 War Memorial AR 87,120 132,260 150,703 29,487 5,617 318,067 (80,600) 237,467 2.73

25 Agoura Hills CA 96,736 92,945 124,897 11,333 5,872 235,047 235,047 2.43

26 Navasota District Stadium TX 82,482 85,215 92,945 27,621 9,042 1,546 216,369 216,369 2.62

27 Valhalla High School CA 79,400 94,127 95,235 51,610 5,820 246,792 246,792 3.11

Total 2,307,341 6,993,006 6,017,879 2.61

$6,017,879

Exhibit 3

Damages from Replaced Fields

Sources: FT00408533 - FT00408585; FT00408536 - FT00408617; FT00412463 - FT00412467; FT00409347 - FT00409360; FT00413873 - FT00413877; FT00413873 - FT00413877; FT00408618 - FT00408657; FT00408658 - FT00408727;

FT00413865 - FT00413867; FT00408768 - FT00408799; FT00412459 - FT00412460; FT00408800 - FT00408848; FT00412437 - FT00412438; FT00408849 - FT00408882; FT00408883 - FT00408912; FT00408913 - FT00408948; FT00408949 -

FT00409001; FT00413868 - FT0041372; FT00409278 - FT00409295; FT00413882 - FT00413888; FT00409100 - FT00409119; FT00412426 - FT00412436; FT00409120 - FT00409136; FT00409137 - FT00409159; FT00412439 - FT00412442;

FT00409160 - FT00409198; FT00409199 - FT00409224; FT00412453 - FT00412454; FT00409225 - FT00409239; FT00414019 - FT00414021; FT00409260 - FT00409277; FT00414027 - FT00414048; FT0041247 - FT00412490; FT00409326 -

FT00409346; FT00412461 - FT00412462; FT00409945 - FT00409969; FT00413902 - FT00413936; FT00409970 - FT00409988; FT00412468 - FT00412476; FT00409840 - FT00409853; FT00412443 - FT00412452; FT00413858; FT00409898 -

FT00409944; FT00412455 - FT00412458; FT00408728 - FT00408767; FT00409240 - FT00409259; FT00413878 - FT00413881; FT00414091 - FT00414096; FT00414118 - FT00414126; FT00414097 - FT00414101; FT00414106; FT00414133 -

FT00414135; FT00414168 - FT00414169; FT00414127 - FT00414132; FT00414102 - FT00414105; FT00414136 - FT00414141; FT00414148 - FT00414161; FT00414162 - FT00414167; FT00414142 - FT00414147; FT00414170 - FT00414174;

FT00414051 - FT00414083; FT00413838.

Damages from Completed Replacements:

HIGHLY CONFIDENTIAL


School Location Sq. Ft. Total Before Sale Sale Grand Total

1 Edison Elementary CA 47,523 143,693 143,693

2 Gilmer High School TX 88,167 344,663 (175,000) 169,663

3 Brook Hill School TX 77,900 236,780 (150,000) 86,780

4 St. Thomas HS TX 89,158 250,472 (175,000) 75,472

5 Pittsburg HS KS 74,980 170,814 170,814

6 University of Rochester NY 76,886 323,719 (193,000) 130,719

7 Towson University MD 90,000 218,820 (185,000) 33,820

8 Santa Ynez HS CA 87,598 276,652 276,652

9 Barron Collier HS FL 80,025 296,927 296,927

Total 712,237 1,384,541

School Location Sq. Ft. Net Cost per Sq. Ft.1

Projected Total

1 Awty International TX 104,566 2.61 272,723

2 Memphis University Hobbs TN 78,371 2.61 204,403

3 Lewisville ISD - Lewisville HS TX 78,582 2.61 204,953

4 Lewisville ISD - The Colony TX 74,176 2.61 193,462

5 Laguna Hills HS CA 84,041 2.61 219,191

Total 419,736 1,094,732

School Location Sq. Ft. Net Cost per Sq. Ft.1

Projected Total

1 Prosper Middle School TX 88,694 2.61 231,327

2 Loyola High School CA 83,462 2.61 217,681

3 Dayton ISD District Stadium TX 91,818 2.61 239,475

4 Santana High CA 78,382 2.61 204,432

5 Lake Highland Prep School FL 77,220 2.61 201,401

6 Pasadena ISD TX 85,224 2.61 222,277

7 Oakdale High School - The Corral CA 83,139 2.61 216,839

8 Isidore Newman School LA 71,539 2.61 186,584

9 Graceland University IA 86,630 2.61 225,944

10 Father Ryan High School TN 98,319 2.61 256,430

Total 844,427 2,202,388

$4,681,661

$6,017,879

$10,699,540

1 Exhibit 3

Sources: FT00409296 - FT00409310; FT00413889 - FT00413901; FT00409361 - FT00409371; FT00409311 - FT00409325; FT00414113 -

FT00414117; FT00409361 - FT00409371; FT00414049 - FT00414050; FT00413838; List of ongoing and planned replacements provided by FieldTurf

management.

Damages from Ongoing Replacements with Budgeted Costs Available

Exhibit 4

Damages from Ongoing and Scheduled Replacements

Damages from Completed Replacements1:

Total Damages from Completed, Ongoing, and Scheduled Replacements:

Total Damages from Ongoing and Scheduled Replacements:

Estimated Damages from Scheduled Replacements Based on Historical Costs

Estimated Damages from Ongoing Replacements Based on Historical Costs

HIGHLY CONFIDENTIAL


CONFIDENTIAL

Exhibit 5kLangley Radiation Map with State Lines and Replacements



Exhibit 6kLangley Radiation Levels by State

kLangley Ranges

100-120

120-140

140-160

160-180


CONFIDENTIAL


Year 100-120 120-140 140-160 160-180 Indoor International Total

2005 11 2 4 1 6 30 54

2006 91 29 31 12 5 45 213

2007 199 43 48 20 7 51 368

2008 252 54 77 23 13 72 491

2009 186 34 38 35 14 36 343

2010 108 16 17 15 8 28 192

2011 14 10 2 2 0 5 33

2012 1 0 0 0 0 5 6

Total 862 188 217 108 53 272 1700


Exhibit 7

FieldTurf Installations by Radiation Zone by Year

HIGHLY CONFIDENTIAL


Year 100-120 120-140 140-160 160-180 Indoor International Total

2005 1 0 2 1 0 0 4

2006 2 6 12 4 0 0 24

2007 2 3 6 8 0 0 19

2008 0 0 3 0 0 0 3

2009 0 1 0 0 0 0 1

2010 0 0 0 0 0 0 0

2011 0 0 0 0 0 0 0

2012 0 0 0 0 0 0 0

Total 5 10 23 13 0 0 51

Exhibit 8

FieldTurf Replacements by Radiation Zone by Year

Sources: FT00413838 (FieldTurf All Installations - SharePoint Export); Exhibit 3; Exhibit 4; Exhibit 6

HIGHLY CONFIDENTIAL


Projected Number of Replacements of Fields Installed in or after 20071

162

Less: Number of Fields Installed 2007-2009 Planned to be or Already Replaced2

23

Projected Number of Future Field Replacements 139

Average Square Footage of Fields Installed in or after 20073

82,397

Historical Weighted Average Net Replacement Cost Per Square Foot4

$2.61

Projected Replacement Costs $29,909,689

Discount Rate5

11.0%

Discounted Projected Replacement Costs6

21,283,673$

1Table 4

2Exhibit 8

3FT00413838 (FieldTurf All Installations - SharePoint Export)

4Exhibit 3

5Exhibit 10

Exhibit 9

Projected Replacement Costs

6Calculated based on the mid-point convention, assuming a future discount date of October 1, 2015.

CONFIDENTIAL


Variable Source

Risk-Free Rate Rf 2.7% 30-year Treasury bill rate as of June 26, 2012

Long-Term Equity Risk Premium Rmp 6.7% Ibbotson Associates 2011 SBBI Yearbook (Valuation Edition)

Beta β 1.2 Estimated beta based on industry; Value Line data

Estimated Size Risk Premium Rs 2.0% Ibbotson Associates 2011 SBBI Yearbook (Valuation Edition); Estimated based on size premia for Low-Cap companies

Company Specific Risk Premium α 0.0% Qualitative estimate based on company-specific risk factors

After-Tax Cost of Equity Ke 12.9% = Rf + (β x Rmp) + Rs + α

Pre-Tax Cost of Debt Dpt 5.0% Moody's BAA corporate bond rate as of June 26, 2012

Estimated Effective Tax Rate T 26.0% Estimated effective tax rate based on industry; Value Line data

After-Tax Cost of Debt Kd 3.70% = Dpt x (1-T)

Percentage of Equity Financing We 75% Estimated capital structure

Percentage of Debt Financing Wd 25% = 1 - We

Weighted Average Cost of Capital (WACC) 10.6% = [Ke x We] + [Kd x Kd]

Rounded 11.0%

Exhibit 10

Weighted Average Cost of Capital (WACC) Calculation

CONFIDENTIAL


Field Name

Square

Footage FiberGuard Date

FiberGuard

Costs

All Saints Episcopal School 77,773 5/31/2012 13,224$

Brophy College Preparatory School 83,387 5/24/2012 13,061$

Canton High School Stadium 88,741 Unknown 13,272$

Monument Valley High School 78,899 5/21/2012 13,407$

Sedona Red Rock High School 77,953 5/26/2012 13,162$

Snyder Independent School District - Tiger Stadium 92,159 5/24/2012 13,268$

Trent High School-Football Field 61,855 5/29/2012 11,644$

Winslow District Stadium 106,457 5/18/2012 13,075$

Total 667,224 104,112$

Actual Average FiberGuard Cost Per Square Foot 0.16$

Sources: FT00413850 (FiberGuard List); FT00413838 (FieldTurf All Installations - SharePoint Export)

Exhibit 11

Incurred FiberGuard Costs

HIGHLY CONFIDENTIAL


Field Name

Square

Footage

Scheduled /

Estimated Planned

FiberGuard Date1

Actual Average

FiberGuard Cost

Per Square Foot2

Estimated Planned

FiberGuard Costs

1 A&M Consolidated High School Stadium 77,275 10/1/2012 0.16$ 12,058$

2 Abilene Christian University - Football Practice Facility 38,448 10/1/2012 0.16$ 5,999$

3 Ada High School 28,800 10/1/2012 0.16$ 4,494$

4 Aldine I.S.D. - W.W. Thorne Stadium 89,505 10/1/2012 0.16$ 13,966$

5 Amarillo ISD Field #1 - Amarillo HS 70,486 6/18/2012 0.16$ 10,998$

6 Amarillo ISD Field #2 - Caprock High School 69,450 6/28/2012 0.16$ 10,837$

7 Amarillo ISD Field #3 - Palo Duro High School 89,625 6/21/2012 0.16$ 13,985$

8 Amarillo ISD Field #4 - Tascosa High School 82,875 10/1/2012 0.16$ 12,932$

9 Amarillo ISD Field #5 - Dick Bivins Stadium 72,000 6/25/2012 0.16$ 11,235$

10 Angleton High School Stadium 100,081 10/1/2012 0.16$ 15,616$

11 Arlington ISD - Cravens Field 100,692 6/6/2012 0.16$ 15,712$

12 Arlington ISD - Wilemon Stadium 100,692 6/7/2012 0.16$ 15,712$

13 Avon Middle School 80,252 10/1/2012 0.16$ 12,522$

14 Baldwin Park High School 102,767 6/11/2012 0.16$ 16,036$

15 Bellevue West High School 77,099 10/1/2012 0.16$ 12,030$

16 Benedictine College 101,301 10/1/2012 0.16$ 15,807$

17 Bixby High School Football Field 77,411 10/1/2012 0.16$ 12,079$

18 Bloomfield High School Football Field 80,216 10/1/2012 0.16$ 12,517$

19 Bobby Bonds - City of Riverside 85,675 10/1/2012 0.16$ 13,369$

20 Boca Raton High School 104,770 10/1/2012 0.16$ 16,348$

21 Breckenridge High School - Buckaroo Stadium 75,882 10/1/2012 0.16$ 11,840$

22 Broken Arrow High School Turf Replacement 81,478 10/1/2012 0.16$ 12,714$

23 Brownsville Sports Park-All Conditions Field 96,250 10/1/2012 0.16$ 15,019$

24 C&K Investments of Oklahoma 11,096 10/1/2012 0.16$ 1,731$

25 Carrollton High School 72,912 10/1/2012 0.16$ 11,377$

26 Carson City High School 88,352 10/1/2012 0.16$ 13,786$

27 Cascia Hall Preparatory School 92,915 10/1/2012 0.16$ 14,498$

28 Cathedral Catholic High School 70,604 10/1/2012 0.16$ 11,017$

29 Catonsville High School - Field #2 99,250 10/1/2012 0.16$ 15,487$

30 Cedar Hill High School 74,175 6/4/2012 0.16$ 11,574$

31 Centennial High School 91,397 10/1/2012 0.16$ 14,261$

32 Charles Rouse High School-New Leander Stadium (4th High School) 78,104 10/1/2012 0.16$ 12,187$

33 Coe College 90,244 10/1/2012 0.16$ 14,081$

34 Collinsville High School 78,079 10/1/2012 0.16$ 12,183$

35 Crenshaw High School 89,480 10/1/2012 0.16$ 13,962$

36 Crespi Carmelite High School 86,829 10/1/2012 0.16$ 13,549$

37 Curtis Park 100,000 10/1/2012 0.16$ 15,604$

38 Del Norte High School 78,229 10/1/2012 0.16$ 12,207$

39 Destrehan High School - St. Charles Parish #1 94,573 10/1/2012 0.16$ 14,757$

40 Diamond Bar High School 97,154 6/2/2012 0.16$ 15,160$3

41 Dinuba High School 93,657 10/1/2012 0.16$ 14,614$

42 Doug Shaw Stadium 77,200 10/1/2012 0.16$ 12,046$

43 East Career Technical Academy 59,926 10/1/2012 0.16$ 9,351$

44 East Jefferson High School 77,800 10/1/2012 0.16$ 12,140$

45 Eastlake High School (CA) 88,770 10/1/2012 0.16$ 13,851$

46 EC Glass High School 98,058 10/1/2012 0.16$ 15,301$

47 Florida International University 91,855 10/1/2012 0.16$ 14,333$

48 Girsh Park 80,812 6/18/2012 0.16$ 12,610$

49 Golden Eagle Regional Park - Field #7 (Football) 109,194 10/1/2012 0.16$ 17,038$

50 Golden Eagle Regional Park - Field #8 (Multi-Purpose Field) 222,335 10/1/2012 0.16$ 34,693$

51 Granite Hills High School 78,239 10/1/2012 0.16$ 12,208$

52 Grossmont College - Replacement Field 102,364 10/1/2012 0.16$ 15,973$

53 Gulf Coast High School 91,457 10/1/2012 0.16$ 14,271$

54 Hahnville High School - St. Charles Parish #2 95,020 10/1/2012 0.16$ 14,827$

55 Heard County High School 93,637 10/1/2012 0.16$ 14,611$

56 Heritage High School (VA) 85,520 10/1/2012 0.16$ 13,344$

57 Heritage High School Football Outdoor 77,859 10/1/2012 0.16$ 12,149$

58 Heritage High School S. Cal 79,838 10/1/2012 0.16$ 12,458$

59 Immokalee High School 80,085 10/1/2012 0.16$ 12,496$

60 Indian Springs 70,000 10/1/2012 0.16$ 10,923$

61 Jenks Public Schools Turf Replacement 73,696 10/1/2012 0.16$ 11,499$

62 John Adams Middle School 208,903 10/1/2012 0.16$ 32,597$

63 John Paul II High School 91,426 10/1/2012 0.16$ 14,266$

64 Junction City High School (Geary County) 88,844 10/1/2012 0.16$ 13,863$

65 Kinkaid School 84,688 10/1/2012 0.16$ 13,215$

66 La Costa Canyon HS - Replacement 89,483 10/1/2012 0.16$ 13,963$

67 LA Southwest College 94,953 10/1/2012 0.16$ 14,816$

68 Leander ISD - AC Bible Stadium 78,177 10/1/2012 0.16$ 12,199$

Exhibit 12

Planned FiberGuard Costs

HIGHLY CONFIDENTIAL


Field Name

Square

Footage

Scheduled /

Estimated Planned

FiberGuard Date1

Actual Average

FiberGuard Cost

Per Square Foot2

Estimated Planned

FiberGuard Costs

Exhibit 12

Planned FiberGuard Costs

69 Legacy Christian Academy 74,324 10/1/2012 0.16$ 11,597$

70 Lely High School 80,095 10/1/2012 0.16$ 12,498$

71 Lewisville ISD #1 - Flower Mound High School 75,393 10/1/2012 0.16$ 11,764$

72 Lewisville ISD #2 - Hebron High School 98,126 10/1/2012 0.16$ 15,311$

73 Life Time Fitness Boca Raton 29,000 10/1/2012 0.16$ 4,525$

74 Louisiana Tech University - Turf Replacement 84,482 10/1/2012 0.16$ 13,182$

75 Lovington High School Football Field 98,000 10/1/2012 0.16$ 15,292$

76 Lumpkin County High School 87,750 10/1/2012 0.16$ 13,692$

77 Maricopa High School Addition and Renovation Phase II 86,854 10/1/2012 0.16$ 13,553$

78 Martin Stadium Football Field - Lowndes County Schools 103,848 10/1/2012 0.16$ 16,204$

79 Mira Mesa High School 77,551 4/16/2012 0.16$ 12,101$

80 Monroe Comprehensive High School 88,491 10/1/2012 0.16$ 13,808$

81 Monte Vista High School 81,500 10/1/2012 0.16$ 12,717$

82 Mountain Brook High School 84,335 10/1/2012 0.16$ 13,159$

83 Mt. Miguel High School 79,399 6/25/2012 0.16$ 12,389$

84 Naples High School 79,914 10/1/2012 0.16$ 12,470$

85 New Braunfels High School 80,909 10/1/2012 0.16$ 12,625$

86 NW Career Tech 69,897 10/1/2012 0.16$ 10,907$

87 Pan Am Stadium 84,093 10/1/2012 0.16$ 13,122$

88 Paramount High School 90,533 10/1/2012 0.16$ 14,127$

89 Perris High School 80,091 10/1/2012 0.16$ 12,497$

90 Port Neches Groves High School 89,111 10/1/2012 0.16$ 13,905$

91 Rancho High School 84,346 10/1/2012 0.16$ 13,161$

92 Ransom Everglades School 69,485 10/1/2012 0.16$ 10,842$

93 Rice Stadium Field 90,320 10/1/2012 0.16$ 14,093$

94 Rockwall High School 90,371 5/22/2012 0.16$ 14,101$

95 Rolling Hills Country Day School 27,140 10/1/2012 0.16$ 4,235$

96 Ruben Ayala Park Expansion 112,384 10/1/2012 0.16$ 17,536$

97 Rubidoux High School - Edward E. Hawkins Stadium 74,806 10/1/2012 0.16$ 11,673$

98 Sams Stadium - Brownsville Independent School District 71,440 10/1/2012 0.16$ 11,147$

99 Santa Monica College - Corsair Field 90,040 6/15/2012 0.16$ 14,050$

100 Seminole High School Football Field 83,852 6/11/2012 0.16$ 13,084$

101 Sierra Vista High School 102,767 7/11/2012 0.16$ 16,036$

102 St. Bernard Parish - Chalmette High School 92,296 10/1/2012 0.16$ 14,402$

103 St. Joseph High School 84,554 6/22/2012 0.16$ 13,194$

104 Strong Rock Christian School 95,000 10/1/2012 0.16$ 14,824$

105 Texas Tech Soccer Field 130,104 7/2/2012 0.16$ 20,301$

106 Trinity University 52,500 10/1/2012 0.16$ 8,192$

107 Tully Stadium - Spring Branch ISD 88,426 10/1/2012 0.16$ 13,798$

108 Tulsa, University of - Mabee Gym 13,908 10/1/2012 0.16$ 2,170$

109 University of Tulsa - Chapman Stadium 84,710 10/1/2012 0.16$ 13,218$

110 Valencia HS - Bradford Stadium 79,300 6/5/2012 0.16$ 12,374$

111 Valley Center High School 88,949 10/1/2012 0.16$ 13,879$

112 Veterans Park Soccer Complex-City of Pomona 323,095 10/1/2012 0.16$ 50,415$

113 Walnut High School 92,476 6/3/2012 0.16$ 14,430$4

114 West Jefferson High School 76,200 10/1/2012 0.16$ 11,890$

115 Willow Grove Elementary School 66,862 10/1/2012 0.16$ 10,433$

116 Yukon High School 92,066 10/1/2012 0.16$ 14,366$

Total 1,576,186$

1For fields planned to be FiberGuarded (listed on FT00413850) without a scheduled date, I estimated a planned FiberGuard date of October 1, 2012.

2Exhibit 11

Sources: FT00413850 (FiberGuard List); FT00413838 (FieldTurf All Installations - SharePoint Export)

3FT00413850, the FiberGuard list, stated that this field was FiberGuarded on 6/2/11. I understand that FiberGuard applications began in 2012, so I assumed that

a typo was made and that the correct date should be 6/2/12.4FT00413850, the FiberGuard list, stated that this field was FiberGuarded on 6/3/11. I understand that FiberGuard applications began in 2012, so I assumed that

a typo was made and that the correct date should be 6/3/12.

HIGHLY CONFIDENTIAL


2013 2014 2015 2016 2017 Total

Number of 1st Projected FiberGuard Applications 307 59 366

Number of 2nd Projected FiberGuard Applications 201 201

Number of 3rd Projected FiberGuard Applications 38 38

Total Number of Projected FiberGuard Applications 307 59 201 0 38 605

Total Square Footage of Fields Projected to be FiberGuarded 25,688,486 5,005,791 17,041,137 0 2,998,234 50,733,648

Actual Average FiberGuard Cost Per Square Foot10.16$

Projected FiberGuard Costs 4,008,374$ 781,092$ 2,659,061$ -$ 467,838$ 7,916,364$

Discount Rate211.0%

Discounted Projected FiberGuard Costs 3,608,051$ 633,409$ 1,942,615$ -$ 277,322$ 6,461,396$

1Exhibit 112Exhibit 10

Exhibit 13

Projected FiberGuard Costs

Sources: FT00413850 (FiberGuard List); FT00413838 (FieldTurf All Installations - SharePoint Export); Exhibit B to the Complaint: The 2005 Warranty; Exhibit D to the

Complaint: The 2006 Warranty; Exhibit G to the Complaint: The 2008 Supply Agreement (Exhibit A to the 2008 Supply Agreement is the 2008 Warranty)

CONFIDENTIAL


Product Name

Product

SKU

Pre Increase

Date

Pre Increase

Price

With 4%

Increase

With 8%

Increase

Post Increase

Date

Post Increase

Price

Increase above

4%

Increase above

8%

Post Increase

Quantity

Impact above 4%

Increase

Impact above 8%

Increase

Woven Grass Backing 170018 3/31/2011 0.395 0.411 0.427 4/12/20111

0.415 0.004 414,105 1,739 -

Woven Primary Backing w/ Fibrillated Warp and Weft 170025 3/31/2011 0.495 0.515 0.535 4/12/20111

0.520 0.005 397,776 2,068 -

PE-10000 Field Green 10000/1 PE 110122 2/17/2011 2.170 2.257 2.344 8/23/2011 2.400 0.143 0.056 152,987 21,908 8,628

PE-10000 Field Green 10000/1 PE 110122 2/17/2011 2.170 2.257 2.344 11/18/2011 2.300 0.043 150,256 6,491 -

PE-10000 Field Green 10000/1 PE 110122 2/17/2011 2.170 2.257 2.344 4/4/2012 2.350 0.093 0.006 135,388 12,618 866

PE-10000 XP PRO Field Green 10000/1 PE 120067 3/30/2011 2.170 2.257 2.344 4/5/2011 2.660 0.403 0.316 824,250 332,338 260,793

CMF 1500X6 Field Green/Olive 9000/6 PE 130123 2/18/2011 2.060 2.142 2.225 7/15/2011 2.530 0.388 0.305 28,268 10,957 8,627

MF TXT 5063 Olive/Lt. Brown 5000/9 PE 145013 2/16/2011 2.770 2.881 2.992 7/15/2011 3.410 0.529 0.418 8,367 4,428 3,501

MF TXT 5063 Olive/Lt. Brown 5000/9 PE 145013 2/16/2011 2.770 2.881 2.992 2/29/2012 2.900 0.019 20,170 387 -

AV9600 Field Green 9600/1 PE 110193 3/1/20112

2.010 2.090 2.171 4/1/2011 2.350 0.260 0.179 60,984 15,831 10,928

PE-10000 XP PRO White 10000/1 PE 120068 3/1/20112

2.450 2.548 2.646 4/8/2011 2.960 0.412 0.314 78,995 32,546 24,804

7600 Golf Green 7600/1 PP 120160 3/1/20112

2.220 2.309 2.398 4/1/2011 2.440 0.131 0.042 25,854 3,392 1,096

7600 Golf Green 7600/1 PP 120160 3/1/20112

2.220 2.309 2.398 5/9/2011 2.650 0.341 0.252 41,251 14,075 10,412

PE-10000 XP PRO Brt-Yellow-08 10000/1 PE 120194 3/1/20112

2.500 2.600 2.700 4/8/2011 3.010 0.410 0.310 37,386 15,328 11,590

PE-10000 XP PRO Red Clay 10000/1 PE 120197 3/1/20112

2.620 2.725 2.830 5/11/2011 3.130 0.405 0.300 83,982 34,030 25,228

PE-10000 XP PRO Tarkett - 8 10000/1 PE 120214 3/1/20112

2.210 2.298 2.387 4/11/2011 2.700 0.402 0.313 8,333 3,347 2,6101

One invoice on 5/16/2011 used pre April 2011 prices Total Impact 511,483 369,0842

Pre increase invoice unavailable for product. Pre increase price obtained from price list dated 3/1/2011.

Sources: FT00408209 - FT00408219; FT00408191 - FT00408208; FT00408089 - FT00408190; FT00408051 - FT00408088; FT00413857; FT00041987; and FT00005846.

Calculation of Damages for Improper Price Increases After April 2011Exhibit 14

Impact of Improper Price Increase in Excess of 4% - 8%: $369,084 - $511,483

CONFIDENTIAL


Product Quantity Avg. Unit Cost Value Write Down Net Value

RM-FEVOLUTION 3GS-MONO-FG/OG 3,322 2.22 7,384 3,692 3,692

RM-FEVOLUTION3GS-MONO 392,984 2.05 804,580 563,206 241,374

RM-FEVOLUTION3GS-MONO-RED 22,221 2.66 59,147 - 59,147

RM-FEVOLUTION-BLACK-MONO 10,319 2.71 27,969 - 27,969

RM-FEVOLUTION-BOISEBLUE-MONO 5,166 2.60 13,432 - 13,432

RM-FEVOLUTION-BOISEORANGE-MONO 6,005 2.60 15,613 - 15,613

RM-FEVOLUTION-BROWN-MONO 11,778 2.44 28,738 - 28,738

RM-FEVOLUTION-BURNTORANGE-MONO 8,083 2.54 20,563 - 20,563

RM-FEVOLUTION-CANARYYELLOW-MON 42,828 2.59 111,068 - 111,068

RM-FEVOLUTION-DARKMAROON-MONO 4,558 2.60 11,851 - 11,851

RM-FEVOLUTION-FG/LG-MONO 9,278 2.09 19,385 - 19,385

RM-FEVOLUTION-JETS GREEN-MONO 802 2.71 2,173 2,173 -

RM-FEVOLUTION-LAGOON BLUE-MONO 15,816 2.00 31,632 - 31,632

RM-FEVOLUTION-LIGHTBLUE-MONO 6,940 2.70 18,723 - 18,723

RM-FEVOLUTION-MAROON-MONO 38,647 2.75 106,423 - 106,423

RM-FEVOLUTION-METALL GOLD-MONO 3,585 2.70 9,689 - 9,689

RM-FEVOLUTION-NAVYBLUE-MONO 28,453 2.77 78,699 - 78,699

RM-FEVOLUTION-ORANGE-MONO 13,668 2.62 35,799 - 35,799

RM-FEVOLUTION-PALACERED-MONO 15,944 2.78 44,246 - 44,246

RM-FEVOLUTION-PURPLE-MONO 18,450 2.56 47,228 - 47,228

RM-FEVOLUTION-RLFXBLUE-MONO 46,252 2.77 128,258 - 128,258

RM-FEVOLUTION-RUST-MONO 23,207 2.72 63,221 - 63,221

RM-FEVOLUTION-SILVER-MONO 14,397 2.39 34,433 - 34,433

RM-FEVOLUTION-SUMGRN-MONO 36,516 2.02 73,589 - 73,589

RM-FEVOLUTION-TAN-MONO 14,325 2.69 38,543 - 38,543

RM-FEVOLUTION-WHITE-MONO 35,619 2.59 92,259 - 92,259

RM-FEVOLUTION-YELLOW-MONO 25,868 2.33 60,394 - 60,394

Grand Total 855,031 2.39 1,985,037 569,070 1,415,966

Source: FT00414180

Exhibit 15

Value of Remaining Inventory of Evolution Fiber Raw Materials at Issue

HIGHLY CONFIDENTIAL


Product Quantity Avg. Unit Cost Value Write Down Net Value

FTOM 1F 204,246 0.88 179,549 89,774 89,774

FTOM 1S 115,395 0.91 105,464 52,732 52,732

FTOM 1S - C 125,561 0.93 116,742 - 116,742

FTOM 1S - W 2,474 0.98 2,417 - 2,417

FTOM 1S - Y 13,155 0.95 12,556 - 12,556

FTOM 2B 675 0.73 491 246 246

FTOM 2S 41,955 0.81 34,001 17,001 17,001

FTOM 2S - C 98,689 0.84 83,200 - 83,200

FTOM 2S - W 10,860 0.88 9,532 - 9,532

FTOM 2S - Y 25,635 0.82 21,082 - 21,082

FTOM 3S 64,800 0.84 54,203 27,101 27,101

FTOM 3S - C 4,140 1.00 4,119 - 4,119

FTOM 3S - Y 90 0.98 88 - 88

XM-44 11,310 0.94 10,687 5,344 5,344

XM-44 - C 375 1.20 451 - 451

XM-44 - W 1,170 1.13 1,325 - 1,325

XM-44 - Y 2,280 0.75 1,710 - 1,710

XM-44-HHS 555 1.15 639 320 320

XM-45NY 3,030 0.80 2,424 1,212 1,212

XM-46 5,100 1.01 5,132 2,566 2,566

XM-46 - C 14,400 1.20 17,220 - 17,220

XM-50 20,085 0.84 16,883 8,441 8,441

XM-50 - C 8,985 0.92 8,267 - 8,267

XM-50 - W 3,090 0.66 2,050 - 2,050

XM-50 - Y 1,755 0.70 1,231 - 1,231

XM-57-PH-GHS 2,070 1.26 2,612 1,306 1,306

XM-60 224,353 0.86 193,994 96,997 96,997

XM-60 - C 61,656 0.95 58,352 - 58,352

XM-60 - W 2,865 0.88 2,514 - 2,514

XM-60 - Y 3,150 0.90 2,832 - 2,832

XM-65 13,470 0.91 12,282 6,141 6,141

XM-65 - W 525 0.93 490 - 490

XM-65 - Y 750 0.75 563 - 563

XM-65-PH 315 0.75 236 118 118

Grand Total 1,088,964 0.91 965,338 309,298 656,040

Source: FT00414180

Exhibit 16

Value of Remaining Inventory of Evolution Fiber Rolls at Issue

HIGHLY CONFIDENTIAL


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